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Ratajczak v. Olde York Country Club

A-4995-01T2 (N.J. Super. App. Div. 2003) (Unpublished)

ASSOCIATIONS—Judicial intervention in the internal affairs of a private membership association is only required when an individual is being deprived of a significant interest in either liberty or property.

A country club declined to renew a member’s annual membership after the member withheld payment of his restaurant dues. The member sued, alleging “that his reasonable expectation of lifetime membership was thwarted when the club terminated his membership notwithstanding its failure to comply with its own termination procedures; that the substandard food and service at the Club’s restaurant facility constituted a breach of contract; and that the services provided by the Club violated the [Consumer Fraud Act].” The lower court dismissed the complaint and the Appellate Division agreed. In dismissing the complaint, the lower court was “satisfied that this [was] a privately owned Club and the [members did] not have an automatic right to demand that his membership continue for future years. As a private association, the Club [was] entitled to the utmost latitude and the regulation and management of its own internal affairs. It may have been that his complaint regarding the quality of the food and the service there was what irritated these folks. But there’s no remedy for excluding someone from admission into a voluntary association no matter how arbitrary or unjust the reasoning. ... In New Jersey the law allows a private organization to do just what [this country club did] here. Judicial intervention is only required when an individual is being deprived of a significant interest in either liberty or property.”


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