Robinson v. Supreme Council of American Fraternal Circle

1 Balt. C. Rep. 245
CourtBaltimore City Circuit Court
DecidedMay 16, 1892
StatusPublished

This text of 1 Balt. C. Rep. 245 (Robinson v. Supreme Council of American Fraternal Circle) is published on Counsel Stack Legal Research, covering Baltimore City Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robinson v. Supreme Council of American Fraternal Circle, 1 Balt. C. Rep. 245 (Md. Super. Ct. 1892).

Opinion

PHELPS and DENNIS, J.J.

On the 3d of February, 1892, the defendant corporation adopted certain amendments to their by-laws, purporting to effect material alterations in the contracts evidenced by the certificates issued to the contributing members of the order, in number, some [246]*246twenty thousand. 'Immediately thereupon, numerous bills were filed by dissatisfied members against the corporation, some in this court, and others in the Circuit Court of Baltimore City. Differing somewhat in their allegations, the object of all these bills was substantially the same, the winding up of the concern by the appointment of receivers.

The suits first instituted in both courts were so nearly simultaneous that a question of priority was raised. It was deemed proper that this question of jurisdiction should be determined by the judges of the two courts, together. Upon the showing made, it appeared that the case first above named was entitled to priority, and the case entitled thereunder was by consent consolidated therewith. It was then ordered that the hearing upon the merits should also be before the judges of both courts in which cases of similar character were pending, the decision involving a responsibility so grave as the proposed liquidation of a concern whose cash assets actual and accruing, amounted to nearly one million dollars.

No exceptions have been filed to any of the testimony offered, documentary or oral. In the able argument of defendants counsel, it was stated that their preference was to meet the case on its merits, as disclosed by the evidence. The same method will be followed by the court.

Several questions of a more or less technical character were raised by the pleadings and discussed at length which we do not find it necessary to consider. The view which we take of this controversy is limited mainly to the substantial charges of breach' of trust and imminent danger to the fund. As incidental thereto, and as bearing upon the question of intent, circumstances of usurpation of power, exclusion of members from representation, suggestio falsi and swppressio veri, wili first be briefly referred to.

In order to understand the scope of this inquiry it will be necessary to premise that the organization known as the American Fraternal Circle is exceptional in its structure.

Ordinarily, benefit societies are organized upon a representative basis. Their grand lodges are composed of delegates from the local lodges, and the, supreme lodge'is composed of delegates from the grand lodges. (Bacon Ben. Soc., See. 11, 144.) They are worked upon the familiar democratic or republican principles to which our people are accustomed. They have their own judicial tribunals to which every officer, however exalted in the hierarchy, is responsible; members, however humble, are protected from oppressive exhibitions of irresponsible power.

The original corporators of the Supreme Council of the American Fraternal Circle have been engaged in experimenting upon an altogether different line. Without at present going into details, it is enough to say m limine, that they resolved themselves into a close corporation, designedly excluded all other members of the order from representation in the governing body, appointed themselves to all the supreme offices, and made those offices lucrative. They enacted the original by-laws, and have from time to time altered them at their pleasure. They have so framed all their contracts with members, as to claim that the members are absolutely bound to all their alterations of these contracts. They claim and exercise supreme administration over the affairs of the order, without accountability or appeal. There is no judicial machinery provided to hold any of their number responsible upon any charge whatever, except to a committee of their own body. There is no means provided by which the order, if dissatisfied, can remove any one of them from office, or substitute a more acceptable person.

In direct violation of Statute Law, they have attempted to extend their own term of office to four years, failed to hold annual elections, or any other elections, and of course failed to give any public notice of such elections. (Article 21, Section 57.)

Over the general fund of the order their control is virtually absolute. Over the reserve fund the by-laws provide for an outside Board of Trustees, whose signature is required to its withdrawal. Since they claim the right to repeal by-laws at their discretion, the protection thus afforded is precarious at best, and it is shown that the function itself is practically of a nominal character.

These six Supreme Officers are the real trustees. The large amounts of money in their custody are trust funds, [247]*247the cestui-que trusts are the certificate holders.

In view of the unlimited confidence reposed, of the magnitude of the interests' at stake, of the opportunities for abuse, and of the extensive powers assumed and exercised, the circumstances here are such as to devolve upon the trustees a very high degree of responsibility. Their position is one of their own making, and is such as to exact, of them the utmost good faith. They must expect to be held at all timos to a strict accountability. The temptations to abuse powers so unusual in their scope require corresponding vigilance on the part of the court. The defenceless position of the certificate holders, their inability to secure protection within the lines of the order, the fact that they are practically at the mercy of the trustees, all these circumstances are to be held in view when considering the conduct of the trustees as to good or bad faith.

Such being the peculiar character of this organization, as we find it, the first inquiry relates to the manner in which the trustees have used or abused their legislative power in such wise as to exclude all their fellow members of the order from representation in the governing body.

In the original by-laws provision was made for the election of State representatives. The Supreme Council at the outset of its career appeared before the public claiming to be partially, at least, a representative body. No State representative has ever been elected; but the by-laws have been so altered, by successive enlargements of the basis of representation, as to make any such election in effect impossible. Should the constituency in any locality hereafter be increased to the standard at present required, there is good reason to apprehend from past experience that the by-laws will again be changed to meet the emergency, and the basis of representation be again enlarged. There is here plain manifestation of intention on the part of the six managers to retain absolute power.

Tf it be said that least they had the legal right to make such amendments, what shall be said of their enlargement of their term of office to four years?

This was done by changing the bylaws in direct violation of the Code, and without notice to members or opportunity on their part to be heard.

In thus taking advantage of their fiduciary position and legislative power, the trustees were plainly actuated by private and interested motives. They at once elected themselves to all the supreme offices, and hastened to allow themselves salaries, excessive as to some, liberal as to all. As to three of these offices, there was no authority for compensation in the original bylaws, but this was found to be no difficulty. The manner of doing the thing was especially objectionable and mysterious.

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Bluebook (online)
1 Balt. C. Rep. 245, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robinson-v-supreme-council-of-american-fraternal-circle-mdcirctctbalt-1892.