Lynn v. Pleasant Valley Country Club, 54 A.3d 915

Lynn sought to add his granddaughter to his senior life membership under Pleasant Valley’s bylaws; the Board denied the request.
A special stockholders’ meeting in June 2009 voted 46 to 44 against Lynn’s request; the Board did not rescind its denial.
Bylaws permit a senior life member (unmarried) to designate an opposite-sex person with board approval to enjoy the same privileges.
Pre-amendment bylaws did not require board approval for designations; amendment on November 20, 2000 changed the requirement to seek board approval for new designations.
Trial court found the Board’s denial supported by competent evidence; post-trial relief was denied; judgment entered November 7, 2011.
Appellant appealed timely; Pa. Superior Court reviews post-trial rulings for legal error and supported findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Board’s denial violated § 5751 equal enforcement	Lynn argues bylaws must be equally enforced for all members in the same class.	Pleasant Valley asserts board governance and discretion authorize the denial.	No error; board discretion upheld.
Whether prior members with opposite-sex privileges show equal application of the bylaw	Lynn points to others granted privileges without explicit board approval.	Board exercised discretion; discretionary approvals were not uniformly required by pre/amendments.	No merit; decisions supported by evidence of discretionary enforcement.
Whether trial court should have admitted or considered testimony about prior designations	Evidence of prior permissive designations supports Lynn’s claim of equal treatment.	Pre-amendment evidence improper and not controlling for current bylaw interpretation.	Evidence insufficient to establish bad faith or non-uniform enforcement.
Whether board’s role is subordinate to membership votes in overruling Board decisions	June 2009 member vote should override the Board.	Bylaws do not permit member veto; Board decisions stand unless bylaw provides override.	Merits lacking; membership vote immaterial to Board authority.
Whether the court should compel adding the granddaughter to Lynn’s membership	Board should be required to grant the designation.	No statutory or bylaw provision granting such compelled action by court.	No; court affirmed judgment for Pleasant Valley.

Lebanon County Housing Authority v. Landeck, 967 A.2d 1009 (Pa. Super. 2009) (appellate review of factual findings limited; no substitution of judgment)
Hollock v. Erie Insurance Exchange, 842 A.2d 409 (Pa. Super. 2004) (credibility not to be reassessed on appeal; factual sufficiency standard)
Anderson v. Colonial Country Club, 739 A.2d 1118 (Pa. Cmwlth. 1999) (court deferential when board actions lack bad faith or ultra vires)
Billig v. Skvarla, 858 A.2d 1042 (Pa. Super. 2004) (appeal from post-trial motions—appellate review of judgment timing)
Calabrese v. Zeager, 976 A.2d 1151 (Pa. Super. 2009) (timeliness and scope of appellate review in post-trial context)