A member of an Illinois nonprofit corporation has standing to sue members of the board of directors for breach of fiduciary duty by establishing “an undisclosed side agreement among themselves” that he claims disenfranchises members by distorting their votes. But a federal District Court in Missouri has directed the member to show whether the amount in controversy exceeds the $75,000 minimum necessary to confer diversity jurisdiction on the court. Andrew Schlafly, son of Phyllis Schlafly who was founder of the Eagle Forum, is a member of the nonprofit Eagle Forum and a former at-large director. Under the Forum’s bylaws, it has eight self-perpetuating directors and an at-large director...