Yeong Wo is an unincorporated association that serves as an umbrella group for a dozen constituent organizations, called “tangs.”  In Hee Shen Cemetery & Benevolent Assoc. v. Yeong Wo Assoc., 2024 WL 938928 (March 5, 2024), the plaintiff, Hee Shen, asked the Superior Court to intervene in a disputed election of the president of Yeong Wo.  The election was so disputed that the police were called to maintain order at the disputed election meeting.

After a bench trial, the Superior Court held that  Yeong Wo’s bylaws were “clear and unambiguous" and that  Yeong Wo had violated its bylaws by “choosing to add additional candidates to the voting list that were not recommended/approved by [Hee Shen].”   The Court of Appeal disagreed, holding that the trial court should not have intervened.  The Court of Appeal based its holding on the California Supreme Court's decision in California Dental Assn. v. American Dental Assn.,  23 Cal. 3d 346 (1979).  According to the Court of Appeal, California Dental established "a two-part framework for courts to determine whether they should wade into the 'dismal swamp' of disputes within a private voluntary association regarding its own bylaws":

• Judicial intervention is appropriate only if an association has abused its discretion by unreasonably construing a plain and unambiguous provision of its bylaws.
•  If an association has done so, then the extent to which judicial relief is available depends on balancing the interests of the aggrieved party against the burden on the courts and infringement on the association’s autonomy.