Brubaker v. Montgomery County Board of Elections

128 N.E.2d 270, 71 Ohio Law. Abs. 99, 1955 Ohio Misc. LEXIS 373
CourtMontgomery County Court of Common Pleas
DecidedMay 11, 1955
DocketNo. 108,273
StatusPublished
Cited by1 cases

This text of 128 N.E.2d 270 (Brubaker v. Montgomery County Board of Elections) is published on Counsel Stack Legal Research, covering Montgomery County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brubaker v. Montgomery County Board of Elections, 128 N.E.2d 270, 71 Ohio Law. Abs. 99, 1955 Ohio Misc. LEXIS 373 (Ohio Super. Ct. 1955).

Opinion

OPINION

By McBRIDE, J.:

It appears anomalous that this court should be requested to restrain the Board of Elections when the same matter was recently in the Court of Appeals in mandamus to compel the same Board to hold an election. We are advised that the Court of Appeals overruled the Board’s demurrer, thereby finding that the petitioners for detachment alleged a cause of action and that thereafter the Board voluntarily reversed its decision as a result of which the mandamus action was dismissed, as moot, at the petitioners’ request. Although the decision of the Court of Appeals on the demurrer of the Board legally interpreted the petition as requiring an election, there was no testimony and no final order, particularly as to the Village of Kettering which had been permitted to answer. Voluntary action of the Board of Elections and dismissal of •the mandamus action in response to a decision on the Board’s demurrer does not defeat the right of the Village to test the validity of the action of the Board of Elections. A decision on demurrer by the Court of Appeals as to the same subject, indicating that as a matter of law, refusal to call an election constituted an abuse of discretion, must be respected by this court in the absence of new or different facts even though the decision of the Court of Appeals may not be formally considered “res judicata”.

Sec. 709.39 R. C. contains detailed provisions with respect to the contents, execution and filing of a petition for detachment from a village. The statute gives to the inhabitants within any portion of the village, such portion being (1) contiguous to an adjoining township and (2) comprising not less than 1500 acres, the right to petition for detachment. The petition for detachment must contain (a) an accurate description of the territory, (b) an accurate map or plat thereof, (c) the name of .the township, if a new township is proposed, (d) the name of the agent of the petitioners and (e) signatures to such petition equal to fifteen percent of the total number of votes cast at the last general election in such territory.

The same section provides

“Within ten days after the filing of such petition with the board, the board shall determine whether the petition conforms to this section. [102]*102If it does not conform, no further action shall be taken thereon. If it does conform, the board shall order an election, * *

When the board finds that a petition conforms to the statute, the duty to order an election is mandatory. On demurrer in State of Ohio, ex rel, Graef v. Board of Elections, Montgomery County Court of Appeals, No. 2342, May 6, 1955.

This section of the statute is exclusive. Leach v. Collins, 123 Oh St 530.

Separation in school districts is a different provision of the statute and not applicable to this situation.

The court is aware of public sentiment against detachment in Kettering and, if we were not, it is apparent on the record of the Board of Elections, which originally and erroneously decided that it was morally obligated to follow a recent decision of the Supreme Court. State, ex Brubaker, v. Brown, Sec’y of State, 163 Oh St 241. That decision, not yet jounalized, is subject to the condition expressed in §703.06 R. C. which postpones Kettering’s transition to city status for thirty days after the issuance of the proclamation by the Secretary of State. State of Ohio, ex rel, Graef v. Board of Elections, No. 2342. Sub H. B. 31, to enact §703.011 R. C. relating to the classification of municipal corporation, a proposal supported by the officials of Kettering, contains a similar provision allowing a thirty day period for the filing of detachments before city status is effective. The existing, as well as the proposed, thirty day delay in transition from village to city status is a clear and unambiguous expression of legislative intent as to a political matter. Sec. 703.06 R. C.

Courts do not have legislative power. They are reluctant to interfere with the election procedure or election officials, except to enforce rights or such mandatory or ministerial duties as the statute may require. ' Where the statute imposes a discretionary duty, courts will compel, but not control, the exercise of that discretion. A court of equity may intervene in the election procedure only where there is proof of a violation of statute, fraud or abuse of discretion.

The fact that a statute may be inadequate does not authorize a court to exercise any equitable jurisdiction. State, ex rel, v. Board (Kettering cases on appeal 1953), 65 Abs 547. The fact that such statute liberally allows detachments without the consent of the village or the majority of all its voters is a matter of legislative policy.

The power to detach is in its nature political or legislative rather than judicial. Metcalf v. State, 49 Oh St 586. A political issue must be decided in a political rather than a judicial forum, according to the rules fixed by statute and not by equities or personal opinions.

This case was heard, argued and submitted on the question of issuance of a temporary restraining order based upon “great and irreparable injury” to the plaintiff. The plaintiff is described in the caption as an individual, mayor of the Village of Kettering. The pleading does not allege any special facts as to the capacity of the plaintiff in bringing this action.

The testimony and arguments were directed to the merits, failing to develop or explain how failure to issue a temporary restraining order [103]*103would cause irreparable injury to the plaintiff in event he is successful on the merits. Proof of need for immediate, temporary relief is essential to invoke emergency equitable relief.

We are not permitted to decide this matter either on demurrer or its merits. If ultimately the opinion of the majority of the inhabitants is not in favor of the detachment, no harm can exist. If the majority are in favor of detachment, their right to vote has not been denied and the effect of such election and the procedure involved in accomplishing it, insofar as alleged in the petition, is pending before the court. The real issue in this case is not the loss or injury to the Village, as that is inherent in the statutory right to detach, but the issue is whether or not the right to detach has been exercised'according to law.

The plaintiff alleges that the Board of Elections acted contrary to law in only two respects:

(1) That the map and description of the territory sought to be detached are both inaccurate and contrary to Section 709.39. No testimony of such inaccuracy was introduced other than a variance as to the number of acres which in any event is in excess of the amount required by statute.

(2) That the portion described and shown on the map is not contiguous to any adjoining township. The statute provides for detachment of

“* * * ANY portion of a village, SUCH PORTION being contiguous to an adjoining township, and * *

The statute contains no further restrictions, conditions or requirements as to the form of the area that may detach. Arguments that the portion must be homogeneous, with definite qualities of physical unity that would promote a useful and efficient political subdivision are not supported by the Ohio statute. We do not question the right of the legislature to impose suitable conditions upon the right to detach. It is sufficient to say that the legislature has failed to do so.

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Cite This Page — Counsel Stack

Bluebook (online)
128 N.E.2d 270, 71 Ohio Law. Abs. 99, 1955 Ohio Misc. LEXIS 373, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brubaker-v-montgomery-county-board-of-elections-ohctcomplmontgo-1955.