In Will v. View Place Civic Ass'n, 580 N.E.2d 87, 92 (Ohio Ct. Com. Pl. 1989), the trial court declined to enforce a contract against two members of an unincorporated association.
The court determined that the members were not officers, and they had manifested an intent not to be bound by the contract, including writing letters and renouncing their membership in the association. Id.