Don Harrison v. Leroy Stanley

CourtCourt of Appeals of Texas
DecidedMarch 9, 2006
Docket01-05-01065-CV
StatusPublished

This text of Don Harrison v. Leroy Stanley (Don Harrison v. Leroy Stanley) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Don Harrison v. Leroy Stanley, (Tex. Ct. App. 2006).

Opinion

Opinion issued March 9, 2006




In The

Court of Appeals

For The

First District of Texas





NO. 01-05-01065-CV





DONALD HARRISON, Appellant


V.


LEROY STANLEY, Appellee





On Appeal from the 127th District Court

Harris County, Texas

Trial Court Cause No. 2005-45756





O P I N I O N

          Appellee, Leroy Stanley, filed an election contest against appellant, Donald Harrison, after an exceedingly close final vote tally in a runoff election for a Pasadena City Council position. The trial court refused appellant’s request to include in the final tally three ballots in his favor that had been excluded by the Early Voting Ballot Board. Appellant filed this expeditedissues on appeal. Appellant contends that are (1) that the Early Voting Ballot Board acted improperly in comparing the relevant signatures;and (2) that the trial court erred in excluding the ballots at issue. For the reasons that follow, we affirm.

BACKGROUND

          On May 7, 2005, an election pitting appellant against appellee was held for a seat on the Pasadena City Council; it resulted in a tie, which necessitatinged a run-off election. The run-off election was almost as close: 591 votes were tallied for appellant, 590 for appellee. During the course of the ballot counting, the Early Voting Ballot Board (“Board”) excluded three ballots from consideration because the signatures on the carrier envelopes and mail-in ballot applications did not match, as required by the Election Code. Appellee filed an election contest, and, after discovery, the parties stipulated that two of appellant’s votes were impermissibly counted because one voter lived outside the geographic boundary of the district in question and the others voter’s registration status had not become effective until after the run-off election. This placed appellee ahead by one vote, 590 to 589.

          After appellee rested his case, Aappellant introduced the applications for ballot by mail and carrier envelopes of three voters—Donald Howard, Angel Marino, and Gary Gray—who had voted for him.. The trial court heard testimony from each of the three voters and, via their depositions, from the four Board members. The Board memberswho had testified that they found, as to appellant’s three proffered voters, that the signatures on the applications for ballots by mail were not made by the same person who signed the carrier envelopes, thereby violating election law statutes. The trial court agreed, finding that the relevant signatures did not match. agreed. The trial court further found that “assistance,” as defined in the Texas Election Code, had been given to each of the proffered voters, in contravention of same. The court also found that none of the three proffered voters had a physical disability such that they could not write or see. After the trial court declined to addthe mail-in ballotsto appellants vote total, filed this expedited appeal contendingthat the trial court abused its discretion in failing to count the three mail-in ballots.

DISCUSSION

          The standard of review for an appeal from a judgment in an election contest is whether the trial court abused its discretion. Tiller v. Martinez, 974 S.W.2d 769, 772 (Tex. App.—San Antonio 1998, pet. dism’d w.o.j.). To overturn an election, the contestant must show that the outcome, as shown by the final canvass, is not the true outcome, either because illegal votes were counted, or because an election official prevented eligible voters from voting, failed to count legal votes, or engaged in other fraud or illegal conduct or made a mistake. See Tex. Elec. Code Ann. § 221.003 (Vernon 2003). The contestant has the burden to make this showing by clear and convincing evidence. Alvarez v. Espinoza, 844 S.W.2d 238, 242 (Tex. App.—San Antonio 1992, writ dism’d w.o.j.). The law presumes that the Ballot Board acted properly in rejecting and accepting ballots; to overcome this presumption, a challenger must show by clear and convincing evidence that the board erred. Id. at 244.

            “To determine whether the trial court abused its discretion, we must review and compare each signature on the early voting ballot applications and carrier envelopes the trial court found to be non-genuine to ascertain whether the signatures are similar enough (i) to compel the conclusion that the same person signed them, or (ii) to override the trial court's conclusion that the same person did not sign them.” Reese v. Duncan, 80 S.W.3d 650, 661 (Tex. App.—Dallas 2002) (“We do not determine the credibility of any witness or substitute our judgment for that of the trial court.”); See >see also Alvarez, 844 S.W.2d at 245cf. > Tiller, 974 S.W.2d at 777 (applying the standardof review in a case in which the trial court found the election judge improperlyrejected the ballots) See > Tiller, 974 S.W.2d at 777.

Appellate review for abuse of discretion on the issue of signature discrepancynecessarily requires independent review and comparison of each signature on theapplication ballots and carrier envelope certificates to determine whether thechallenged sets of signatures are so different to compel the conclusion that differentpersons signed them. Tiller, 974 S.W.2d at 777. However, the reviewing courtshould not determine the credibility of any witness or substitute itsjudgment for thatof the trier of fact. Id. Election Code Requirements & Ballot Board

          Appellant’s first contendsargument is that the Ballot Board incorrectly rejected the three ballots at issue because it impermissiblycreated an ultra vires requiredmen that the signatures on the ballot envelope and mail-in application match—a requirement, he argues, not compelled by the Election Code.

          To be entitled to vote an early voting ballot by mail, the application must be signed by the eligible voter. Tex. Elec. Code Ann. § 84.001(b) (Vernon 2003). A witness may sign for the voter if the voter cannot sign due to a physical disability or illiteracy. Id. § 1.011(a).

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Related

Munters Corp. v. Swissco-Young Industries, Inc.
100 S.W.3d 292 (Court of Appeals of Texas, 2003)
Reese v. Duncan
80 S.W.3d 650 (Court of Appeals of Texas, 2002)
Tiller v. Martinez
974 S.W.2d 769 (Court of Appeals of Texas, 1998)
Alvarez v. Espinoza
844 S.W.2d 238 (Court of Appeals of Texas, 1992)

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