Haughton v. McCollum

530 So. 2d 758, 1988 Ala. LEXIS 253, 1988 WL 68924
CourtSupreme Court of Alabama
DecidedMay 27, 1988
Docket87-705
StatusPublished

This text of 530 So. 2d 758 (Haughton v. McCollum) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Haughton v. McCollum, 530 So. 2d 758, 1988 Ala. LEXIS 253, 1988 WL 68924 (Ala. 1988).

Opinions

BEATTY, Justice.

This is an appeal from the denial of the appellants’ request for “emergency declaratory and injunctive relief.”

Appellants, Paul Haughton, Bryant Evans, and Neil Buettner, filed suit to prevent implementation by the appellees, W. Hardy McCollum, Doris Turner, and Beasor Walker, of a plan to have election workers indicate on the official list of voters for each ward or precinct the party primary in which the voter participated.

W. Hardy McCollum is the probate judge of Tuscaloosa County, Doris Turner is the circuit clerk, and Beasor Walker is the sheriff. They constitute the board that is required, under Code of 1975, § 17-16-2, to appoint the inspectors and clerks for each voting place and the returning officer for each voting precinct, who must perform their election duties according to law. See § 17-6-10. The facts are not in dispute, and we adopt the statement thereof contained in the trial court’s order:

“The facts in this case revolve around the statutory framework of Alabama election laws and the actions of the Defendants in attempting to carry out their statutory duties thereunder. The facts are largely undisputed.
“Under current Alabama law, when a voter participates in a Presidential Preference Primary Election, the voter must present and identify himself or herself to the election officials at his or her designated polling place. After the official verifies that the voter is listed on the official voting list, the voter must publicly declare in which party’s primary he or she wishes to participate by signing the appropriate party’s polling list. The Democratic party’s polling list is one col- or and the Republican party’s list is another color. An election official then [759]*759marks the voter’s name on the official voting list to ensure that the person does not attempt to vote more than once in the election. After the election, the polling lists are sealed and forwarded to the respective chairmen of the political parties in each county. The marked copies of the official voting lists are sealed and retained by the Probate Judge of each county. Neither the polling lists nor the official voting lists may be unsealed for any purpose except in the event of an election contest. The polling lists must be destroyed 30 days after the election unless a contest is filed within that time. The Probate Judge retains the sealed voting lists for one year before destroying the lists.
“The controversy in this case centers around the instruction of the appointing board to the election officials to mark on the official voting list the names of those voters participating in the March 8, 1988 Presidential Preference Primary Election using colored markers in a manner that would identify in which party’s primary a voter participated. In uncontroverted testimony in an open hearing, Probate Judge Hardy McCollum, a named Defendant, stated that the sole purpose of such instruction was to aid in the resolution of any contested election by identifying which voters participated in which party’s primary. The coded marking of the voting list requires no disclosure from the voter other than the disclosure of party preference already required by Alabama law.
“The Plaintiffs contend that such coded marking of the voting list in effect creates a separate voting list not specifically authorized by law and that the existence of such list would tend to affect them in a disparate manner because the Plaintiffs belong to a party that is in a numerical minority in Tuscaloosa County. The Plaintiffs alleged that if voters are aware that such coding is being utilized to record who participated in the primary election, they may feel pressured to vote in the majority party’s primary because of peer pressure.
“The Plaintiffs seek (1) a ruling that such marking is contrary to Alabama law and (2) an injunction against the Defendants prohibiting the color coded marking of the voting lists.”

The trial court went on in its order to rule as follows on the matters presented by the complaint filed by appellants:

“Given the facts of the case, the current Alabama voting laws, and the testimony of the witnesses at the hearing, this Court finds that the Plaintiffs failed to meet their burden of proof that they would suffer immediate and irreparable harm absent granting of the relief sought. As to the legality of the Defendants’ instructions to Tuscaloosa County election officials, the Plaintiffs have failed to produce any statutory or judicial precedent to show that the absence of specific statutory authorization for their actions makes those instructions contrary to the statutes governing elections in Alabama. The coding of the voting list by party preference creates no record not already required by the Alabama law requiring voters to declare their party preference by signing a poll list.”

Thus, the substantive issue in the case, as framed at the beginning of the trial court’s order, is:

“[Wjhether or not the board created under Ala. Code § 17-6-1 (1987 repl. vol.) for the purpose of appointing election officials (the appointing board) may legally instruct those officials to mark the names of those voters participating in the March 8, 1988 Presidential Preference Primary Election in a manner that would identify in which political party’s primary election a voter participated. Further, the Plaintiffs ask this Court to enjoin the appointing board from so instructing voting officials.”

Appellants argue that the plan, calling for color coding of the official voting list to indicate in which party’s primary those voting participated, violates Code of 1975, § 17-7-17, which provides as follows:

“Any election officer or any other person who makes a copy of the poll list or [760]*760any memoranda therefrom, or list of the persons voting, or the number of their ballots, or discloses the number of such voter’s ballot, shall be guilty of a misdemeanor, and upon conviction, shall be fined not less than $200.00.”

This statute, passed by the legislature on October 3, 1903, was first codified in the 1907 Code at § 6806, in the portion of volume 3 entitled “the Criminal Code.” The language of the statute has remained unchanged since that first codification. In Sartain v. Shepherd, 173 Ala. 474, 55 So. 919 (1911), the first decision construing this section, the Court, speaking through Justice Somerville, noted that “Section 6806 of the Criminal Code is, of course, designed to prevent in general the making of copies of poll lists by any person, or for any use or occasion, not authorized by law; and it must be construed in connection with section 458.” (Emphasis added.) 173 Ala. at 478, 55 So. at 921.

We do not equate the procedure used in this case for checking off electors from the official voting list {viz., color-coded checkoffs indicating in which party primary each elector participated) with the sort of duplication of the poll list proscribed by § 17-7-17. First of all, § 17-16-25 provides that, as each voter votes in primary elections, “the name of the voter shall be checked off the official voting list.” Thus, the checkoff procedure is not only authorized but is required by law. Secondly, the color-coded checkoff procedure constitutes neither a “copy of the poll list,” nor a “memorand[um] therefrom.”

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Bluebook (online)
530 So. 2d 758, 1988 Ala. LEXIS 253, 1988 WL 68924, Counsel Stack Legal Research, https://law.counselstack.com/opinion/haughton-v-mccollum-ala-1988.