Ashe v. Yale University

Summary

The Connecticut Appellate Court affirmed the trial court’s judgment in favor of Yale University in a dispute concerning the election of alumni fellows to Yale’s board of trustees. The court held that the plaintiffs lacked standing to enforce Yale’s charter as third-party beneficiaries because the charter did not impose a particular election method for alumni fellows and was intended to benefit Yale. The court also held that the plaintiffs lacked statutory standing to challenge Yale’s election practices as ultra vires under the Connecticut Revised Nonstock Corporation Act because they were not members of the nonstock corporation.

Holdings

1. The plaintiffs were not third-party beneficiaries of Yale's charter and therefore lacked standing to pursue their breach-of-contract claim. The charter authorized Yale to regulate the alumni fellow election process and did not obligate Yale to maintain a particular nomination method, including the petition process.
2. Yale alumni were not members of Yale within the meaning of the Connecticut Revised Nonstock Corporation Act and therefore lacked standing under General Statutes § 33-1038 (b) (1) to challenge Yale's alleged ultra vires acts.

Questions Presented

1. Whether the plaintiffs had standing as third-party beneficiaries of Yale's charter to pursue a breach-of-contract claim challenging Yale's regulation of alumni fellow elections and elimination of the petition process.
2. Whether Yale alumni were members of the nonstock corporation within the meaning of General Statutes § 33-1038 (b) (1) and therefore had standing to bring an ultra vires action under the Connecticut Revised Nonstock Corporation Act.

Disposition

affirmed