Dowling v. Orleans Parish Democratic Committee

102 So. 2d 755, 235 La. 62
CourtSupreme Court of Louisiana
DecidedApril 21, 1958
Docket44006
StatusPublished
Cited by35 cases

This text of 102 So. 2d 755 (Dowling v. Orleans Parish Democratic Committee) is published on Counsel Stack Legal Research, covering Supreme Court of Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dowling v. Orleans Parish Democratic Committee, 102 So. 2d 755, 235 La. 62 (La. 1958).

Opinions

FOURNET, Chief Justice.

In compliance with the provisions of R. S. 18:364, requiring disposition of cases of this character within twenty-four hours after submission, we herewith hand down our decision — the reasons for which will follow in due cours.e.

[67]*67The judgment of the lower court is annulled and set aside, and it is now ordered, adjudged and decreed that there be judgment herein in favor of the plaintiff, Richard A. Dowling, and against the defendants, Malcolm V. O’Hara and the Orleans Parish Democratic Committee, decreeing that the plaintiff, Richard A. Dowling, has received a majority of the votes legally cast in the second primary election held in New Orleans on February 25, 1958, and accordingly is the nominee of the Democratic party for the office of District Attorney for the Parish of Orleans. Defendants to pay all costs.

HAMITER, J., dissents, being of the opinion that the holding of another second primary should be ordered. HAWTHORNE, J., concurs in part and dissents in part and will assign written reasons. McCALEB, J., concurs in the reversal of the judgment but dissents from the ruling that contestant is Democratic nominee and will assign written reasons.

Opinion

The plaintiff, Richard A. Dowling, having qualified as a candidate for the Democratic nomination for the office of District Attorney for the Parish of Orleans in the Democratic primary held on February 4, 1958, and received the second highest number of votes, was one of the two candidates in the second primary election for that office held in New Orleans on February 25, 1958, as a result of which his opponent therein, Malcolm V. O’Hara, was certified as the Democratic nominee by the Orleans Parish Democratic Committee; and has instituted suit to contest that election, alleging that he, plaintiff, received a majority of the legal votes cast and is entitled to be the party nominee in the forthcoming General Election, in that all of the 232 absentee ballots cast in the second primary (105 for plaintiff and 127 for O’Hara) were void ab initio because the Legislature has failed to provide a method by which absentee voting can be accomplished where voting machines are used, no provision having been made for ballot boxes wherein the absentee ballots “shall” be deposited; 1 and the elimination of those ballots would leave a majority in his (plaintiff’s) favor of 9 votes in the case of the tabulation of the Orleans Parish Democratic Committee, and 13 votes in the case [69]*69of the totals obtained from the voting machines by the Parish Custodian of voting machines;2 that the method used by the commissioners of election in the second primary to record said absentee votes, 1. e., opening the envelopes, unfolding and examining the ballots, and recording them on the tabulation sheets as indicated by the vote, destroyed the secrecy of the ballot as provided for in the Louisiana Constitution, Article 8, Section 15; 3 if this Court should hold that such procedure is the method intended by the Legislature, then Act 415 of 1952 (providing for absentee voting) is null and void because violative of the same provisions of the Constitution; and that timely protest was made before the Orleans Parish Democratic Committee of the “void” absentee votes, but to no avail. In the alternative it is alleged that on the day of the election, frauds and irregularities were committed by the commissioners of election throughout the City of New Orleans, particularly in certain named precincts of certain wards, in that (a) names of persons who did not personally appear in the polling places were placed on the poll list, and votes were actually cast through the voting machine; (b) that persons were allowed to vote without the necessity of signing the precinct register; (c) that signatures which are questionable and which are apparently not the signa- _ tures of the persons registered appear on precinct registers; and (d) that a system of fraud has been developed whereby a voter is required to place his signature on the precinct register without the commissioner writing on said register the date that the signature was so placed, as required by law (R.S. 18:256), thus leaving the door open to the casting of unlimited fraudulent votes; and that “such irregularity and fraud are of such a nature and in such quantity that the result of this election would be materially changed if such illegal and fraudulent votes were eliminated.”

It is further alleged, with particularity, that in Ward 17, Precinct 13 — where there was no commissioner representing the plaintiff and all commissioners were of the [71]*71O’Hara faction — certain named persons, 59 in number,4 whose names appear on an attached photostatic copy of the poll list, were shown as voting on February 25, 1958, but the permanent precinct register contains no entry of a date showing that the said persons voted on that day, and that “the number of undated entries in the permanent precinct register for the election of February 25, 1958, is so excessive, and the indication of fraudulently cast votes [is] so strong, that the court should disregard the returns of the entire precinct;” in the Third Precinct of the Second Ward, there appears on the poll list the names of 17 persons who did not sign the precinct register and there appears on the voting machine 17 more votes than there are signatures on the precinct register; that two other named persons did not go to the polls and did not vote on February 25, although an entry was made in the permanent precinct register indicating that those two persons appeared and cast their votes; that certain other entries on the precinct register are irregular and illegal either because of want of date or commissioner’s signature, signature of the voter, or not the genuine signature of the person; that all commissioners were from the faction supporting O’Hara and plaintiff was unrepresented, or if committed at a time when plaintiff was represented, the fraudulent acts were done surreptitiously, so that there was no opportunity for detection. Plaintiff asserts that these illegal votes should be subtracted from the total votes received in that precinct by O’Hara. The same irregularities are alleged in the Third Precinct of the Tenth Ward; and in the Thirteenth Precinct of the Tenth Ward there is the additional allegation that “somebody was permitted to vote after placing this questionable signature on the precinct register because the name of the registered voter is included in the poll list.” It is alleged that in the First Precinct of the Third Ward, the commissioners voted two absentee votes through the voting machines and in addition thereto added the same two votes to the tally sheet as absentee votes; “that the action of the commissioners was protested by a watcher and supporter of your petitioner, and that the said commissioners in said precinct laughed at and ignored such protest.” In the Twelfth Precinct of the Fifth Ward, where all of the commis[73]

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Bluebook (online)
102 So. 2d 755, 235 La. 62, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dowling-v-orleans-parish-democratic-committee-la-1958.