Cole v. City of Columbus

2 Ohio N.P. (n.s.) 563, 1904 Ohio Misc. LEXIS 293

This text of 2 Ohio N.P. (n.s.) 563 (Cole v. City of Columbus) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Franklin County, Civil Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cole v. City of Columbus, 2 Ohio N.P. (n.s.) 563, 1904 Ohio Misc. LEXIS 293 (Ohio Super. Ct. 1904).

Opinion

The plaintiff claims the election is void for three reasons. I will discuss these in the order as presented by counsel for the plaintiff.

First. Because the election was held more than thirty days after the filing of the petition.

The Brannock Law contains the following express provisions:

‘ ‘ Section 1. Whenever forty per cent, of the qualified electors of any residence district of any municipal corporation shall petition the mayor of such municipal corporation, or a common pleas judge of the county for the privilege to determine by ballot whether the sale of intoxicating liquor as a beverage shall be prohibited within the limits of such residence district, such mayor or common pleas judge shall order a special election to he held in not less than twenty and not more than thirty days from the filing of such petition with the mayor of the municipal corporation or common pleas judge of the county” (97 O. L., p. 87).

In the case at bar it is admitted that the election was held on the 11th day of July, 1904, or thirty-one days after the refiling of the petition and forty-one after the filing of the petition.

This issue in this cause depends upon what construction is put on the words of the statute “shall order a special election to be held in not less than twenty and not more than thirty days from the filing of such petition,” etc.

If this language of the statute is merely directory then the judge committed no error in ordering an election in thirty-one days or in forty-one days after the filing of the petition.

[566]*566If, however, the language of the statute is mandatory, then the judge did commit an error. Statutes similar to the one in question have been assailed in other states, and the question here involved is not a new one, and, although it has not been passed on by any court, in Ohio, it has been passed on by courts in other states.

In two cases, to-wit, In re Petition for an Election (Toledo), 2 N. P. — N. S., 469, and In re Petition for an Election (Bayton), 2 N. P. — N. S., 245, two common pleas judges, acting in a ministerial capacity, held the language limiting the time within which, the election shall be ordered in this act to be “directory merely.” But neither give any reason for-such an opinion nor do they cite any authority for their ruling.

I shall take up and quote liberally from the authorities upon this point.

“Statutes providing that the election shall be held within a certain number of days after the filing of the petition, or within a specified number of days after the making of the order for election are mandatory, and elections held after the expiration of such time are void.” 19 Am. & Eng. Ency. of Law, 503 (2d Ed.)
“An election held at a time other than that authorized by law is of no effect.” 19 Am. & Eng. Ency. of Law, 502 (2d Ed).
See Mo. Appeals, 325; McCrary, on Elections (3d Ed.), Sec. 193; 6 Nevada, p. 104; 92 Georgia, 309; 30 Mo. Appeals, 612; 59 S. W., 275; 49 Mo. Appeals, 407.

There can not be any question about the authorities. In answer to them, counsel for the city (Mr. Clark) presents arguments to which I now desire to direct attention and weigh beside these authorities. He says:

“There is not the slightest doubt of the correctness of plaintiff’s contention that where the Legislature has fixed the time for holding an election, elections held after that time are void. The proposition here is different. The Legislature has left it to the mayors of cities or judges of common pleas courts to fix the time for holding these elections and has directed that they be held not more than thirty days from the time of filing of the petition.”

[567]*567Very true. Then why not so hold them?

Again he says the Texas decisions are not in accord, and cites a case in the 2 Texas Reports, p. 217, as holding the contrary.. This case was decided in the year —■—, while the ease in 59 S. W. Rep., 275, was decided in 1900.

Again he says:

“The two cases from Missouri cited herein have no bearing whatever in this ease, as in each of these cases the law specifically forbade holding an election within sixty days of a municipal election; and it was because the elections violated these negative words of the Missouri statute, that they were declared invalid.”

In answer to this I quote from The State, ex rel White, v. Ruark et al, 34 Mo. App., 325:

“That the special elections referred to by relator were held within sixty days after the local option election is a conceded fact. But we can not agree with the relator that on account of this, the local election was rendered void and inoperative.”

Section 2 of the local option law provides, “that no election under said law shall be held within sixty days of any municipal or state election, ’ ’ etc. The evident intention of the law making power of the state was to free the elections on the whiskey question from all partisan and local influences, and that such elections should be uninfluenced by the excitement aroused by other recent elections or by contemplated elections. But it is not every municipal or other election held within sixty days after a local option election, that will invalidate the latter. If either one of said special elections have been ordered, or even, contemplated at the time of the local option election, the relator’s objection would have some force. But the record shows that the regularly elected city marshal did not resign for almost a month after the local option election, and there is nothing to show that the election on the water works question was even contemplated until the twelfth day of September, 1887, which was more than a month after the local option election. It would be judicial nonsense to hold that these subsequent elections, that were not even contemplated at the time, prevented a free expression of the will of the voters at the local option election. [568]*568And this is not in conflict with the decision of this court in case Ex parte B. S. Woolridge, 30 Mo. App., 612. The facts in the two cases are different.

Again he (counsel for the city) quotes from People v. Cook, 14 Barbour (N. Y.), 290, and claims that the' general rule is laid down by the New York court in that case, and that the rule should govern in the case at bar. The same quotation is made in The State, ex rel White, v. Ruark et al, Mo. App., 325, and the court in passing upon that case fully answers, in my judgment, this argument. Having quoted it supra (page 6) herein I shall not again quote the court’s opinion disposing of that rule in cases similar to the one at bar.

“To say that this rule is mandatory would be a dangerous holding for the court to make, for, if such is the case, it puts it within the power of any contrary mayor or stubborn judge to delay action until the thirty-day limit has been reached, and in that way defeat the will of the people.”

Counsel for the city in the statement just above quoted makes, in my judgment, the strongest possible argument against his cause and in favor of holding the language mandatory.

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Related

Cain v. State
59 S.W. 275 (Court of Criminal Appeals of Texas, 1900)
In re Wooldridge
30 Mo. App. 612 (Missouri Court of Appeals, 1888)
State ex rel. White v. Ruark
34 Mo. App. 325 (Missouri Court of Appeals, 1889)

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Bluebook (online)
2 Ohio N.P. (n.s.) 563, 1904 Ohio Misc. LEXIS 293, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cole-v-city-of-columbus-ohctcomplfrankl-1904.