John P. Hampton v. Audie Barber

CourtIndiana Court of Appeals
DecidedAugust 21, 2020
Docket20A-MI-143
StatusPublished

This text of John P. Hampton v. Audie Barber (John P. Hampton v. Audie Barber) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John P. Hampton v. Audie Barber, (Ind. Ct. App. 2020).

Opinion

FILED Aug 21 2020, 8:16 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

ATTORNEY FOR APPELLANT ATTORNEY FOR APPELLEE Louis Denney Brian M. Pierce Muncie, Indiana Muncie, Indiana

IN THE COURT OF APPEALS OF INDIANA

John P. Hampton, August 21, 2020 Appellant-Defendant, Court of Appeals Case No. 20A-MI-143 v. Appeal from the Delaware Circuit Court Audie Barber, The Honorable Peter D. Haviza, Appellee-Plaintiff. Special Judge Trial Court Cause No. 18C02-1911-MI-873

Najam, Judge.

Statement of the Case [1] John P. Hampton, a Muncie City Councilman, appeals the trial court’s order

granting Audie Barber’s request for a permanent injunction following his

complaint for ouster of an unlawful office holder in which the court concluded

that, under Indiana Code Section 3-5-8-1(e), Hampton is not eligible to hold a

Court of Appeals of Indiana | Opinion 20A-MI-143 | August 21, 2020 Page 1 of 8 seat on the Muncie City Council. Hampton raises two issues for our review,

which we revise and restate as follows:

1. Whether Barber had standing to file the complaint against Hampton.

2. Whether Indiana Code Section 3-8-1-5(e) is unconstitutional as applied to him.

[2] We affirm.

Facts and Procedural History [3] At some point in 2019, an at-large councilman on the Muncie City Council

either withdrew or resigned from his position, and his seat became available.

Hampton, Barber, and two other individuals applied to the Democratic Central

Committee to fill the vacancy. On August 27, the committee held a caucus to

vote for a candidate to fill the position. Hampton received the most votes, and

Barber came in third. Accordingly, the precinct committeemen selected

Hampton to fill the vacant seat on the city council.

[4] Thereafter, on November 7, Barber discovered that Hampton had been

convicted of two prior felony convictions that were later reduced to

misdemeanors. Accordingly, on November 19, Barber filed a verified

complaint and information for ouster of an unlawful office holder and for a

permanent injunction. In that complaint, Barber alleged that Indiana Code

Section 3-8-1-5(d) and (e) precluded any person who had been convicted of a

felony from assuming or being a candidate for an elected office even if that

Court of Appeals of Indiana | Opinion 20A-MI-143 | August 21, 2020 Page 2 of 8 felony had been later reduced to a misdemeanor. Accordingly, Barber

maintained that Hampton was not eligible to serve as an elected official because

of his prior convictions. Barber also asserted that he was authorized to file the

complaint against Hampton because he had an interest in the office.

Specifically, he alleged that he had been an unsuccessful candidate for the same

council seat and that he would again attempt to hold that office if a vacancy

were to occur as a result of his complaint against Hampton.

[5] The court held a hearing on Barber’s motion on December 18. At that hearing,

Barber introduced evidence that, on June 19, 1998, Hampton pleaded guilty to

dealing in marijuana, as a Class D felony, in Monroe County. See Ex. Vol. III

at 6. Barber also introduced evidence that, on June 30, 2000, Hampton pleaded

guilty to possession of a controlled substance, as a Class D felony, in Brown

County. See id. at 4. Hampton did not dispute his criminal history, but he

testified that the trial court had reduced both of his offenses to Class A

misdemeanors following his successful completion of probation. Hampton then

asserted that Barber was not “a proper person” to bring the complaint against

him because Barber had finished third out of four at the caucus election and, as

such, that Barber did not have an interest in the office. Tr. at 19.

[6] Following the hearing, the court entered findings and conclusions. Specifically,

the court found that Barber “has an interest in the office, in that he was also a

candidate, albeit unsuccessful[.]” Appellant’s App. Vol. II at 34. The court

also found that Indiana Code Section 3-8-1-5(d) and (e) prohibits any person

who has been convicted of a felony from holding office even if that conviction

Court of Appeals of Indiana | Opinion 20A-MI-143 | August 21, 2020 Page 3 of 8 was later reduced to a misdemeanor. Accordingly, the court concluded that

Barber had standing to file the complaint against Hampton and that Hampton

“is not eligible to hold any seat” on the city council. Id. This appeal ensued.

Discussion and Decision Issue One: Barber’s Standing

[7] Hampton first asserts that Barber lacked standing to file the complaint against

him. In determining that Barber was a proper person to file the complaint, the

trial court issued findings of fact and conclusions thereon. As this Court has

recently stated:

Where, as here, issues are tried upon the facts by the trial court without a jury, and the trial court enters specific findings sua sponte, we apply a two-tiered standard and determine whether the evidence supports the findings, and then whether the findings support the judgment. Findings and conclusions will be set aside only if they are clearly erroneous, that is, when the record contains no facts or inferences to support them. A judgment is clearly erroneous when our review of the record leaves us with a firm conviction that a mistake has been made.

VanHawk v. Town of Culver, 137 N.E.3d 258, 265 (Ind. Ct. App. 2019) (internal

citations omitted).

[8] Here, Barber filed his complaint against Hampton pursuant to Indiana Code

Section 34-17-1-1(1) (2020), which provides that an information may be filed

against any person when that person “usurps, intrudes into, or unlawfully holds

or exercises a public office” in Indiana. And Indiana Code Section 34-17-2-

Court of Appeals of Indiana | Opinion 20A-MI-143 | August 21, 2020 Page 4 of 8 1(a)(2) provides that that information may be filed by the prosecuting attorney

or “by any other person on the person’s own relation, whenever the person

claims an interest in the office” that is the subject of the information.

[9] On appeal, Hampton asserts that the evidence does not support the trial court’s

finding that Barber had standing to file the complaint against him. As this

Court has previously stated, a private person may file an information to

determine the right of a party to hold office “only if he claims an interest on his

own relation or a special interest beyond that of a taxpayer.” City of Gary v.

Johnson, 621 N.E.2d 650, 652 (Ind. Ct. App. 1993). The individual “must

demonstrate a personal interest distinct from that of the general public, which

interest must be in the right or title to the office.” Id. Indeed, our Supreme

Court has held that an individual is authorized to file such an action when that

individual “lives in the district from which he claims the appointee must be

selected and by his own act has made himself a candidate for that office.” State

ex rel. Brown v. Cir. Ct. of Marion Cty., 430 N.E.2d 786, 787 (Ind. 1982).

[10] Here, the undisputed evidence demonstrates that Barber is a resident of the City

of Muncie. The evidence further shows that Barber applied for the vacant seat

on the Muncie City Council, which vacancy was ultimately filled by Hampton.

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