5

Zehner v. Wilkinson Memorial United Methodist Church, 581 A.2d 1388 (Pa. Super. 1990). See also Crocker v. Barr, 367 S.E.2d 471 (S.C. App. 1988) (“a member of a voluntary unincorporated association . . . cannot maintain an action in tort against the association for injuries suffered by the member because of the negligence of fellow members”).