Stevens v. Anatolian Shepherd Dog Club of America

Appellant Rhea C. Stevens is an enthusiast and breeder of a relatively rare breed of dog known as the Anatolian Shepherd. Stevenss interest in the breed led her to apply for membership in the Anatolian Shepherd Dog Club of America, Inc. (ASDCA). The ASDCA never recognized Stevens as a member, despite retaining her membership fee of thirty dollars. Stevens sued for specific performance, exemplary damages, and attorneys fees due to what she perceived to be a breach of contract by the ASDCA. The trial court, after a bench trial, entered a take-nothing judgment against Stevens, except the trial court ordered her thirty-dollar membership fee be returned. Stevens now raises five issues on appeal. She claims that the trial court erred in the following: 1) not recognizing a binding contract for membership between her and the ASDCA; 2) holding that the laws of contract did not apply in this case to the ASDCA; 3) failing to find her irreparably harmed and entitled to specific performance; 4) denying her motion for new trial after alleged misconduct by the judge; and 5) failing to award her attorneys fees. We affirm the trial courts judgment because the trial court had the discretion to refrain from exercising jurisdiction over Stevenss suit to grant her membership. In addition, we hold the trial court did not err in denying the motion for a mistrial, or in refusing to award attorneys fees to Stevens.