Tannenbaum v. Hofbauer
The plaintiff filed a motion to set aside the dismissal of their complaint, which sought damages for an alleged assault and battery perpetrated by unidentified men acting under the direction of Powers, a business agent of the defendant union during a strike. The plaintiff's evidence indicated the tortious act was committed by a union agent in furtherance of the strike. However, there was no evidence of official union authorization for the act, nor was the agent's unlawful activity sufficiently notorious or prolonged to infer knowledge and acquiescence from the union membership. Citing established precedent, the court reiterated that to hold a voluntary, unincorporated association liable, facts must prove all members are liable, either through a public act of the association or member-approved acts of its agents. The court found that the evidence presented was insufficient to bind the entire union membership, requiring clear and convincing evidence to identify the union with the individual acts. Consequently, the plaintiff's motion to set aside the dismissal was denied.