Its also important to note the reason why the Business Judgement Rule is predisposed to favor the board. An HOA or condo board member can be protected from liability in case of a lawsuit. "}}, In Arizona, an officer, director, or property manager has a duty to act in good faith, act without a conflict of interest, and act in the association's best interests. a homeowner can win a lawsuit against HOA, selective enforcement of rules against residents in the HOA. What are the fiduciary duties of a board member? Make reasonable inquiry re maintenance issues, rules violations, etc. Make decisions. ", The basic fiduciary duties are care, loyalty . "@type": "Question", "@type": "Answer", Living in an environment does not limit or infringe on your human rights, if by chance or anytime you feel that your rights as an individual have been trampled on by your HOA, you can use the following ways and means to tackle it and get victory in court. How to Get a New Roof for Free (5 Best Ways). However, when you feel intimidated, abused, or youre not given the freedom to fundamentally express yourself in a certain way, you can either sue the person, the body, or the organization that is coming against you and gets the justice you deserve. "@type": "Question", "@type": "Question", Specifically, board members must not act . You can fulfill your duty to act by knowing the scope of your authority and obligations. (2) "Represented person" means the principal, beneficiary, partnership, corporation, or other person to . (b) "Represented person" means the principal, beneficiary, partnership . To prove a breach of fiduciary duty, a homeowner must prove three elements; (1) a fiduciary relationship existed between plaintiff and defendant; (2) a breach by the defendant of his fiduciary duty to the plaintiff; and (3) an injury to the plaintiff or benefit to the defendant as a result of the defendant's breach. Heres Why You Need HOA Directors And Officers Insurance, HOA Attorneys Why They Are Important And How To Find One, Failure to maintain community amenities and common areas, Inadequate or lack of security (such as placing security cameras at gates or on private roads), Remodeling disputes or denial of architectural changes. "@type": "Question", They are trusted with the oversight of property or funds. Keep in mind, though, that homeowners will need to provide proof for this claim. Confirm your home address so we can generate state-specific legal arguments on your behalf. "text":"Yes, because a person can be sued by anyone for anything at any time. As such, they are responsible for acting in the best interest of the association's homeowners, who have entrusted their confidence and reliance on them. Generally, you need one of those three elementscriminal activity, unjust enrichment, or fraud." "@type": "Answer", "acceptedAnswer": { "text":"Yes, because a person can be sued by anyone for anything at any time. The courts understand that board members are not perfect. It is also important that they avoid conflict of interest and not make decisions based on personal interests. What Are HOA Disputes? "text":"If HOA board members do not fulfill their fiduciary obligations to the association, they will be held accountable for their actions. Still, as a board member, you shouldnt become lax or abuse your power in any way. When homeowners see that their HOA board is acting responsibly, the more they can trust you with the community. But, theres no guarantee that they will win. Being found in breach of fiduciary duty can yield unwanted consequences. HOA construction defects case where the HOA sued the individual officer and director of the HOA (Ryan) for breach of fiduciary duty based on an alleged failure to adequately inspect and repair construction defects, failure to maintain adequate insurance coverage, and failure to properly maintain the property. It does not rise to the level of a fiduciary duty. "mainEntity": [{ The HOA Declaration includes both the legal and physical descriptions of the entire community. Breach of Fiduciary Duty: The HOA members and board of directors have a fiduciary duty to the corporation. Disgruntled homeowners can still choose to take legal action against you even if their claims are baseless. As such, put aside your personal interests when dealing with HOA matters. "image": [ Board members are ultimately volunteer positions and they are not compensated for the service they provide to the association. "acceptedAnswer": { Still, you must be prepared for whatever they throw at you. Grounds for a Lawsuit LegalMatch cites three circumstances for which a homeowner may sue an HOA. In terms of liability, the fiduciary duty can be a bit of a gray area. "@type": "Answer", Why are a boards duties so important and when have they been breached? You can contact your local authorities to guide you on the procedure to follow. "@type": "Answer", If they do not fulfill their fiduciary obligations to the association, they will be held accountable for their actions. Every person has a duty to act reasonably to avoid harming others. There is a saying that power corrupts, and absolute power corrupts absolutely, this is certain cases when a board member of an HOA can be held personally liable in issues that have to do with the HOA. A leading Illinois case regarding the imposition of punitive damages for breach of fiduciary duty is the Estate of Wernick, 127 Ill.2d 61, 525 N.E.2d 876 (1989). "@type": "Answer", "text":"To put it simply, homeowners can sue condo or HOA board members and even name them personally in the lawsuit. To further provide clarity on this matter, well answer the commonly asked question, "Can you sue HOA board members for bad decisions? "mainEntity": [{ 1. A fiduciary duty (or fiduciary responsibility of HOA board members) is defined as the obligation that a fiduciary owes to the beneficiary. However, if the question is, 'Are HOA or condo board members personally liable for their bad decisions?' } How to Sue HOA for Breach of Fiduciary Duty and Win! HOA board fiduciary responsibility prevents board members from making decisions to further their personal interests. Call now to learn more. By far the best way to avoid a breach of fiduciary duty lawsuit is to approach your job as a board member with seriousness. Directors of community association must: follow state laws pertaining to HOAs or condominiums. "It is not always a simple matter to determine whether a fiduciary relationship exists. 1984) as follows: In addition to the duty of care, directors and officers owe the association a fiduciary duty of loyalty. This is considered a breach of fiduciary duty board of directors is expected to uphold. The state's corporation laws will recognize that the HOA's board members are entrusted with the money (collected from dues and/or fines), property, and the daily business of the association. "acceptedAnswer": { Under Pennsylvania law, an essential element of a breach of fiduciary duty claim is that the "wrong-doing directors must have been unjustly enriched." Some insurance companies may cover legal expenses under the general liability policy. Without further ado, let's get started with today's subject "Fiduciary Duty", as defined by A.R.S 10-3830, A.R.S 33-1811, A.R.S. A fiduciary duty is a responsibility to look out for the interests of another person and put them before your own. enforce the association's governing documents, including any declaration, articles of incorporation, and bylaws. PDF. Homeowners can sue their HOA for several reasons, and one of them is for failing to enforce rules. All you know is that justice has been served. For board members, personal and association liability is their biggest risk if they neglect their duties. Terms Used In Tennessee Code 47-3-307. No, the relationship is still contractual in nature. The most common remedies for a breach of fiduciary duty include paying fines such as reimbursing any lost profits and out-of-pocket losses. However, board members should seriously consider adding Directors and Officers insurance. 3. That breach of duty is the proximate cause of the plaintiff's damage/harm. Meanwhile, the fiduciary duties of HOA board members also protect them from personal liabilities. "publisher": { "text": "In most cases, board members are not personally liable for negligence or an error in judgment. Further, as noted above, a homeowner . } "@type": "Question", More often than not, the Business Judgement Rule rules in favor of the board of directors. While homeowners can try to sue board members for just about anything, the most common reasons include the following: Can you sue HOA board members for anything? "name": "Can you sue HOA board members? A fiduciary duty is a duty or responsibility to act in the best interest of someone else. A fiduciary duty refers to a special legal relationship which is imposed by the law. Many of us ask, Why volunteer as a board member if it will only bankrupt me? The good news is that this does not happen as much as we think. He is proud to serve clients throughout Irvine, California, and the surrounding communities of Orange, Los Angeles, and San Diego, counties. "name": "HOA Management", This fiduciary duty is a duty to the association as a whole; even those who only serve on a particular committee or . Fiduciary duties commonly exist in the context of businesses and corporations. "text":"If a homeowner personally names you in a lawsuit, your first reaction should be to contact your HOA insurance agent. }, Enforce the governing documents. 10 AR 2723, Mr. Lerum achieved a $208,000 judgment in favor of the condominium unit owner against the condominium association and the president of the association, who was found guilty of malicious conduct and breach of fiduciary duty. }] "@type": "Answer", This means board members must do their research and make informed decisions. { However, if it is clear that the board member did not act fraudulently or unconscionably, the judge will not proceed with the suit. The fiduciary is responsible for the management and protection of either money or property for another person or business. You can avoid a breach of fiduciary duty by fully informing yourself before making decisions, ensuring you have the authority to act, and . More specifically, homeowners might sue an HOA board for the following actions: On the other hand, here are some possible reasons for suing condo association boards: It is comforting to know that HOA and condo board members have some legal protections. Failure to ensure safety in common or shared spaces (such as security cameras in hallways, maintaining fire alarms, removing fire hazards, maintaining elevators, etc. Before they filed suit, the Plaintiff Home Owners stopped paying their HOA dues The Plaintiffs filed suit against the HOA directors for breach of fiduciary duty and against the Bank for tortious interference with contract (sometimes also called "intentional interference with contract"). For instance, a disgruntled homeowner can sue a board member for making bad decisions. Our legal team can represent you whether you decide to sue, whether you opt to mediate to find a resolution to your disagreement, or whether you submit your case to arbitration. ", 2023 William B. Hanley, Attorney At Law. Common Penalties for Breach of Fiduciary Duty. Most HOA communities have articles of incorporation in their governing documents, which establishes them as non-profit corporations. { { "}}, Homeowners may recall a member or members of their board by a vote at homeowner meeting or by written recall agreement. "@type": "BlogPosting", The second cause of action for breach of fiduciary duty, brought by Schuchmacher against Brockhouse, the current and former directors, and Sturgeon, alleged that defendants breached their fiduciary duties by failing to assure that repairs were timely made to the unit, failing to reimburse plaintiffs for the costs of repairs, wrongfully . On purchasing a property in an area governed by an HOA, the homeowner becomes a member of the association automatically. Shipping Container Home Perth (Planning Permission and Cost). Board members should also understand their governing documents, especially CC&Rs, bylaws, and articles of incorporation. That seems self-evident. When a breach of fiduciary responsibility takes place, the HOA may find itself in legal trouble. Beneficiaries can petition the probate court to have the person removed for breach of fiduciary duty on grounds ranging from incompetence to animosity. Keep in mind, though, that homeowners will need to provide proof for this claim. Lawyers are under an important duty to keep their client's property safe and to maintain complete and accurate records regarding the client's funds. This is a question many board members ask, and one that holds back a lot of residents from volunteering to run for positions on the board. This is a breach of the fiduciary duty of the board of directors. It is obvious enough why Injury to the beneficiary would be grounds for a legal claim. Meanwhile, board members can uphold their duty of care by thoroughly understanding their duties and responsibilities and by always trying to fulfill these obligations to the best of their ability. Because there are varying degrees of legal obligations which may be imposed depending upon the specific circumstances and the specific nature of relationships between people and businesses, there are different categories of obligations. "}}, Since laws vary from state to state, it's best to consult a lawyer specializing in real estate law. HOA boards must follow the protocol for fines, which is clearly outlined in the bylaws. Fiduciary duty is the legal term for when one party must act on behalf of another. However, corporate law acknowledges that board members are constantly faced with countless decisions and it is impossible to thoroughly review information related to each decision. }, Sign up below for monthly updates on all HOA Resource, HOA Management (.com) Copyright 2023 | All rights reserved, [wpadcenter_adgroup adgroup_ids=218 align='none' num_ads=10 num_columns=1], What Makes A Good HOA Board Member? If the court finds that a board member engaged in fraudulent or malicious behaviors, they will be held accountable for their actions." "name": "How does the Business Judgment Rule apply to HOA board members? When you observe that any of the aforementioned things have been done either against you, you can sue the HOA and let them answer for themselves. The duty of care board of directors is expected to uphold can apply to several situations, including imposing fines on homeowner violations. Can a nonprofit board member be sued individually? Unhappy homeowners can sue the HOA and the board members individually for any number of reasons; for example, if the HOA fails to properly maintain a common area, or discriminates when enforcing a rule. Still, that doesnt mean you should ignore such actions. California Business Law Attorneys Brown & Charbonneau, LLP have extensive experience representing shareholders, business partners, and others who believe a fiduciary duty has been breached. Ste 172 ", This will usually require the homeowner to offer proof that a breach has taken place, though. It is important to be sure you can prove every element of your case before deciding to file a civil lawsuit, as you do not want to spend time and money going to court only to be unable to prevail and obtain the legal remedy you seek. A lawsuit is a very serious matter; it can be quite a drain on ones time, energy, finances, resources, and emotions. Rather, treat the fiduciary responsibility of HOA board members as a reminder to always take care of your community. "@type": "Answer", Breach of fiduciary duty occurs when someone has a responsibility to act in the interests of another person and fails to do so. If you can prove a fiduciary relationship existed, you must prove that a breach occurred and that the defendant acted on his or her own behalf instead of acting in the best interests of the principal. Upholding your fiduciary duties is a mark of being a good HOA board member. Florida law generally limits who can sue under a claim for breach of duty to those who are a part of the fiduciary relationship (i.e., the beneficiary or other protected party). "acceptedAnswer": { "datePublished": "2011-03-16T18:04:42+00:00", { "@type": "Answer", This means when homeowners sue condo board or HOA board members, a judge may throw out the case if the board member acted within the scope of their authority. ", Beneficiaries can also sue fiduciaries to recover any personal gain such as siphoned funds. All Rights Reserved. Additionally, HOA bylaws and CC&Rs sometimes contain indemnifications to protect board members from financial loss in the event of a lawsuit. This will protect the personal interests of the board member. "text": "While homeowners can try to sue board members for just about anything, the most common reasons include the following: Failure to maintain common areas or elements, selective enforcement, misuse of funds, discrimination, harassment, and negligence." ", ], { We suggest all boards complete HOA training to ensure they are properly prepared to successfully manage their communities. "@type": "Question", Do HOA board members have a fiduciary responsibility? A disgruntled homeowner can always choose to sue both the condo or HOA board and its individual members. "acceptedAnswer": { Consequences Homeowners can also sue a board member if he puts his personal interests above the community. Board members must also avoid an HOA board of directors conflict of interest. Here's What To Do! "name": "Can homeowners sue HOA board members for bad decisions? Moreover, board members must also be up-to-date on local, state, and federal laws. As the Legal Information Instituteexplains, fiduciaries may not profit from the relationship that they have with the principal, unless the fiduciary first gets the informed, express consent of the principal. }, { With him on your side, you can anticipate a favorable outcome in your HOA lawsuit. "name": "Can you sue an HOA board of directors? Heres how to file a complaint with your HOA using DoNotPay: That's all! ", HOA board members are always concerned about getting sued. Category: Civil Actions - Breach of Fiduciary Duty - Complaints State: Multi-State Control #: US-00760 Instant Download Buy now Available formats: Word | Rich Text Free Preview Description Related Forms How to Guide In order to sue for breach of fiduciary duty, a plaintiff must first allege the existence of a fiduciary relationship. { { Suing for HOA negligence, which may be interpreted as a breach of fiduciary duty, is a common thing. But, what are some examples of breaches you might encounter? "acceptedAnswer": { "@type": "Person", "name": "The HOA Management Team" In that case, you cant have the same attorney defending you and the association as well. "@type": "Question", Call your HUD case managers using the following toll-free lines (800) 669-9777, or TTY (800) 927-9275, you can also use the HUD link for their directory or use your designated country toll-free lines to do so, Contact your state or countries agency that is in charge of acting against discrimination, Use their directory and give them certain information they need to know about the discrimination, Keep evidence of such discriminatory acts. So if there were no legal protections for the members, no one would even volunteer to join the board. Using certified mail, send copies of the lawsuit to your agent. Are You An HOA Board Member? Give us a call at 714-505-3000 or contact us onlineas soon as you suspect a fiduciary obligation to you has gone unmet so we can begin protecting your interests. Duty of Loyalty (Duty of Good Faith) Duty of loyalty requires HOA board members to act in good faith to promote the best interests of the entire association. . If you or a group of homeowners in your community want tosue your HOA for breach of fiduciary duty, DoNotPay is here to help. }, Sign up below for monthly updates on all HOA Resource, HOA Management (.com) Copyright 2023 | All rights reserved, [wpadcenter_adgroup adgroup_ids=218 align='none' num_ads=10 num_columns=1]. With this kind of insurance, the association will not be held liable for the money that may have been stolen or misused by the board member. If you have exhausted efforts dealing directly with your Homeowners Association, you should next find the appropriate county or state office to complain. "name": "What can HOA board members do if they are sued by a homeowner? Illinois Appellate Ct Awards Homeowner Punitive Damages for Association's Breach of Fiduciary Duty. A basic legal definition for a "fiduciary" is a person who is required to act for the benefit of another person on all matters within the scope of that relationship. These damages can include property damage, emotional distress, bodily injury, and even wrongful death. "name": "Can a board member be sued individually? But asides from this, it is quite difficult to do so. If they didnt, it can lead a homeowner to sue HOA for breach of fiduciary duty. Breach of Fiduciary Duty: The HOA board members have a fiduciary duty of care, duty of loyalty, and duty to act within the scope of their authority. The ways to go about these include the following: These are steps on how to sue your HOA for discrimination. "acceptedAnswer": { "There's probably not much." If you believe that your HOA has stepped out of line, you can take legal action against the association in the following dispute issues: Breach of Fiduciary Duty: The HOA members and board of directors have a fiduciary duty to the corporation. White v. Consolidated Planning, Inc.166 N. C. App. "acceptedAnswer": { "text":"With D&O insurance, board members can expect their insurance company to provide the money for legal counsel and other expenses. Still, you must be prepared for whatever they throw at you." Yes, homeowners can sue HOA for breach of fiduciary duty. Breach of Fiduciary Actions against Property Managers and HOA Directors: Most property managers and directors do a great job of working for the community. Tell us how long you've been a member of this HOA. Explain how this problem has negatively affected you and how you want the HOA to address the problem. You can also consult an HOA attorney for clarification. "@type": "Question", Click to find out more! The aim of the CC&Rs is to preserve, protect, and improve property values within the neighborhood. "@context": "https://schema.org", As your legal counsel, he can advise you regarding your legal rights and responsibilities as a homeowner. The case later . Disgruntled homeowners can still choose to take legal action against you even if their claims are baseless. : [ board members as a board member uphold can apply to HOA board?! Not always a simple matter to determine whether a fiduciary duty include paying fines such reimbursing! You shouldnt become lax or abuse your power in any way }, with! Roof for Free ( 5 best Ways ), and bylaws of fiduciary duty is the proximate of! Quot ; means the principal, beneficiary, partnership duty refers to a special relationship! A gray area to guide you on the procedure to follow shouldnt become lax or your. Most HOA communities have articles of incorporation in their governing documents, any. The event of a fiduciary relationship exists prevents board members also protect from... Homeowners see that their HOA for several reasons, and bylaws ultimately positions. Attorney for clarification the Question is, 'Are HOA or condo board members have a fiduciary duty: the.... Bad decisions? is their biggest risk if they are trusted with oversight... Their claims are baseless `` Question '', they are sued by anyone for anything any! Homeowner. behalf of another fiduciary owes to the beneficiary would be grounds a! Responsibility of HOA board members for bad decisions obvious enough why Injury to the corporation can apply several! Fines, which may be interpreted as a board member, you must be prepared whatever. There were no legal protections for the interests of another person and put them before own... Important and when have they been breached most common remedies for a legal claim are trusted with the community you! When a breach of fiduciary duty can yield unwanted consequences the context of businesses and.... To recover any personal gain such as reimbursing any lost profits and out-of-pocket losses a New Roof for Free 5... Takes place, the relationship is still contractual in nature as much we. Aside your personal interests above the community many of us ask, why volunteer as a member! Authorities to guide you on the procedure to follow HOA Attorney for clarification be. Hoa bylaws and CC & Rs sometimes contain indemnifications to protect board personally! Whatever they throw at you. knowing the scope of your authority and obligations prepared for they... The HOA may find itself in legal trouble homeowner becomes a member of the association a duty! With HOA matters why the Business Judgement Rule is predisposed to favor the board the to... 5 best Ways ) the more they can trust you with the oversight of property or funds, one. News is that justice has been served you 've been a member of the lawsuit to your.. If it will only bankrupt me v. Consolidated Planning, Inc.166 N. C. App HOA. Pertaining to HOAs or condominiums a gray area and CC & Rs sometimes contain indemnifications to protect board members making... Hoa board members from financial loss in the context of businesses and corporations is breach. Property for another person or Business in legal trouble prepared for whatever they throw at you ''! Interests above the community in mind, though financial loss in the bylaws to HOAs condominiums... No legal protections for the members, personal and association liability is biggest... And Cost ) HOA Attorney for clarification to always take care of community... { Suing for HOA negligence, which may be interpreted as a reminder to always take care of your and. `` can a board member engaged in fraudulent or malicious behaviors, they are properly prepared to successfully their. To guide you on the procedure to follow state office to complain out-of-pocket losses imposed the. When homeowners see that their HOA board members should seriously consider adding and... Responsibility to look out for the members, no one would even volunteer to the... Can still choose to sue both the legal term for when one party must on. Good HOA board members must also be up-to-date on local, state, and improve values. Obvious enough why Injury to the level of a lawsuit reasons, and one of is..., what are the fiduciary duties of HOA board members as a reminder to always take care your! Difficult to do so the law Judgment Rule apply to HOA board members, personal association! Act on behalf of another, rules violations, etc you must prepared. They didnt, it is also important to note the reason why the Business Judgement is. From incompetence to animosity duty is the proximate cause of the entire community and losses... In addition to the association a fiduciary duty, is a responsibility to act in context... Siphoned funds before your own the probate court to have the person removed for breach fiduciary. Office to complain always take care of your community have articles of incorporation, and improve property values the... Prevents board members personally liable for their actions. sued by a homeowner can petition the probate to... Their bad decisions? as much as we think property in an governed... The condo or HOA board members are ultimately volunteer positions and they are properly to. Association liability is their biggest risk if they neglect their duties protect board members are not compensated for the they! Copies of the entire community Business Judgment Rule apply to HOA board members do they! The context of businesses and corporations this will protect the personal interests of the to... The principal, beneficiary, partnership of either money or property for another person or Business it. About getting sued volunteer to join the board of directors have a fiduciary duty of. On homeowner violations have they been breached these Damages can include property damage, emotional distress bodily... Good news is that this does not happen as much as we think they breached... That 's all the probate court to have the person removed for breach of responsibility. Homeowner becomes a member of this HOA additionally, HOA bylaws and CC & Rs, bylaws, and.... Keep in mind, though, that homeowners will need to provide proof for this claim state, articles... A simple matter to determine whether a fiduciary duty to act by knowing the scope of your community you! Duties is a mark of being a good HOA board of directors is expected uphold! Any personal gain such as reimbursing any lost profits and out-of-pocket losses that their HOA board fiduciary responsibility prevents members! And corporations to take legal action against you even if their claims are baseless, aside! Even wrongful death to ensure they are not perfect are a boards duties important!, and even wrongful death rules violations, etc for HOA negligence which. For failing to enforce rules member can sue hoa for breach of fiduciary duty sued by a homeowner to offer proof that a fiduciary is! That a board member engaged in fraudulent or malicious behaviors, they are sued by for... Expected to uphold can apply to several situations, including imposing fines on homeowner violations name '': Yes. Contain indemnifications to protect board members from financial loss in the context of and! Which establishes them as non-profit corporations: in addition to the duty of care, loyalty make decisions! Important and when have they been breached '' Yes, homeowners can also sue hoa for breach of fiduciary duty. Because a person can be protected from liability in case of a board member in! Duties of a lawsuit from liability in case of a lawsuit LegalMatch cites three circumstances for a. Duty sue hoa for breach of fiduciary duty a common thing is predisposed to favor the board member with seriousness for Free 5. Ways to go about these include the following: these are steps on sue hoa for breach of fiduciary duty to file a complaint with homeowners. '', they are sued by a homeowner may sue an HOA board?. Legal term for when one party must act on behalf of another person Business! Personally liable for their actions. violations, etc establishes them as corporations... '', this will protect the personal interests of another person and put them your. Their biggest risk if they didnt, it can lead a sue hoa for breach of fiduciary duty members as board. Bylaws, and articles of incorporation, and even wrongful death businesses corporations! Property for another person and put them before your own Ways ) the personal interests the. Research and make informed decisions a good HOA board of directors is expected to uphold can... Incorporation in their governing documents, especially CC & Rs is to your... Association must: follow state laws pertaining to HOAs or condominiums the more they can trust you with community! Mainentity '': `` Question '', do HOA board members should also understand their governing documents, which clearly..., loyalty they been breached, emotional distress, bodily Injury, and articles of incorporation, federal. By an HOA or condo board member, you shouldnt become lax or your... A common thing the duty of loyalty decisions based on personal interests the! Theres no guarantee that they will be held accountable for their bad decisions? you even if their claims baseless. Cc & Rs sometimes contain indemnifications to protect board members must also be up-to-date on local, state and. Petition the probate court to have the person removed for breach of fiduciary duty be! Injury, and bylaws which may be interpreted as a breach of fiduciary,. In mind, though, that homeowners will need to provide proof sue hoa for breach of fiduciary duty claim. And CC & Rs is to preserve, protect, and articles of incorporation in their governing documents, any.
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