Hubby v. Carpenter

350 S.E.2d 706, 177 W. Va. 78, 1986 W. Va. LEXIS 550
CourtWest Virginia Supreme Court
DecidedNovember 14, 1986
Docket17165
StatusPublished
Cited by3 cases

This text of 350 S.E.2d 706 (Hubby v. Carpenter) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hubby v. Carpenter, 350 S.E.2d 706, 177 W. Va. 78, 1986 W. Va. LEXIS 550 (W. Va. 1986).

Opinion

MILLER, Chief Justice:

This original proceeding in prohibition challenges the validity of W.Va. Code, 8-10-1, 1 which vests mayors with the authority to hear and determine violations of municipal ordinances, on the basis that it contravenes the separation of powers clause, Article V, Section 1 2 of the West Virginia Constitution.

*80 In April, 1986, the relator, Robert Nielsen Hubby, Jr., was arrested on a charge of contributing to the delinquency of a minor and was taken before James Carpenter, the mayor of the City of Buckhannon, who had previously issued the arrest warrant, and a hearing date was set. According to the respondent mayor, contributing to the delinquency of a minor is prohibited by Article 3 of Ordinance No. 100 of the City of Buckhannon. The relator then petitioned this Court for a writ of prohibition seeking to prevent the mayor from conducting the misdemeanor proceeding.

Section 8 of the Charter of the City of Buckhannon entitled “Legislative Department: Duties” vests the legislative power of the city in the city council composed of the mayor, the city recorder, and five councilmen. Section 10 of the Charter provides that the mayor shall preside over city council meetings, and Section 18 provides that the judicial power of the city shall be vested in a police court of which the mayor shall be the judge. 3

In the past, most challenges to municipal court procedures have been based on due process grounds or a constitutional provision specifically applicable to criminal proceedings. In Champ v. McGhee, 165 W.Va. 567, 270 S.E.2d 445 (1980), this Court invalidated a Bluefield municipal ordinance which prohibited jury trials in municipal courts and held in its single Syllabus:

“Under art. 3, § 14 of the West Virginia Constitution, the right to a jury trial is accorded in both felonies and misdemeanors when the penalty imposed involves any period of incarceration.” 4

The Court also recognized in Champ that defendants in municipal court are entitled to a twelve-person jury, although in magistrate court they would only be entitled to a six-person jury under Article VIII, Section 10 of the West Virginia Constitution. 5

Four years later in a case arising out of the same municipal court, we held in Scott v. McGhee, 174 W.Va. 296, 324 S.E.2d 710 (1984), that the due process clause of our Constitution prohibits a municipal court judge in certain circumstances from dismissing municipal charges solely because the defendant exercised his right to a jury trial. In granting a writ of prohibition to prevent dismissal of the municipal charges, we held in Syllabus Point 2:

“The due process clause of Article III, § 10 of the Constitution of West Virginia prohibits a municipal court judge from dismissing municipal charges solely because the accused has exercised his constitutional right to a jury trial, when the penalty under state law for the same offense carries a heavier jail sentence than provided for by municipal ordinance.”

The right to counsel, as guaranteed by both the United States Constitution 6 and the West Virginia Constitution, was extended in Bullett v. Staggs, 162 W.Va. 199, 250 S.E.2d 38 (1978), to criminal trials in municipal courts as reflected by Syllabus Point 1: “Absent a knowing and intelligent waiver, no person may be imprisoned for any offense, whether classified as petty, misdemeanor, or felony, unless he was represented by counsel at his trial.” We also ruled in Bullett that circuit courts under *81 W.Va. Code, 51-11-5, have the authority to appoint counsel for an indigent charged with a municipal ordinance violation.

The legislature has afforded persons convicted of municipal ordinance violations with an appeal de novo to the circuit court. W.Va. Code, 8-34-1. 7 In State v. Eden, 163 W.Va. 370, 256 S.E.2d 868 (1979), we held that our due process clause prohibits the imposition of a heavier penalty upon a defendant who exercises his right of appeal from magistrate court. In State v. Bonham, 173 W.Va. 416, 317 S.E.2d 501 (1984), we reaffirmed and extended this principle to appeals from municipal courts, stating in Syllabus Point 2:

“A defendant who is convicted of an offense in a trial before a magistrate or in municipal court and exercises his statutory right to obtain a trial de novo in the circuit court is denied due process when, upon conviction at his second trial, the sentencing judge imposes a heavier penalty than the original sentence. W.Va. Const. art. III, § 10.”

In Ward v. Village of Monroeville, Ohio, 409 U.S. 57, 93 S.Ct. 80, 34 L.Ed.2d 267 (1972), a municipal court judge was held to be subject to the due process guarantee that a judicial tribunal be neutral and detached. There, the United States Supreme Court found that a defendant was denied due process because he had been compelled to stand trial in a mayor’s court, which provided a substantial portion of the village revenues. It was also shown that the may- or had substantial executive powers with regard to administering the affairs of the municipality. 8

The Supreme Court’s decision in Ward was a logical outgrowth of its earlier decision in Tumey v. Ohio, 273 U.S. 510, 47 S.Ct. 437, 71 L.Ed. 749 (1927). In Tumey, the defendant was convicted of violating the prohibition law before the mayor of a small town in Ohio, whose regular salary was supplemented by the fees and costs he levied against persons he found to have violated municipal ordinances. The Supreme Court held the convictions violated due process, because the judge had “a direct, personal, substantial pecuniary interest in reaching a conclusion against him [the defendant] in his case.” 273 U.S. at 523, 47 S.Ct. at 441, 71 L.Ed. at 754.

We have adopted the principles of Ward and Tumey and have sustained due process challenges to our former justice of the peace system based upon the concept that the pecuniary interest of the justice of the peace disqualified him from trying the case. 9 In Keith v. Gerber, 156 W.Va. 787, 197 S.E.2d 310

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Cite This Page — Counsel Stack

Bluebook (online)
350 S.E.2d 706, 177 W. Va. 78, 1986 W. Va. LEXIS 550, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hubby-v-carpenter-wva-1986.