In Martin v. Curran (303 NY 276 [1951]) the Court of Appeals held that because a voluntary, unincorpo-rated membership association has no existence independent of its members, a plaintiff cannot maintain a cause of action against it "unless the debt which he seeks to recover is one upon which he could maintain an action against all the associates by reason of their liability therefor, either jointly or severally" (id. at 281.) The New York Court of Appeals set the controlling standard for determining whether a plaintiff may maintain a particular action against a union. Under New York law, a plaintiff must allege and prove that each individual union member authorized or ratified the alleged wrongful acts. It is insufficient to plead that a majority or controlling portion of the union voted for a specific action; the authorization must be unanimous. (Id. at 282.) Plaintiff argues that this application of Martin is illogical, yet both the language of Martin as well as subse-quent case law confirm this rule. " So, for better or worse, wisely or otherwise, the Legislature has limited such suits against association officers, whether for breaches of agreements or for tortious wrongs, to cases where the individual liability of every single member can be alleged and proven." (Id.) The New York's Court of Appeals held that, in order to state a claim accusing a labor union and/or its officials in their representative capacities of committing, e.g., a tort, a plaintiff must allege and prove that each individual union member authorized or ratified the unlawful action. This is because "a voluntary, unincorporated membership association is neither a partnership nor a corporation. It is not an artificial person, and has no existence independent of its members. No agency of one member for another is implied. A part of the members of a voluntary organization cannot bind the others without their consent before the act which it is claimed binds them is done, or they, with full knowledge of the facts, ratify and adopt it." (Id. at 280 .) Therefore, "suits against association officers, whether for breaches of agreements or for tortious wrongs, [are limited] to cases where the individual liability of every single member can be alleged and proven." (Id. at 282.) Because the plaintiff in Martin had failed to allege that the individual members of the union had authorized or ratified the tortious conduct at issue, the dismissal of the action was affirmed. (Id. at 282-283.)