Justiciability; Freedom of association; Heitmanis v Austin (6th Cir); The political-question doctrine; House Speaker v Governor; An entity’s validly promulgated bylaws as a binding contract between the entity & its members; Conlin v Upton; Subject-matter jurisdiction; Standing; Applicability of quo warranto; Entry of a permanent injunction; Bylaws interpretation & application

The court held that under the undisputed facts, the Michigan Republican State Committee’s members held a valid special meeting and properly removed defendant-Karamo as the State Committee’s chairperson. Thus, the trial court did not err in granting plaintiffs summary disposition in this dispute over control over the State Committee. The court first determined that the “trial court plainly had subject-matter jurisdiction to hear and decide plaintiffs’ claims for declaratory judgment and the enforcement of the State Committee’s bylaws to the extent that the bylaws applied to the parties.” Next, it found that the “trial court’s decision to allow plaintiffs to proceed with their claims did not violate Karamo’s freedom of association or the freedom of association of the State Committee or any” of its members. “The State Committee adopted its own criteria for membership in its bylaws and established how persons become members, remain members, and are removed as members. The bylaws also established the manner by which its various members participate in the association; they identified the rights and duties for its members. The trial court’s decision to allow plaintiffs’ claims to proceed did not alter any of these internal structures; rather, [it] simply recognized that—absent application of some other doctrine governing justiciability—it had the authority to resolve a membership dispute consistent with the State Committee’s bylaws.” The court additionally concluded “the trial court properly applied the test from House Speaker and determined that the dispute at issue was justiciable under the political-question doctrine. There is no law that commits intraparty disputes in a political association to a coordinate branch of government. Further, a court is not precluded from resolving purely legal disputes among the members of a political party.” The court noted that the “complaint and request for relief in this case also did not require the trial court to make a policy determination or resolve a policy dispute.” It further determined that the State Committee’s “bylaws are a binding contractual agreement that gives individual members rights and obligates them to certain duties, which can be enforced by a court sitting at law or in equity.” Based on the complaint’s allegations, “the case was justiciable.” The court also rejected defendant’s claim that the trial court erred in interpreting and applying the bylaws. Affirmed.