Carlson v. Rabkin

Mark P. Painter, Judge.

{¶ 1} Plaintiffs-appellants, members and former members (we refer to all as “members” except where a distinction is relevant) of Save the Animals Foundation (“STAF”), appeal the trial court’s dismissal of their complaint against the defendants-appellees, directors of STAF and STAF itself. We conclude that three of the members’ five causes of action were properly dismissed. But we hold that because the members’ complaint stated a prima facie case for two of their claims, the members’ complaint should not have been dismissed in its entirety. We therefore reverse the trial…