Harry Martin v. Joseph Curran

Summary

The New York Court of Appeals affirmed the Appellate Division's dismissal of the libel complaint against the National Maritime Union officers in their representative capacities because the complaint failed to allege member authorization or ratification, and it also affirmed the lower court's discretion to strike paragraphs 13 and 15 of the complaint. Justice Conway dissented, arguing that the union and its officers should be liable without such allegations.