Generally, a court will not interfere with the internal affairs of voluntary associations absent mistake, fraud, collusion or arbitrariness. 125 Ill. App. If there has been no mistake, fraud, collusion or arbitrariness, our supreme court has endorsed the exercise of jurisdiction only when a substantial property, contract, or other economic right that implicates due process is at stake. In granting summary judgment for defendants on the breach of contract count, the trial court found that the Board acted consistently with the Club's bylaws when it imposed the cap on veteran members. The trial court's review of this case should have ended there.
Plaintiffs argue that, because their injury is economic, judicial intervention is warranted.
But Illinois courts have never held that classifying an injury as economic is sufficient to subject a voluntary association's decision to judicial review. Not all economic injuries implicate due process concerns. 51 Ill. 2d at 394. Certified offered substantial economic benefits to its members, including lower grocery prices and rebates. 51 Ill. 2d at 395.