Consumer Party v. Commissioners of Centre County

25 Pa. D. & C.3d 87, 1981 Pa. Dist. & Cnty. Dec. LEXIS 63
CourtPennsylvania Court of Common Pleas, Centre County
DecidedSeptember 25, 1981
Docketno. 1981-948
StatusPublished

This text of 25 Pa. D. & C.3d 87 (Consumer Party v. Commissioners of Centre County) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Centre County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Consumer Party v. Commissioners of Centre County, 25 Pa. D. & C.3d 87, 1981 Pa. Dist. & Cnty. Dec. LEXIS 63 (Pa. Super. Ct. 1981).

Opinion

LEHMAN, S.J.,

Specially Presiding,

FACTUAL BACKGROUND

This matter is before the court upon plaintiffs complaint in mandamus. Said complaint seeks to have the Commissioners of Centre County, in their capacity as the Election Board for said county, place plaintiffs candidates on the May, 1981 primary election ballot and the November, 1981 general election ballot and to certify plaintiff to be a [88]*88political party within Centre County. Defendant filed preliminary objections which were disposed of by opinion and order of this court dated July 1,1981.

In the November, 1980 general election, plaintiff, among its candidates for public office, ran a candidate for the office of Representative to the United States Congress for the Twenty-Third Congressional District. 25 P.S. §2199.21 provides:

“The Twenty-Third District shall consist of the Counties of Cameron, Centre, that part of Clarion not included in the Twelfth District, Clearfield, Clinton, Elk, Forest, McKean, Potter, Venango and Warren.”

Plaintiffs candidate, Doug Mason, received 2,079 votes in Centre County for the Twenty-Third District Congressional seat. The winning candidate for said seat, incumbent William Clinger, received 29,768 votes in Centre County. Representative Clinger’s total vote in the Twenty-Third Congressional District was 122,855. Plaintiffs candidate Doug Mason received a total of 3,158 votes in the Twenty-Third Congressional District. The number of votes received by plaintiffs candidate in Centre County is equal to 6.98 percent of the total number of votes received by Representative Clinger in Centre County. The total number of votes received by plaintiffs candidate in the Twenty-Third District is equal to 2.5 percent of the total number of votes received by Representative Clinger in the Twenty-Third District.

Plaintiff, as a result of the aforementioned vote totals, sought certification as a political party within Centre County and to have its name placed on ballots for the May, 1980 primary elections. On or about February 3, 1981, defendants, in their capacity as the Board of Elections for Centre County, notified plaintiff that it would not be cer[89]*89tified as a political party within Centre County and was thus denied ballot status. On or about March 10, 1981, Trustee for plaintiff filed nomination petitions with defendant for the purpose of having plaintiffs candidates listed on the ballot for the upcoming May, 1981 primary ballot. On or about March 13, 1981, defendants, in their capacity as the Board of Elections for Centre County, rejected said nomination petitions. Neither plaintiff nor its candidates filed an appeal from the rejection of said nomination petitions. Plaintiff then filed this complaint in mandamus on April 21, 1981.

DISCUSSION

The first issue presented for the court’s consideration is whether the necessary percentage of votes that a political body’s candidate must receive pursuant to 25 P.S. §2831(b) in the general election preceding the primary in order to be declared a political party is to be based on the elected candidate’s total vote or only on the voting results within the county where political party status is sought.

Section 801(b) of the Pennsylvania Election Code of 1937, as amended, 25 P.S. §2831(b) provides:

“(b) Any party or political body, one of whose candidates at either the general or municipal election preceding the primary polled at least five per centum of the largest entire vote cast for any elected candidate in any county, is hereby declared to be a political party within said county; and shall nominate all its candidates for office in such county and in all political districts within said county, or of which said county forms a part, and shall elect such party officers as its rules provide shall be elected therein, by a vote of the party electors, in accordance with the provisions of this act.”

[90]*90Defendants argue that the operative words in the above-quoted subsection are “ . . . the largest entire vote cast for any elected candidate ...” Plantiff argues that the words “ ... in any county ...” provides the necessary qualifier which indicates that the entire vote cast is the total vote cast in the county for which the political body seeks ballot status. Both parties cite the case of In re Liberal Party, 17 D. & C. 176 (1931), in support of their respective positions. Since we feel that the Liberal Party case does nothing but further confuse the semantic interpretations upon which both parties rely and is not binding on this court as a matter of stare decisis, we feel it best to engage in our own analysis of section 801(b).

The purpose behind section 801(b) of the Election Code is to allow political groups which have sufficient voter support within certain counties, but not sufficient voter support throughout the state to qualify as ‘a political party within the state’ as defined in section 801(a), to appear on the ballot in those counties where they have garnered voter support: Kerns et al. v. Kane et al., 363 Pa. 276, 69 A. 2d 388 (1949).

Defendants would have us interpret section 801(b) to require that the Consumer Party candidate receive five percent of Representative Clinger’s vote total throughout the Twenty-Third District. In other words, since no county-wide offices were the subject of the November, 1980 general election, plaintiff would have to show sufficient voter support throughout the entire Twenty-Third District in order to attain ballot status as a certified political party in Centre County. We feel that this interpretation fails to effectuate the purpose of section 801(b). Said section provides in part:

[91]*91“ . . . and shall nominate all its candidates for office in such county and in all political districts within said county, or of which said county forms a part, ...” (Emphasis added.)

We feel that the above-emphasized portion of section 801(b) indicates the intent of the legislature to allow for the certification of a third party for offices for the political districts formed, in part, by counties where sufficient voter support has been demonstrated. In the case sub judice section 801(b) would allow for the nomination of plaintiffs candidates for Twenty-Third District posts if, in a previous election for a county-wide post, plaintiffs candidate received five percent of the winning candidate’s vote total. However, defendant would have us hold that where no county-wide offices were the subject of the previous general election but posts for the Twenty-Third District were, plaintiffs candidate would be required to show voter support throughout the entire Twenty-Third District in order to be certified in any county which forms part of said district for the purpose of running candidates for county-wide offices in the subsequent election. Thus, where the statute contemplates party expansion from the county to the political district formed in part by said county, defendants would have us hold that the party and its supporters in one county within the political district are subject to voter support of the party in the other counties which form the political district. We feel that defendant’s interpretation places too great a burden on parties seeking certification in election years where no county-wide offices are on the ballot as the actions of voters in ten other counties would affect the party status of a political body within this county.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kerns v. Kane
69 A.2d 388 (Supreme Court of Pennsylvania, 1949)

Cite This Page — Counsel Stack

Bluebook (online)
25 Pa. D. & C.3d 87, 1981 Pa. Dist. & Cnty. Dec. LEXIS 63, Counsel Stack Legal Research, https://law.counselstack.com/opinion/consumer-party-v-commissioners-of-centre-county-pactcomplcentre-1981.