In re Sundry Citizens of Cass Township

2 Foster 307
CourtSchuylkill County Court of Quarter Sessions
DecidedNovember 2, 1874
StatusPublished

This text of 2 Foster 307 (In re Sundry Citizens of Cass Township) is published on Counsel Stack Legal Research, covering Schuylkill County Court of Quarter Sessions primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Sundry Citizens of Cass Township, 2 Foster 307 (Pa. Super. Ct. 1874).

Opinion

Opinion delivered Nov. 2, 1874, by

Green, J.

The petition of citizens of the Township of Cass, sets forth inter alia that the election officers of that township have returned, that, James Hughes had been elected supervisor, James O’Maley, treasurer, and James Moore and Patrick Derrick, school directors at the last election and that these returns were untrue and false. It further sets forth that in point of fact, James Carney was the legally elected supervisor, and not James Hughes, that Thomas Ryan was duly elected treasurer, and not James O’Maley, and that Patrick Kelly and William Shartle were duly elected school directors and not James Moore and Patrick Derrick, having received a majority of the legal votes cast at said election. A number of specifications, charging irregularities, in the manner of conducting the election, in the receiving of illegal votes and the rejection of legal votes to an extent sufficient to change the result, are given, setting forth in detail the facts relied upon to maintain the issues raised.

The petition is signed by upwards of twenty persons, and it sets forth that they are qualified electors of the said township. The affidavit of two of the petitioners, Hugh Connery and Michael Brennan, accompanies the petition and they swear that the facts set forth are true to the best of their knowledge and belief. The petition was presented and filed on the 24th February 1874.

On the 9th of March following an amended petition was filed: This petition raised a contest as to the election of Alexander McDonald and Thomas Dormer who had been returned as auditors, and of James Mc-Keown who had been returned as town clerk, and set forth that Daniel Brennan and William Foyle were duly elected auditors, and Henry East-cock, town clerk, they having received a majority of the legal votes for said offices, respectively.

On the nth of May following a second amended petition was filed. This petition is silent as to any contest for auditors and town clerk, and confines the question to the issues raised in the first petition — that is — -as [308]*308to the offices of supervisor, treasurer and school directors. The specifications are ten in number, and do not vary substantially from the specifications in the preceeding petitions.

The defendants have moved to quash the petiton upon various grounds, the principal one being that one petition cannot raise a contest involving the election of different persons to different offices — that there must be separate, petitions for each office that may be contested. This objection if sustained is fatal to the petition.

Upon reason and the well recognized principles of law, this objection seems to me to be well founded. A contest in one and the same proceeding for two or more offices, raises separate and distinct issues, between different parties having no connection with each other, and for offices which are entirely independent of each other. The facts which may be proven to decide the issue in one case may be of an entirely different character from the facts proven in the other. The judgment in the one case might be entirely different from the judgment in the other, and the proper disposition of the costs difficult to determine in such an event. Such a joinder of actions between different parties would be unheard of, and contrary to all the analogies of the law.

But it may be said, the proceeding to contest an election is entirely the creature of statute law. Does the statute authorize the joinder of these different issues in one proceeding ? The 153rd and 154th sections of the act of 2nd July, 1839, provide the method of procedure in the case of a contested election and read as follows: Sec. 153. “The several courts of quarter sessions shall have jurisdiction to hear and determine all cases in which the election of any county or township officer by the citizens in the respective county may be contested.” Sec. 154. “Upon the petition in writing of at least twenty qualified electors of the proper county or township, as the case may be, complaining of an undue election or false return of any such officer, the court shall appoint a suitable time for hearing such complaint, notice of which shall be given to the person returned., at least ten days before such hearing: Provided, &c.”

It is very evident from the language of the act, that a contest only as to a single office, and not as to two or more is contemplated. We have already seen that the general spirit and principles of the law do not require us to enlarge its letter so as to make it embrace three or more contests for as many different offices. The books show many cases of contested elections, but I have found none where more than one contest was waged in a single proceeding. It may be further worthy of remark that the new election law passed the 19th of May, 1874, also excludes the idea that there can be a proceeding, in which more than one office is contested in the same petition. The 18th Section of the Act directs that “notice of the filing of the petition with a copy thereof shall be served upon the person whose right of office shall be contested

[309]*309The complainants, realizing the force of this objection, claim that, at all events, under the petition, the Court has the power, after hearing, to set aside the election, and to declare, that none of the persons voted for, are entitled to hold the offices. That such a power exists is established by many decisions, but the circumstances under which it may be exercised, maybe somewhat more difficult to determine. What might be good cause for deciding an election in favor of a contestant, would not be necessarily good ground for setting an election aside and creating a vacancy Where an election is regularly held by legally chosen officers at the place and time fixed by law, it would not be set aside even though many irregularities may have been committed, and enough illegal votes received to have changed the result of the election, if it had been conducted fairly. For the election itself is legal, even though the person returned may not be the legally elected officer. I find but few instances of the setting aside of an election, but they serve to illustrate the principle. In the case of “The Penn District Election, 2 Parsons, 526”' — -the prayer of the petition was to set aside an election, at which a number of officers had been returned as elected, for the reason that the polls had been closed several hours earlier than the hour prescribed by law. As this deprived the legal voters of the opportunity of exercising the right of suffrage, the election was declared illegal and was set aside. So also in the case of The Locust Ward Election, 3 Penn’a. L. J. 341, where the polls had been kept open for some time after the legal hour of closing, and votes enough had been polled after the proper hour to have possibly changed the result, then the election was set aside as not legal. Those voting after the proper hours lost their opportunity, and by receiving their votes it rendered the election just as null as if they had been permitted to cast them on the following day. In Melvins case 18 P. F. Smith, 333, it is decided that “ if an election be held at a place not fixed by law the returns should be stricken out by the return judges’ ’ and that “a whole election district may be stricken out on.showing an •entire disregard of conformity to the law in holding it, either by design or ignorance,” and “where an election was not opened till 2 o’clock P. M., the law requiring it to be opened between 6 and 7 o’clock A. M. the return should be rejected.” Says Thompson, C. J.

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Bluebook (online)
2 Foster 307, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-sundry-citizens-of-cass-township-paqtrsessschuyl-1874.