What is the test for standing to bring a derivative action in a non-profit corporation?

We also conclude that the trial court erred in determining that plaintiff has no standing to bring this derivative action. This determination was based on textbook language that a plaintiff in such case 'cannot recover unless he shows [175 Cal.App.2d 841] an injury to himself, in addition to an injury to the corporation' (13 Fletcher on Corporations [Rev.Vol.] 309). A full reading of the cited section ( 5948), particularly in the light of other language (see 5816), indicates that the author means only to state that a stockholder who is 'in nowise affected, directly or indirectly,' cannot sue. But appellant has shown that he would be so affected. Even if an individual member of this union would have no interest in distribution of the corporation's assets on dissolution as respondents claim, he would nonetheless suffer an indirect adverse affect if the financial stability of the union were endangered by the making of illegal payments. Sick benefits and death or funeral benefits are provided for by the by-laws and seem clearly to give each member of the incorporated union an interest in its continued financial soundness. Thus even if the rule relied upon by respondents were followed in California, this action would not be barred. However, the California rule does not require that a member of a non-profit corporation show individual damage to himself in order to bring an action in behalf of the corporation. Malone v. Superior Court, 40 Cal.2d 546, 254 P.2d 517. The decision principally relied upon by respondents (Briggs v. Scripps, 13 Cal.App.2d 43, 56 P.2d 277) states only the obvious rule that a stockholder may not maintain an action on behalf of a corporation unless there is a showing of some injury to the corporation.

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