1550 MP Road, LLC v. Teamsters Local Union No. 700

This case presents question as to whether trial court properly found that defendant-union had breached terms of lease of premises under corporate successor liability theory, where different union had entered into said lease, and where defendant had acquired assets of said union following said union’s dissolution. While defendant argued that lease was void ab initio and could not be enforced because it was not executed in conformity with former union’s bylaws or with Property of Unincorporated Associations Act (Act), Appellate Court, in affirming judgment in favor of plaintiff, found that former union’s failure to comply with its bylaws or with Act did not render lease void ab initio, and that instant defendant was liable for breach of lease based on corporate successor liability principles, where defendant had acquired and retained former union’s operations and had knowledge of instant lease at time of asset acquisition. Appellate Court further noted that nothing in Act outweighed state’s preferred policy of enforcing otherwise legal private contracts entered into for legitimate reasons.