In re "Liberal Party"

17 Pa. D. & C. 176, 1931 Pa. Dist. & Cnty. Dec. LEXIS 312
CourtPennsylvania Court of Common Pleas, Montgomery County
DecidedOctober 16, 1931
DocketNo. 13
StatusPublished

This text of 17 Pa. D. & C. 176 (In re "Liberal Party") is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re "Liberal Party", 17 Pa. D. & C. 176, 1931 Pa. Dist. & Cnty. Dec. LEXIS 312 (Pa. Super. Ct. 1931).

Opinion

Knight, J.,

— The facts are these:

1. In the municipal election, held November 5, 1929, the Liberal Party did not exist, and no candidate of that party appeared on the ballot.

2. In the general election of 1930, the name “Liberal Party” appeared on the ballot, having been placed thereon by virtue of nomination papers filed in the office of the Secretary of the Commonwealth, under the provisions of the Act of July 9, 1919, P. L. 855. On this ballot the sole representative of the “Liberal Party” was its candidate for governor, and no other candidate received any votes in this county as a candidate of the said “Liberal Party.”

3. On November 21, 1930, five electors of Montgomery County, the petitioners herein, preempted the name “Liberal Party” by filing a preemption in the office of the prothonotary in and for Montgomery County.

4. In the general election of 1930, no candidates were voted for to fill county offices in Montgomery County. James S. Boyd was in said election elected to the office of senator in the general assembly for the twelfth district, receiving 46,255 votes, all on the Republican ticket, and being the largest entire vote for any elected candidate in Montgomery County.

5. At said general election, John M. Hemphill, candidate for governor, received on the “Liberal” ticket 15,787 votes.

6. In the summer of 1931, the Secretary of the Commonwealth certified to the Commissioners of Montgomery County the political parties entitled by law to have their names printed on the official ballots of the primary election held September 15, 1931. Among the names so certified was that of the “Liberal Party.”

7. No nominating petitions were filed by members of the Liberal Party in Montgomery County or by the preemptors prior to the primary election held on September 15, 1931, but the ballot prepared, displayed and issued by the county commissioners contained a list of all offices, county, state and local, to be voted for at the municipal election of 1931, with a blank space under each designated office.

[177]*1778. At the primary election of September 15, 1931, nine duly enrolled members of the “Liberal Party” in Montgomery County, using ballots prepared for that party, cast their votes by writing in the names of candidates of their choice for the various state and county offices to be filled.

9. The votes thus cast were counted by the return board, and no exceptions or objections being filed within the time provided by the law, the board, on September 29, 1931, certified the returns to the county commissioners.

10. By these returns, the following candidates received the highest number of votes on the “Liberal Party” ballot, for the offices following their names: Grover C. Albright and F. Joseph Roach for county commissioners; Rodger J. Maynes for county controller; John D. Ganger for sheriff; Edward S. Haws for register of wills; Andrew B. Robinson for recorder of deeds; Charles A. De Huff for clerk of the courts; Harry S. Hartzell for county treasurer; Edward F. Kane for district attorney; Teresa A. Feeney for director of the poor; Edmund C. Rezer for director of the poor; B. Rodney Vaughan for coroner; William T. Muldrew for county surveyor.

11. On October 8, 1931, the preemptors, none of whom are now enrolled members of the “Liberal Party,” presented this petition, praying that the names of the alleged nominees of said party be removed from the ballot as candidates of said party in the municipal election to be held next month.

12. The alleged nominees filed an answer, and a hearing was held on October 13, 1931, at which the foregoing facts were developed.

Discussion

The petitioners assign several reasons in support of their petition.' They pressed but one, which is the only one that it is necessary for us to consider. It involves the underlying and fundamental question: Does the “Liberal Party” exist as a political party within Montgomery County?

The second section of the Act of July 12, 1913, P. L. 719, defines what shall constitute a political party as a legal entity. It reads as follows:

“Any party or body of electors, one of whose candidates at the general election next preceding the primary polled in each of at least ten counties of the State not less than two per centum of the largest entire vote cast in each of said counties for any elected candidate, and polled a total vote in the State equal to at least two per centum of the largest entire vote cast in the State for any elected candidate, is hereby declared to be a political party within the State; and shall nominate all its candidates for any of the offices provided for in this act, and shall elect its delegates and alternate delegates to the National convention, State committeemen, and also such party officers, including members of the National committee, as its rules provide shall be elected by a vote of the party electors, in accordance with the provisions of this act. Any party or body of electors, one of whose candidates at either the general or municipal election preceding the primary polled at least five per centum of the largest entire vote cast for any elected candidate in any county, is hereby declared to be a political party within said county; and shall nominate all its candidates for office in such county and in all political districts within said county, or of which said county forms a part, and shall elect such party officers as its rulés provided shall be elected therein by a vote of the party electors, in accordance with the provisions of this act.”

A careful reading of the above section shows that it was the legislative intent to draw a distinction between a political party in the state and a political party in a county, and this has been the construction placed upon the section by the courts of the Commonwealth: CampbelTs Nomination, 46 Pa. [178]*178C. C. 457; Forster’s Nomination Paper, 41 Pa. C. C. 696, an opinion by the attorney general; Miller v. Secretary of Commonwealth, 1 D. & C. 40.

It follows then that a political body may have the legal status of a “party” in the state and not have that status in a county, and a county may have a legal “political party” created by local conditions which may have no statewide authority or existence. That the “Liberal Party” is a legal existing political party in the state at large is conceded, and, therefore, the Secretary of the Commonwealth was correct in certifying to the Commissioners of Montgomery County that the “Liberal Party” was entitled to a separate ballot,, through which its enrolled electors in the county could vote for every statewide office. The petitioners concede this, but they contend that the “Liberal Party” does not exist as a legal political entity in Montgomery, and that, therefore, these same electors had no power to nominate candidates for county offices on the “Liberal Party” ballot.

Let us turn again to the second section of the Act of 1913, supra, the second paragraph of which defines a party within a county. We repeat the wording here:

“Any party or body of electors, one of whose candidates at either the general or

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Bluebook (online)
17 Pa. D. & C. 176, 1931 Pa. Dist. & Cnty. Dec. LEXIS 312, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-liberal-party-pactcomplmontgo-1931.