Milford School District v. Henlopen Conference

Summary

Milford School District's lawsuit challenges the Henlopen Athletic Conference's moving Milford from the Southern Division, which includes the smaller schools, to the Northern Division, which includes the larger schools.

Whether Milford was appropriately moved to the Northern Division depends on the methodology used for counting Milford's students. Milford contends that the Conference should not have counted students enrolled in a separate school that rented space in the Milford facility, and who therefore attended classes at Milford, but who were not enrolled as Milford students.

The Henlopen Athletic Conference's summary judgment motion was predicated on the argument that the school district should not be allowed to interfere with the internal affairs of a voluntary membership association.

The Court ruled that it would not under the circumstances presented serve as an appeals court for hearing disputes between a voluntary organization and its members. As long as the Board's actions were within the broad objectives of the organization, and did not result in some type of personal pecuniary gain to the officers or directors of that association, the Court would refrain from interfering in the association's internal affairs. Although the Court acknowledged that some circumstances might warrant departure from this general rule, no such circumstances were present in this case. Accordingly, the Court granted the Conference's summary judgment motion and dismissed the case.

The Court advised the School District that its appropriate remedy was to pursue its claims with the Conference, or withdraw from the Conference. The Court also suggested that both laches and the failure to show irreparable harm might also have barred relief.