Edwards v. National Security Speleological Society- not enough control
a. Facts: Women falls into a well and dies. The well is surrounded by a fence which was repaired by members of NSS (a nonprofit). This group has several chapters w/ their own freedom & 1000s of members. Sue the local chapter which is repairing the well and the national society on grounds of vicarious liability.
b. Held: No P-A relationship b/c no control. Since the National Society does not control the local chapter cannot be held vicariously liable.
i. Lack of control indicated by:
a. no integration of finances and operations
b. they are independent local chapters with their own freedom
c. independent members: each chapter can have members who are not part of NSS
d. not covered by NSS tax exemption
ii. This is a loose relationship—there is still some control because need charter, can get expelled from membership—but its too loose.