Kemp v. Gonzalez

849 S.E.2d 667, 310 Ga. 104
CourtSupreme Court of Georgia
DecidedOctober 8, 2020
DocketS21Q0068
StatusPublished
Cited by1 cases

This text of 849 S.E.2d 667 (Kemp v. Gonzalez) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kemp v. Gonzalez, 849 S.E.2d 667, 310 Ga. 104 (Ga. 2020).

Opinion

310 Ga. 104 FINAL COPY

S21Q0068. KEMP et al. v. GONZALEZ et al.

MELTON, Chief Justice.

This election case comes before us based on the following

certified question submitted to this Court by the United States

Court of Appeals for the Eleventh Circuit:

Does OCGA § 45-5-3.2 conflict with Georgia Constitution Article VI, Section VIII, Paragraph I (a) (or any other provision) of the Georgia Constitution?

For the reasons that follow, we conclude that the answer to the

question is “yes” to the extent that OCGA § 45-5-3.2 authorizes a

district attorney appointed by the Governor to serve beyond the

remainder of the unexpired four-year term of the prior district

attorney without an election as required by Article VI, Section VIII,

Paragraph I (a) of the Georgia Constitution of 1983 (“Paragraph I

(a)”).

1. The facts are not in dispute. On March 6, 2020, Deborah

Gonzalez attempted to qualify for the November 3, 2020 general election for the office of district attorney for the Western Judicial

Circuit after Ken Mauldin resigned from the office effective

February 29. The Georgia Secretary of State determined that

Gonzalez could not qualify for the November 2020 election for

district attorney because, under OCGA § 45-5-3.2 (a), there would

not be an election for that position until November 2022 — the state-

wide general election immediately prior to the expiration of the

Governor’s future appointee’s term. See OCGA § 45-5-3.2 (a) (Where

the Governor fills a vacancy in the office of district attorney, the

appointee “shall serve until January 1 of the year following the next

state-wide general election which is more than six months after the

date of the appointment of such individual, even if such period of

time extends beyond the unexpired term of the prior district

attorney.”). Though the vacancy began more than six months before

the scheduled November 2020 election, the Governor did not make

2 an appointment in time to maintain that scheduled election

pursuant to the provisions of the statute.1

On May 18, 2020, Gonzalez and four other registered voters2

sued the Governor and the Secretary of State in the United States

District Court for the Northern District of Georgia. Gonzalez alleged

that OCGA § 45-5-3.2 (a) violates Paragraph I (a). A week later,

Gonzalez filed a motion for preliminary injunction, asking the

district court to require the Governor and the Secretary of State to

move forward with the November 2020 election for the Western

Judicial Circuit district attorney. The district court granted the

request, finding that Gonzalez likely would succeed on her federal

due process claim because OCGA § 45-5-3.2 (a) conflicts with

Paragraph I (a) and is therefore unconstitutional under Georgia law.

See Duncan v. Poythress, 657 F2d 691, 704 (5th Cir. 1981) (“It is

1 According to Gonzalez’s brief, the Governor still has not made an appointment to fill the vacancy.

2 The other registered voters are April Boyer Brown, Adam Shirley, Andrea Wellnitz, and Linda Lloyd. For ease of reference, Gonzalez and the other registered voters will be referred to collectively as “Gonzalez.” 3 fundamentally unfair and constitutionally impermissible for public

officials to disenfranchise voters in violation of state law so that they

may fill the seats of government through the power of appointment.

. . . [S]uch action violates the due process guarantees of the

fourteenth amendment [of the United States Constitution].”). In

July, the Governor and the Secretary of State appealed to the

Eleventh Circuit, which certified the above-referenced question to

this Court.

2. In evaluating whether OCGA § 45-5-3.2 (a) violates the

Georgia Constitution,

we recognize at the outset that all presumptions are in favor of the constitutionality of an Act of the legislature and that before an Act of the legislature can be declared unconstitutional, the conflict between it and the fundamental law must be clear and palpable and this Court must be clearly satisfied of its unconstitutionality. Moreover . . . statutes are presumed to be constitutional until the contrary appears.

(Citation and punctuation omitted.) JIG Real Estate v. Countrywide

Home Loans, 289 Ga. 488, 490 (2) (712 SE2d 820) (2011).

4 With these principles in mind, our analysis begins with the text

of Paragraph I (a), which states:

There shall be a district attorney for each judicial circuit, who shall be elected circuit-wide for a term of four years. The successors of present and subsequent incumbents shall be elected by the electors of their respective circuits at the general election held immediately preceding the expiration of their respective terms. District attorneys shall serve until their successors are duly elected and qualified. Vacancies shall be filled by appointment of the Governor.

Notably, this text closely resembles constitutional language that set

the term of office for elected superior court judges under the 1877

Constitution (as amended in 1898), which this Court interpreted in

Hooper v. Almand, 196 Ga. 52, 57-58 (1) (25 SE2d 778) (1943). In

Hooper, an incumbent judge died shortly before the end of his four-

year term, and this Court determined that a judge appointed to fill

the vacancy could not serve for longer than the unexpired term of

the deceased judge without an election for a successor taking place.

See id. at 59-61 (1). At the time that Hooper was decided, Article VI,

Section III, Paragraph I of the 1877 Constitution provided for at

least one superior court judge in each circuit “whose term of office

5 shall be four years, and until his successor is qualified.”

(Punctuation omitted; emphasis supplied.) Id. at 57 (1). Paragraph

II of Section III stated in pertinent part:

The successors to the present and subsequent incumbents shall be elected by the electors entitled to vote for members of the General Assembly of the whole State, at the general election held for such members, next preceding the expiration of their respective terms. . . .

(Emphasis supplied.) Id.

The same pertinent constitutional language also existed at

that time with respect to the selection of solicitors-general, whose

duties later became those of district attorneys. See Copland v.

Wohlwender, 197 Ga. 782, 784 (2) (30 SE2d 462) (1944) (interpreting

Article VI, Section XI, Paragraph I of the Georgia Constitution of

1877, which stated in relevant part, “There shall be a solicitor-

general for each judicial circuit, whose official term (except to fill a

vacancy) shall be four years. The successors of present and

subsequent incumbents shall be elected by the electors of the whole

Free access — add to your briefcase to read the full text and ask questions with AI

Related

TAYLOR, EXR. v. THE DEVEREUX FOUNDATION, INC. (And Vice Versa)
885 S.E.2d 671 (Supreme Court of Georgia, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
849 S.E.2d 667, 310 Ga. 104, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kemp-v-gonzalez-ga-2020.