The Pennsylvania Commonwealth Court has held in an unreported opinion that former members of a Blue Cross organization have no standing to sue the corporation over the amount of reserves it had accumulated. Two individuals, who lost their corporate memberships in 2009 when Highmark, Inc., changed its corporate structure to eliminate general membership and provide that the directors are the sole members of the corporation, filed suit in 2011 challenging the accumulation of surplus. The trial court granted standing but found that there was no improper accumulation of surplus. Pennsylvania’s Nonprofit Corporation Law in effect at that time (the standing provision was amended in 2013) limited...