“If I’d Observed All The Rules, I’d Never Have Got Anywhere,” Marilyn Monroe.

With regard to the purchase of additional land by a country club, members were given the option of paying a lump sum or making payments over a period of years. After some time, there was a dispute over the club’s treatment of that obligation vis-à-vis new members. Four members brought suit against the club, and the club, by then the defendant, petitioned to compel arbitration, based on an arbitration provision incorporated into its bylaws four months after plaintiffs’ complaint was filed. In affirming the trial court’s denial of defendant’s petition to compel arbitration, the appellate court stated: “And [defendant’s] basic premise, which is that each member’s agreement to the bylaw provision allowing for future amendments to its bylaws means those members are automatically bound by whatever amendments the Club makes in accordance with that provision – even after the members have resigned their membership – would doom the agreement as illusory if it were correct. Fortunately, it is not. (Cobb v. Ironwood Country Club (Cal. App. Fourth Dist., Div. 3; January 28, 2015) 233 Cal.App.4th 960, [183 Cal.Rptr.3d 282].)