Lyons v. American Legion Post No. 650 Realty Co.

In the cases of Koogler et al., Trustees, v. Koogler (1933), 127 Ohio St., 57, 186 N. E., 725; State v. Fremont Lodge of Loyal Order of Moose (1949), 151 Ohio St., 19, 84 N. E. (2d), 498; and Damm v. Elyria Lodge No. 465, B. P. O. E. (1952), 158 Ohio St., 107, 107 N. E. (2d), 337, it was either indicated or held that, since a voluntary unincorporated association had no status as a legal entity, an action against it as such would not lie, and that ordinarily any action had to be brought against the individual members of such an association collectively and conjointly.

Or stating it in another…