WEST PALM BEACH -- The Florida Fourth District Court of Appeal has overturned a ruling from the 19th Judicial Circuit in a dispute between The Naked Lady Ranch Inc. (NLRI) and Michael Wycoki Jr. regarding the termination of his membership.
In its five-page ruling, the court said Nov. 20 the lower court had “erred in conducting a de novo inquiry into the merits of NLRI’s disciplinary decision.” It went on to state that the “defendant’s membership was suspended and terminated pursuant to a procedure that was fair and reasonable,” and that was done in “good faith” pursuant to Florida law.
The appeals court brought up the rule of judicial deference, in which “courts ordinarily will not intervene in the internal affairs of voluntary organizations.” It noted that it’s “well-established” that private groups and organizations make the final decision in terminating one’s membership to the organization.
The court disagreed with Wycoki’s argument that the NRLI board was “powerless to suspend a member once admitted.” The judges pointed out that the NRLI bylaws gave the board broad powers in its discretion. Also, according to the court, Florida law states that a not-for-profit corporation can suspend or terminate a member who fails to comply with the terms and conditions of membership,” as long as that action is “fair and reasonable and carried out in good faith.”
Wycoki also argued to the court that his loss of membership was “unauthorized” because he met the basic membership requirement of owning a 5-acre parcel of land in the housing community. The appeals court said it “disagreed” with Wycoki, finding that in his application to NLRI that a member “may be suspended” if a member’s “actions violate the trust of acceptable airport operations.”
Wycoki’s membership to NRLI was terminated after he repeatedly used the airport in the community for flights that the board considered to be “commercial operations” after he was warned not to. NRLI filed a lawsuit against Wycoki when he still flew out of the community airport after his membership was terminated. The trial court found in favor of Wycoki, which led the NRLI to appeal.