Smith & Edwards v. Golden Spike Little League

In 1974, residents (defendants) in a suburb in Utah obtained a charter from Little League Baseball, Inc., to create their own team, Golden Spike Little League (defendant). Although the league was recognized by the national little league association, the team itself was never incorporated. Additionally, the charter did not grant any authority to the team to make any purchases on the national association’s behalf. One of the residents, David Anderson, was tasked with finding equipment for the team. Anderson received a price quote from Albert Smith, the owner of Smith & Edwards (plaintiff). Anderson informed Smith that the team would obtain the needed merchandise from his store, but how the team would pay for the equipment was never discussed. Smith then went out of town for business. During this time, many of the residents involved in the team would pick up different items from the store without paying. The residents would inform the employees that they were obtaining the equipment for Golden Spike Little League. When Smith returned, he informed the residents that they had obtained $3,900 worth of merchandise. The residents began a fund-raising operation for the amount owed but raised only $149. In response, Smith filed a suit against the residents and the team. The trial court held that Golden Spike Little League was responsible for the amount owed to Smith but, because the team was not incorporated, the residents were not personally liable for the amount owed. Smith appealed.