In Re Shana R. Arthur v. the State of Texas

CourtCourt of Appeals of Texas
DecidedMarch 15, 2024
Docket09-24-00093-CV
StatusPublished

This text of In Re Shana R. Arthur v. the State of Texas (In Re Shana R. Arthur v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Shana R. Arthur v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-24-00091-CV __________________

IN RE DUKE W. COON

AND

NO. 09-24-00093-CV __________________

IN RE SHANA R. ARTHUR

__________________________________________________________________

Original Proceedings Montgomery County, Texas __________________________________________________________________

MEMORANDUM OPINION

In separate mandamus petitions, Duke W. Coon (Coon) and Shana R. Arthur

(Arthur) ask this Court to compel the Respondent, Soco M. Gorjón (Gorjón), in her

capacity as the City Secretary of the City of Conroe Texas, to reject applications to

appear on the ballot filed by Real Parties in Interest Bobby Todd Yancey (Yancey)

1 and Curt L. Maddux (Maddux). The mandamus record establishes that on January

17, 2024, Gorjón accepted Yancey’s and Maddux’s applications for a place on the

ballot in the May 4, 2024 General Election for the City of Conroe. Coon and Arthur

assert that Gorjón accepted the applications, but she should have rejected the

applications when each application was received by Gorjón. They ask this Court to

compel her to now reject the applications as a duty imposed by law in connection

with the holding of the election. See Tex. Elec. Code Ann. §§ 273.061-.063; see also

Tex. R. App. P. 52. We deny the petitions for a writ of mandamus.

Background

Yancey and Maddux are currently serving as councilmen on the City Council

for the City of Conroe. Both Yancey and Maddux have submitted applications for a

place on the May 2024 general election ballot. Yancey has submitted an application

to appear on the ballot for the position of Mayor, while Maddux has submitted his

application to appear on the ballot for re-election to his current position for place 2

on the City Council. The filing period for the May 2024 election commenced on

January 17, 2024, and concluded on February 16, 2024. According to Coon, on

January 17, 2024, Gorjón retrieved Yancey’s application from his desk at the City’s

offices. Coon contends that Yancey left the field for “occupation” blank but

Yancey’s signature was on the application when it was retrieved from his desk. That

said Coon contends that the notary’s signature and stamp were absent at that time.

2 According to Arthur, on January 17, 2024, Gorjón also retrieved Maddux’s

application from his desk at the City’s offices, and when she did so Maddux’s

signature was on the application, but the notary’s signature and stamp were absent.

Coon and Arthur contend that the City Secretary gave Yancey’s and Maddux’s

applications to a notary public in the City’s office and the notary then notarized the

applications and signatures for Yancey and Maddux.

A copy of the application filed by Yancey and Maddux appears in the

mandamus appendix for each mandamus petition. Yancey’s and Maddux’s

application each bear the signature of an Official Authorized to Administer Oath and

each is stamped with a seal as a Notary Public for the State of Texas. The

applications are dated January 17, 2024, are signed by the candidates, and bear

Gorjón’s signature with a notation that each was received at 8:00 am on January 17,

2024, and accepted by Gorjón that same day. The field for date of birth and

occupation are blank on Yancey’s application. Yancey’s application states a length

of continuous residence in Texas of 64 years, 6 months and states Yancey has lived

in the territory for which the office is sought for 7 years, 6 months. The field for date

of birth is blank on Maddux’s application, but his occupation is listed as being

employed by Conroe Golf Cars. Maddux’s application states a length of continuous

residence in Texas of 55 years, 6 months and states Maddux has lived in the territory

for which the office is sought for 48 years, 6 months.

3 Coon and Arthur do not argue that Yancey and Maddux failed to sign the

applications, nor do they contend that either signature has been forged. Additionally,

they do not argue that either Coon or Arthur is unqualified by residency, or age to

serve on the City Council. Rather, they argue Gorjón should have rejected the

applications because Maddux and Yancey affixed their signatures to the applications

on a date before January 17, 2024, and they were not physically present when the

notary affixed her signature and seal to the applications. Consequently, Coon and

Arthur argue, Yancey and Maddux actually failed to swear to the information in the

application and failed to swear to their oaths in the application wherein they promise

to uphold the Constitutions of the United States and the State of Texas. Coon argues

that in addition to failing to swear an oath to uphold the Constitutions, Yancey failed

to comply with the requirements of the Election Code when he left blank the section

on the application requiring him to identify his occupation. Coon and Arthur argue

that under the Election Code Gorjón had a ministerial duty to reject the applications

because these defects rendered the applications invalid. On January 17, 2024, Gorjón

accepted both applications. However, after the filing deadline had closed, a request

was made for Gorjón to reject the applications. Coon and Arthur contend they did

not know about the irregularities in question until March 2024, which they admit

was after the filing deadline had closed. Relators ask this Court to compel Gorjón to

now reject the applications.

4 Mandamus Review

Mandamus relief is an extraordinary remedy that issues only to correct a clear

abuse of discretion for which the relator has no adequate remedy by appeal. In re

Prudential Ins. Co. of Am., 148 S.W.3d 124, 135-36 (Tex. 2004) (orig. proceeding).

A court of appeals “may issue a writ of mandamus to compel the performance of any

duty imposed by law in connection with the holding of an election or a political party

convention, regardless of whether the person responsible for performing the duty is

a public officer.” Tex. Elec. Code Ann. § 273.061(a).

That said, the Texas Supreme Court has “long and consistently held, ‘[t]he

public interest is best served when public offices are decided by fair and vigorous

elections, not technicalities leading to default.’” In re Walker, No. 24-0016, 2024

Tex. LEXIS 17, *1 (Tex. 2024) (orig. proceeding) (quoting In re Francis, 186

S.W.3d 534, 542 (Tex. 2006) (orig. proceeding)). “[P]rovisions that restrict the right

to hold office must be strictly construed against ineligibility.” Id. at *3 (quoting

Francis, 186 S.W.3d at 542 & n.34 and citing In re Green Party of Tex., 630 S.W.3d

36, 39 (Tex. 2020) (orig. proceeding)). Mandamus is not issued as a matter of right.

Id. Even if a candidate’s application may have some deficiencies, an opposing

candidate is not entitled to mandamus relief when the opposing candidate’s claims

require factual determinations. See In re Angelini, 186 S.W.3d 558, 560 (Tex. 2006)

(orig. proceeding).

5 Coon states “there is no dispute that Councilman Yancey signed the

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Related

In Re Prudential Insurance Co. of America
148 S.W.3d 124 (Texas Supreme Court, 2004)
In Re Francis
186 S.W.3d 534 (Texas Supreme Court, 2006)
In Re Angelini
186 S.W.3d 558 (Texas Supreme Court, 2006)

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Bluebook (online)
In Re Shana R. Arthur v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-shana-r-arthur-v-the-state-of-texas-texapp-2024.