The 7th U.S. Circuit Court of Appeals has affirmed a trial court’s ruling in a case involving a card player, who sought legal intervention after the American Contract Bridge League suspended him for 18 months.
Specifically, the panel agreed with the trial court that the plaintiff had not demonstrated any of the exceptions that would allow the court to usurp the rules of a “volunteer membership organization like the ACBL.”
John E. Blubaugh was suspended from all ACBL play in the spring of 2001 after the league determined that he had, while dealing the cards, manipulated a specific card so that his partner would receive it. Blubaugh appealed the the decision of the Ethical Oversight Committee, but the Board of Directors affirmed the ruling.
Blubaugh turned to the courts, alleging 19 causes of action, including breach of contract, tortious interference, defamation, violation of the Sherman Anti-Trust Act and violation of the Racketeer Influenced and Corrupt Organizations Act. The league moved for summary judgment, which the district court granted.
Blubaugh appealed. The panel noted that “Whether Blubaugh is, in fact, a card cheat is of no great consequence to this Court; we do not sit in place of the ACBL in weighing the case against Blubaugh. The district court correctly noted that the ‘central defect running throughout the Complaint lies in Blubaugh’s erroneous and expansive view of the court’s role in overseeing the internal affairs of a voluntary membership organization like the ACBL.’ Blubaugh v. Am. Contract Bridge League, 2004 U.S. Dist. LEXIS 3178, No. IP 01-358-C H/K, 2004 WL 392930 (S.D. Ind. February 18, 2004).”
It added that the Indiana Supreme Court has held that Indiana courts “will not interfere in the internal affairs of a voluntary membership organization absent fraud, other illegality, or abuse of civil or property rights having their origin elsewhere. Ind. High Sch. Athletic Ass’n v. Reyes, 694 N.E.2d 249, 256 (Ind. 1997). Therefore, we need only determine whether any of these exceptions exist so as to compel our interference in the internal affairs of the ACBL. None are present in this case.” (Blubaugh v. American Contract Bridge League et al.; 7th Cir.; No. 04-1663; 11/18/04
Attroneys of Record: (for plaintiff) F. Bruce Abel, Cincinnati, OH. (for defendants) James S. Stephenson of Stephenson, Daly, Morow & Kurnik in Indianapolis, IN.
