Fallowfield Township Election

18 Pa. D. & C. 87, 1932 Pa. Dist. & Cnty. Dec. LEXIS 436
CourtWashington County Court of Quarter Sessions
DecidedFebruary 6, 1932
DocketNo. 333
StatusPublished

This text of 18 Pa. D. & C. 87 (Fallowfield Township Election) is published on Counsel Stack Legal Research, covering Washington County Court of Quarter Sessions primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fallowfield Township Election, 18 Pa. D. & C. 87, 1932 Pa. Dist. & Cnty. Dec. LEXIS 436 (Pa. Super. Ct. 1932).

Opinion

Brownson, P. J.,

-[The facts found are summarized in the court’s discussion.]

Section twenty-nine of the Act of June 10,1893, P. L. 419, as amended by the Act of April 14, 1897, P. L. 23, provides: “Whenever in any contested election the tribunal trying the ease shall decide that the ballots used in one or more election districts were, by reason of the omission, addition, misplacing, mis-spelling or mis-statement of one or more titles of offices, or names of candidates, or parties or policies represented by them, so defective as to the office in contest as to be calculated to mislead the voters in regard to any of the candi[88]*88dates nominated for said office, and that the defective condition of the said ballots may have affected the result of the entire election for said office, the said tribunal shall declare the election to be invalid as regards the said office,” etc.

The effect of these provisions would seem to be that, if it were made to appear that “the ballots used in one or more election districts” in voting for the candidates contained this error of omitting the designation of Dworatzek as the candidate of the Democratic Party and substituting therefor the untrue statement that he (as well as Beazell) was nominated by the Republican Party, it would be the duty of the court to declare this election void: Foy’s Election, 228 Pa. 14; Snodgrass’s Case, 267 Pa. 494.

But what is the meaning of the phrase “the ballots used”? This same phrase occurs in section fifteen of the statute, which provides that all “the ballots used” at the same voting place shall be alike, and shall be printed “upon white paper,” etc. It evidently was intended to have the same meaning in each of the instances in which it is employed, and it seems to be clear that, in each instance, it refers to the official ballots used by the electors for the casting of their votes — those which, after marking their choices thereon, they deposit in the ballot box. The intent and meaning of the enactment would appear to be that when the ballots thus used are so printed as to be capable of affecting the result of the voting, it shall be conclusively presumed that an intelligent expression of the voters’ will has been interfered with. Upon the mere proof of that state of facts there is a conclusive statutory presumption of the invalidity of the election. The reason why section twenty-nine enacts that the mere fact of there being on those ballots misleading statements, which “may have affected the result” of the voting, shall require the election to be declared invalid as to the office in question, is that they have gone into the hands of every voter who participated in the election for the specific purpose of being used by him in casting his vote, and every such voter has thus been exposed to the misleading operation of them, and that it is impracticable to investigate the extent to which such ballots actually did, by misleading voters, affect the result, because such an inquiry, involving as it would calling upon electors to disclose how they marked their ballots, would violate the “secrecy in voting” that article eight, section four of the Constitution, as amended November 5, 1901, requires to be maintained. Such would seem to be the thought and idea which led to the framing of this enactment in the form and language given to it by the legislature. But, be this as it may, I think it clear, upon the language of the enactment, that it refers solely to the official ballots “used” in voting, by being, deposited in the ballot box, and that it is only the occurrence of confusing or misleading statements thereon that gives rise to the statutory presumption of invalidity.

In the present case it appears that the official ballots used at this election, i. e., the white ballots upon which electors were to mark their choices (and also the “specimen ballots” officially furnished by the county commissioners to the election officers, and by the latter furnished at the polls to voters), were absolutely correct, having nothing upon them in the way of any misinformation or misleading statement. This being so, the facts do not bring the case within section twenty-nine, and the statutory presumption of invalidity does not arise.

But, apart from section twenty-nine of the statute, if the contestants should be able to show that, by something not coming within the statutory rule therein laid down, voters have been led to misunderstand the situation in sufficient number to justify the conclusion that the result of their voting was (or, perhaps, probably was) different from what it would have been had they not so been deceived, doubtless this election could be set aside upon the general prin[89]*89eiples that are applicable to elections. In such case, however (circumstances sufficient to raise the statutory presumption of invalidity not being shown), the question would appear to be one of fact, and the burden would seem to rest upon the contestants to present competent legal proofs, direct or circumstantial, from which a conclusion of fact, justifying the setting aside of the election, can be drawn.

Let us, then, consider just what the contestants have proved as a basis for the drawing of such a conclusion.

It appears that certain papers, which purported to be but were not true copies of the official ballots, had been to some extent circulated among the electors. As already shown by the findings of fact, these were not officially furnished nor put out by the county commissioners. They were privately printed and furnished and (to the extent to which they were circulated among electors) were privately circulated. They incorrectly represented the Republican Party as having two nominees for the office of justice of the peace — Earl Beazell and Stephen Dworatzek — whereas there was but one justice of the peace to be elected, and the only Republican nominee for that office was Beazell, Dworatzek being the Democratic (instead of the Republican) nominee therefor. The cause of this was a typographical error of a compositor employed in the establishment of the printing company that prepared these papers purporting to be copies of the official ballot, which error escaped attention until after the papers had been printed and circulated. If they had any effect in misleading voters, so as to affect their voting, it could be only by causing persons who did not know the contrary to believe that Mr. Dworatzek had the Republican nomination, and that, therefore, a cross-mark in the Republican square, in the first column of the official ballot, would have the effect of a vote for him; and if thirty-seven persons who desired to vote for Dworatzek were thus misled into placing a mark in the party square for a straight Republican ticket and relying upon this as having the effect of operating as a vote in Dworatzek’s favor, the result of the election would be affected.

But, excluding from consideration hearsay testimony (which was ruled upon the trial to be incompetent), there is no clear affirmative proof that more than about twenty-five electors of the township actually saw and read these purported copies before voting. Probably a great many more persons did see them, but this was not proved by legal evidence. Nor is there any competent evidence that any voter was in fact misled by them.

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Related

Foy's Election
76 A. 713 (Supreme Court of Pennsylvania, 1910)
Snodgrass's Case
110 A. 293 (Supreme Court of Pennsylvania, 1920)

Cite This Page — Counsel Stack

Bluebook (online)
18 Pa. D. & C. 87, 1932 Pa. Dist. & Cnty. Dec. LEXIS 436, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fallowfield-township-election-paqtrsesswashin-1932.