Disposition of funds upon a local's disaffiliation from the international union has been one of the most difficult problems for the courts to overcome in the field of Labor Law. The application of common law doctrines to a mobile field requiring flexible approaches posed many problems. Seemingly, a new theory had to be developed every time'a new situation arose since the courts were reluctant to consistently apply any one theory because of its undesirable results. This resulted in the development of six distinct doctrines: "implied condition" or "frustration of purpose," "local autonomy," "trust fund," "unclean hands," "certification" and "breach of fiduciary obligation."
Joseph T. Svete, Disposition of Local's Funds upon Disaffiliation, 12 Clev.-Marshall L. Rev. 539 (1963)