Halbert v. Shelby County Election Commission

31 S.W.3d 246, 2000 Tenn. LEXIS 618
CourtTennessee Supreme Court
DecidedNovember 6, 2000
StatusPublished
Cited by12 cases

This text of 31 S.W.3d 246 (Halbert v. Shelby County Election Commission) is published on Counsel Stack Legal Research, covering Tennessee Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Halbert v. Shelby County Election Commission, 31 S.W.3d 246, 2000 Tenn. LEXIS 618 (Tenn. 2000).

Opinion

OPINION

BIRCH, J.,

delivered the opinion of the court, in which

ANDERSON, C.J., HOLDER and BARKER, JJ., joined. DROWOTA, J., not participating.

This matter is before us on direct appeal from the Chancery Court of Shelby County pursuant to TenmCode Ann. § 2-17-116. At issue is Michael A. Hooks, Jr.’s eligibility to be elected to and serve on the Board of Education of the Memphis City Schools (School Board). His eligibility hinges on the meaning of the term “resident voter” as used in the School Board’s charter. Wanda Halbert, the appellant, contends that Hooks was not a “resident voter” and is thus ineligible to serve on the School Board. The trial court found that Hooks was, indeed, a “resident voter” and eligible to serve as a member of the School Board. The judgment of the trial court is, therefore, affirmed, and this cause is dismissed.

I. Facts and Procedural History

The appellant, Wanda Halbert, and the appellee, Michael A. Hooks, Jr.,1 were candidates for a seat on the Board of Education of the Memphis City Schools, to be filled by election August 6, 1998.2 Shortly before the election, Halbert learned that Hooks had registered to vote in Shelby County on June 16, 1997, and had never voted. Based on these facts, Halbert filed a petition in the Chancery Court challenging Hooks’ eligibility to serve on the School Board and seeking declaratory and injunctive relief. The trial court denied the request for a temporary restraining order. Hooks received almost fifty-six percent of the votes cast on August 6, 1998, and a majority of the votes cast in the general election held November 3, 1998.

Halbert contends that the August 6, 1998, and November 3, 1998, elections are void because Hooks was not eligible to serve on the School Board. She seeks a new election. See Forbes v. Bell, 816 S.W.2d 716, 719-24 (Tenn.1991); Emery v. Robertson Co. Election Com’n, 586 S.W.2d 103, 109 (Tenn.1979). In response, Hooks insists that he has complied with all residency and eligibility requirements or, in the alternative, if the School Board’s charter establishes a durational registration requirement, such requirement infringes on his right to hold public office in violation of the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. Cf. Dunn v. Blumstein, 405 U.S. 330, 92 S.Ct. 995, 31 L.Ed.2d 274 (1972). Thus, the essential issue before us is whether Hooks is eligible to serve as a member of the Board of Education of the Memphis City Schools. The resolution of this issue hinges on the meaning of the term “resident voter” as used in the School Board’s charter.

We are of the opinion that the term “resident voter” neither requires nor includes that the subject person either register or vote. Thus, we conclude that Hooks met all eligibility requirements for service on the School Board. We affirm the judgment of the Chancery Court and dismiss this cause of action.

II. Standard of Review

The issue presented is a question of law to be reviewed de novo with no presumption of correctness given the lower court’s judgment. Myint v. Allstate Ins. Co., 970 S.W.2d 920, 924 (Tenn.1998).

[248]*248In construing legislative enactments, the principal goals are to ascertain the legislative intent and give it effect without unduly restricting or expanding its coverage beyond its limited scope. Austin v. Memphis Pub. Co., 655 S.W.2d 146, 148-49 (Tenn.1983). That intent is primarily discerned from the language of the enactment. Browder v. Morris, 975 S.W.2d 308, 311 (Tenn.1998). “Courts are restricted to the natural and ordinary meaning of the language used by the legislature in the statute, unless an ambiguity requires resort elsewhere to ascertain legislative intent.” Id. Where different meanings are possible from the language, an ambiguity exists. Owens v. State, 908 S.W.2d 923, 926 (Tenn.1995).

III. Analysis

The Memphis City Schools is a special school district whose charter comprises a series of Private Acts of the Tennessee General Assembly, the earliest of which was enacted in 1869. The act relevant here took effect in 1970.3 Essentially, it adds to the eligibility requirements for service on the School Board by imposing a five-year durational-residency requirement:

No person shall be elected, or appointed as hereinafter provided, as a member of the Board of Education of the Memphis City Schools unless he or she shall have been a resident voter and taxpayer of the City of Memphis for not less than five (5) years preceding his or her election or appointment....

Id. (emphasis added).

The appellant concedes that Hooks has at all times been a resident of the City of Memphis. That Hooks has been eligible to vote for more than five years preceding the election is conceded also. The appellant’s sole contention, then, is that the term “resident voter” in the charter requires that a candidate actually register and vote five years prior to the election as distinguished from merely being eligible to do so. Though eligible much earlier, Hooks registered to vote approximately one year before the election. Thus, Hooks’ eligibility to serve hinges solely on the construction of Chapter 340 of the 1970 Private Acts.

To resolve this matter, we must construe the term “resident voter.” While the term is not defined in the Act, the residence requirements are not contested, so our focus is on the word “voter” as used in the term “resident voter.” The word “voter” is, however, undefined in context. Moreover, the word has several possible meanings as is noted by Black’s Law Dictionary:

The word has two meanings — a person who performs the act of voting, and a person who has the qualifications entitling him to vote. Its meaning depends on the connections in which it is used, and is not always equivalent to electors. In a limited sense a voter is a person having the legal right to vote, sometimes called a legal voter.

Black’s Law Dictionary 1576 (6th ed.1990). Thus, we must treat it as ambiguous and look to sources beyond the Act for its meaning. In so doing, we find our decision in Trammell v. Griffin4 persuasive.

In Trammell, we were asked to determine whether the word “voter,” as used in a city charter, meant “a person having the qualifications entitling him to vote, or ... a person who has registered and thus lawfully evidenced his right to vote.” Id. We concluded that “[a]n inspection of our election and registration laws demonstrates that the word ‘voter’ is used therein in the sense of one who is qualified to vote, and not in the sense of a registered voter.” Id. at 727.

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

Related

John C. Wells, III v. State of Tennessee
Court of Appeals of Tennessee, 2016
James Bates v. State of Tennessee
Court of Appeals of Tennessee, 2016
Sean Goble v. State of Tennessee
Court of Appeals of Tennessee, 2016
Ralph Thompson v. State of Tennessee
Court of Appeals of Tennessee, 2016
Kenneth Cradic v. State of Tennessee
Court of Appeals of Tennessee, 2016
Larry Smith v. State of Tennessee
Court of Appeals of Tennessee, 2016
Lewis v. Gibbons
80 S.W.3d 461 (Supreme Court of Missouri, 2002)
Letellier v. Letellier
40 S.W.3d 490 (Tennessee Supreme Court, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
31 S.W.3d 246, 2000 Tenn. LEXIS 618, Counsel Stack Legal Research, https://law.counselstack.com/opinion/halbert-v-shelby-county-election-commission-tenn-2000.