Court Dismisses Vest Derivative Lawsuit Against Former LNC Chair McArdle

The Superior Court of the District of Columbia has dismissed a lawsuit brought by former Libertarian National Committee Region 7 Representative Beth Vest against former LNC Chair Angela McArdle and the National Committee.

In an October 24 order, Judge Robert Okun granted a motion to dismiss for lack of subject-matter jurisdiction, ruling that McArdle’s January 2025 resignation rendered the request for her removal moot and that D.C. law gave the court no authority to grant the other demands. An earlier motion to dismiss, arguing that Vest failed to state a claim and lacked standing, had been denied in December 2024, allowing the case to proceed until the renewed motion was filed after McArdle’s resignation.

Vest’s suit, filed in May 2024 while she was still serving on the committee, alleged breaches of fiduciary duty and violations of bylaws by LNC leadership under McArdle. Vest accused McArdle of diverting party assets, making decisions without transparency, interfering with state affiliate autonomy, and excluding certain LNC members from decision-making at the time. The complaint sought McArdle’s removal as chair, a permanent bar on her holding future office within the organization, and access to internal LNC records.

In its order, the court concluded that it lacked jurisdiction to remove McArdle because she had already resigned from her role, which she said at the time was to accept a “new opportunity,” and no longer held any position within the organization. It also declined to impose a permanent ban on her ability to hold future leadership roles, finding that the District’s Nonprofit Corporation Act authorizes courts to remove or bar directors but not officers. As McArdle’s role as chair was classified as an officer position, the court said it fell outside its authority.

Vest also sought access to internal LNC records, arguing she had inspection rights under D.C. law. The court rejected that claim, ruling that those rights apply only to “membership corporations.” According to its Articles of Incorporation, the Libertarian National Committee is a “non-membership corporation” and therefore not subject to those provisions. The court further held that the common-law inspection rights Vest cited apply only to shareholders of for-profit corporations and not nonprofit entities.

The court did not address the substance of Vest’s allegations. All three counts were dismissed without prejudice, allowing for the possibility of a future refiling if the case is argued differently.