Barrett v. New York Republican State Committee

Judgment unanimously reversed on the law without costs and motion denied. Memorandum: Supreme Court erred in granting plaintiff summary judgment for $260,000 against *990defendant New York Republican State Committee (Committee), an unincorporated association, on three promissory notes payable to plaintiff and executed by defendant Lewis Bart Stone as Treasurer of the Committee. "[S]ince a voluntary, unincorporated association has no existence separate and apart from its members, an association is not liable on the contracts of its officers, agents, or individual members in the absence of prior…