Brandner v. American Academy of Orthopaedic Surgeons

Dist. Ct. did not err in granting defendant-professional group organization’s motion for summary judgment in action by plaintiff-member of said organization, alleging that defendant’s one-year suspension of plaintiff from said group violated Illinois law and group’s own governing documents, where, according to plaintiff, said suspension would severely impact his future income as expert witness. Plaintiff could only proceed with instant case if he could show that membership in defendant’s group affected his important economic interests, and while plaintiff testified that suspension would devastate his potential income, plaintiff failed to present any documentary evidence, such as his own actual income loss or income losses from others who had been suspended from group, to support his claim of significant loss of income arising out of instant suspension.