Jonathan W. Birdt V. The United States Practical Shooting Association

Court of Appeals of Washington·Decided July 13, 2026·No. 89299-1·Unpublished

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON JONATHAN W. BIRDT, No. 89299-1-I Appellant, DIVISION ONE

v.

UNPUBLISHED OPINION

THE UNITED STATES PRATICAL SHOOTING ASSOCIATION/IPSC,

Respondent.

SMITH, J. — Jonathan W. Birdt was a director at United States Practical Shooting Association/IPSC (USPSA). Birdt initiated a lawsuit against USPSA seeking judicial dissolution for its refusal to give him access to corporate records. The court concluded that Birdt did not have standing, and the court did not have subject-matter jurisdiction or personal jurisdiction, and dismissed the case. Finding no error, we affirm.

FACTS

In January 2025, United States Practical Shooting Association/IPSC (USPSA) elected Jonathan W. Birdt as a director. USPSA is a non-profit corporation incorporated in Delaware and registered in the state of Washington. Upon taking office, Birdt requested access to various corporate records. USPSA denied his requests.

In March 2025, Birdt initiated a complaint against USPSA. In his complaint, Birdt contended that USPSA wrongfully denied his access to

corporate documents, failed to maintain statutorily required meeting records, and made false statements about the existence of these records. Under RCW 24.03A.936, Birdt requested the court appoint a receiver to “wind up” and liquidate USPSA, or, in the alternative, to manage the affairs of the corporation until the court decides whether a decree of dissolution should be issued.

In May 2025, USPSA moved for judgment on the pleadings, contending the court lacked personal and subject matter jurisdiction, the court was an improper venue, and the action should be dismissed under forum non conveniens.1 USPSA alleged that its only connections with Washington State since 2022 were a single mail drop and a registered agent appointed to receive legal documents.

Birdt cross-moved for summary judgment. Birdt contended USPSA was domiciled in Washington, with its principal place of business in Skagit County, thereby conferring jurisdiction to the court. In its opposition to Birdt’s motion, USPSA realleged its original claims and further contended Birdt lacked standing because he was no longer a director.2 The court denied both motions without

1 At the hearing, the court converted the motion to a motion for summary judgment because Birdt requested judicial notice of publicly available documents including, (1) a 2023 legal filing in Ohio by USPSA declaring Washington is the corporate headquarters of USPSA; (2) a 2025 trademark filing listing Washington as corporate’s address; (3) IRS EIN filing showing the non-profit is located in Sedro Woodley, including copies of return from 2020-2021; (4) Washington Charity registration; (5) Cover page from a 2016 Skagit Superior Court Case No. 162 005040 admitting headquarters in Skagit County; (6) Form 990 for 2023 showing business income in Skagit County, and (7) Workers Compensation report defendant claiming 7-10 employees in Skagit County covered by Washington State Workers Compensation Insurance.

2 After Birdt initiated his complaint, USPSA removed him from his position.

prejudice, concluding genuine questions of material fact existed with respect to USPSA’s connection with Washington.

In September 2025, USPSA again moved for judgment on the pleadings, reasserting the issues of standing and subject-matter jurisdiction. Birdt also moved for summary judgment. The court denied both motions without prejudice, and ordered the parties to take part in an evidentiary hearing on the issue of jurisdiction.

After an evidentiary hearing in November 2025, the court issued an order, concluding Birdt had standing to pursue his claims because the court had both

subject matter and personal jurisdiction. Specifically, the court found:

[Birdt] was a director at the time of filing this lawsuit, and he is no longer a director, in part due to his claims connected with this litigation.

....

Between 1987 and 2023 USPSA maintained a physical office in Skagit County, with employees. It has never maintained a physical office outside of Skagit County.

All of the organization’s bank accounts, charitable trust funds, and investment accounts are held by financial institutions within the state of Washington.

The organization’s legal filings, trademarks, non-profit filings with the IRS, and tax returns all identify Skagit County as its principal place of business.

USPSA moved for reconsideration. The court granted USPSA’s motion, simply noting “[USPSA’s] Motion for Reconsideration is granted and [Birdt’s] Complaint is dismissed with prejudice for lack of standing, subject matter jurisdiction, and personal jurisdiction.” Birdt appeals.

ANALYSIS

Standard of Review

We review de novo the dismissal for lack of standing, subject-matter jurisdiction, and personal jurisdiction. Wash. Bankers Ass’n v. State, 198 Wn.2d 418, 455, 495 P.3d 808 (2021) (standing); Dougherty v. Dep't of Lab. & Indus., 150 Wn.2d 310, 314, 76 P.3d 1183 (2003) (subject matter jurisdiction); State v. LG Elecs., Inc., 186 Wn.2d 169, 176, 375 P.3d 1035 (2016) (personal jurisdiction).

Standing

Birdt contends the trial court erred because depriving him of standing is contrary to the legislative intent of allowing a director to seek relief under RCW 24.03A.936(2) and would render the Washington Nonprofit Corporation Act3 (WNCA) worthless. Because Birdt is no longer a director of USPSA, and he has no ongoing fiduciary relationship with USPSA or a legitimate basis to represent USPSA, we conclude the trial court did not err when it dismissed the case based on standing.

RCW 24.03A.936(2) authorizes a director to seek judicial dissolution of a nonprofit corporation. However, not every individual who ever served as a director falls within the statutory definition.

“[A] single word in a statute should not be read in isolation, and . . . ‘the meaning of words may be indicated or controlled by those with which they are associated.’ ” State v. Roggenkamp, 153 Wn.2d 614, 623, 106 P.3d 196 (2005)

3 Chapter 24.03 RCW.

(internal quotation marks omitted) (quoting State v. Jackson, 137 Wn.2d 712, 729, 976 P.2d 1229 (1999)). This principle is known as “noscitur a sociis.” Roggenkamp, 153 Wn.2d at 623.

Applying the cannon of noscitur a sociis, the word “director” should be interpreted consistently with other persons authorized to initiate judicial dissolution under RCW 24.03A.936(2). In addition to a director, the statute permits two other categories of individuals to initiate dissolution: “fifty members” or “members holding at least five percent of the voting power.” RCW 24.03A.936(2). These two categories share a common characteristic: each represent a group with substantial and ongoing relationships with the corporation. Generally, “ ‘directors shall be deemed to stand in a fiduciary relation to the corporation.’ ” State ex rel. Hayes Oyster Co. v. Keypoint Oyster Co., 64 Wn.2d 375, 381, 391 P.2d 979 (1964) (quoting RCW 23.01.360). Directors “ ‘shall discharge the duties of their respective positions in good faith, and with that diligence, care and skill which ordinarily prudent men would exercise under similar circumstances in like positions.’ ” Keypoint Oyster Co., 64 Wn.2d at 381. (quoting RCW 23.01.360). But, once an individual ceases to be a director, they no longer owe a fiduciary duty and do not have a substantial and ongoing relationship with the corporation. Allowing a former director to have continued standing would grant an individual, whose relationship with the corporation has already ended, access to confidential corporate records and the ability to seek judicial dissolution of the corporation.

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Jonathan W. Birdt V. The United States Practical Shooting Association, (Wash. Ct. App. 2026).

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