Developments In Association Law 2021 – 2022

Governance

Striltschuk v. Hryckowian, 202 A.D.3d 497, 160 N.Y.S.3d 56 (2022)
Petitioners brought an action seeking to set aside the election results of directors, officers, and committee members of the not-for-profit Organization for the Defense of Four Freedoms for Ukraine, Inc.; petitioners also filed a motion for injunctive and declaratory relief. The court denied the petition, denied the motion, and dismissed the proceeding; the petitioners appealed. On appeal, the Supreme Court of New York, Appellate Division held that the petitioners fell short of meeting their burden under the New York Not-For-Profit Corporation Law of making "a clear showing" that judicial "interfere[nce] in the internal affairs of [the] corporation ... is ... warrant[ed]."