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Labor Law-Prima Facie Tort Doctrine Bars Unreasonable Deprivation Of Union Membership-Hurwitz V. Directors Guild Of America, Inc., Michigan Law Review
Labor Law-Prima Facie Tort Doctrine Bars Unreasonable Deprivation Of Union Membership-Hurwitz V. Directors Guild Of America, Inc., Michigan Law Review
Michigan Law Review
In July 1965 the officers of the Directors Guild of America (DGA) and the Screen Directors International Guild (SDIG) concluded a merger agreement which provided that DGA was to be the surviving union and SDIG members were to become members of DGA automatically upon signing the DGA non-Communist loyalty oath. Although the SDIG membership ratified the merger agreement by a majority vote, six members steadfastly refused to sign the oath and as a result were not admitted to membership in DGA. They thereupon brought a diversity suit in a New York federal district court: and moved for a preliminary injunction …