Mary C. Wilcox, Respondent v. Supreme Council of the Royal Arcanum, Appellant

Summary

The New York Court of Appeals affirmed the Appellate Division's judgment that the expulsion of Frank Z. Wilcox from the Royal Arcanum was void because the trial committee members were disqualified by a direct interest in the controversy. The court held that while expulsion proceedings themselves are not subject to judicial review, a collateral action to enforce a benefit certificate may examine the jurisdiction of the committee that conducted the expulsion.