Pizer v. Trade Union Service, Inc.
The plaintiff, as president of a labor union, initiated an action seeking to obtain a roster of the union membership from an independent trade newspaper. The defendant, currently possessing the list, was instructed by the union's secretary-treasurer not to release it to the plaintiff due to an internal union dispute concerning the plaintiff's authority and alleged personal use of the list. The defendant's contract with the union did not explicitly provide for such delivery. The Special Term had previously granted a temporary injunction compelling the defendant to surrender the list. However, the appellate court reversed this decision, stating that a mandatory injunction pendente lite is an extraordinary measure justified only in unusual situations to maintain the status quo, which was not the case here given the sharp factual dispute. The court denied the motion and emphasized the need for a speedy plenary trial.