Kizer v Livingston County Board of Commissioners

195 N.W.2d 884, 38 Mich. App. 239, 1972 Mich. App. LEXIS 1578
CourtMichigan Court of Appeals
DecidedJanuary 26, 1972
DocketDocket 13423
StatusPublished
Cited by37 cases

This text of 195 N.W.2d 884 (Kizer v Livingston County Board of Commissioners) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kizer v Livingston County Board of Commissioners, 195 N.W.2d 884, 38 Mich. App. 239, 1972 Mich. App. LEXIS 1578 (Mich. Ct. App. 1972).

Opinion

Per Curiam.

On December 28, 1970, the Attorney General addressed the following letter opinion to the Prosecuting Attorney of Clinton County:

“You have requested my opinion as to whether reapportioning the county board of commissioners *242 as required by Act 261, PA 1966 [MCLA 46.401 et seq; MSA 5.359(1) et seq\, the board of commissioners in counties the population of which on the effective date of Act 261 was less than 75,000 is authorized during a period of 30 days following the publication of the latest official United States decennial census figures of the 1970 federal decennial census to adopt a plan for that purpose.
“Reference to Section 1 of Act 261 as originally enacted discloses said section contained provision therefor. That section has since been amended by Act 153, PA 1968, and Act 137, PA 1969. Each of those amendments continued such provision without change aside from change in the name of that board. The fact that the legislature in reenacting such section, as amended, continued without change such provision evidences the legislative intent that in those counties population of which was less than 75,000 on the effective date of Act 261, the board of commissioners is authorized to draft and adopt such a plan within the 30-day period following publication of the latest official figures of each decennial census.”

The Secretary of State furnished the counties with the Federal census data needed to accomplish reapportionment on January 4, 1972 j 1 pursuant to the foregoing opinion of the Attorney General, the Livingston County Board of Commissioners began the task of reapportionment. The Livingston County Prosecutor, a member of the apportionment commission, 2 immediately filed an action in the Livingston County Circuit Court seeking a declaratory *243 judgment as to the authority of the Board of Commissioners to perform the act of reapportionment. He maintained that MCLA 46.401; MSA 5.359(1) permitted the board of county commissioners in counties of less than 75,000 population in 1960 to reapportion in conformity with the one man/one vote requirements of the statute 3 and decisions of the United States Supreme Court 4 only in the initial reapportionment upon the effective date of the county reapportionment act; 5 thereafter, after each decennial census, the prosecutor maintained that it was the sole responsibility of the apportionment commission to complete the work of reapportionment of the board of county commissioners. The circuit court agreed and designated the apportionment commission as the proper party to reapportion Livingston County. The board of county commissioners has appealed. Because of the important nature of the issue, to the reapportionment of county commissions now being accomplished throughout the state, we have given our immediate attention to the matter.

In an effort to codify apportionment procedures sufficient to effectuate the one man/one vote principle ennunciated in Reynolds v Sims, 377 US 533; 84 S Ct 1362; 12 L Ed 2d 506 (1964), and possibly to anticipate Avery v Midland County, 390 US 474; 88 S Ct 1114; 20 L Ed 2d 45 (1968), the Michigan Legislature adopted 1966 PA 261 (hereinafter cited as the County Apportionment Act). This act provided *244 for the apportionment of county Boards of Supervisors, prescribed the size of said hoards, and indicated the manner of their election. Section 1 of the original act is of primary relevance to the issue presented and read as follows:

“On or before May 15,1967, and in subsequent years within 60 days after the publication of the latest United States official decennial census figures, the county apportionment commission in each county of this state shall apportion the county into not less than 5 nor more than 35 county supervisor districts as nearly of equal population as is practicable and within the limitations of section 2. In counties under 75,000, upon the effective date of this act, the hoards of supervisors of such counties shall have not to exceed 30 days into which to apportion their county into supervisor districts in accordance with the provisions of this act. If at the expiration of the time as set forth in this section a board of supervisors has not so apportioned itself, the county apportionment commission shall proceed to apportion the county under the provisions of this act.” (Emphasis added.)

This section was amended by 1968 PA 153 (given immediate effect June 13, 1968) to read as follows: 6

“On or before May 15,1967, and in subsequent years within 60 days after the publication of the latest United States official decennial census figures, the county apportionment commission in each county of this state shall apportion the county into not less than 5 nor more than 35 county supervisor districts as nearly of equal population as is practicable and *245 ■within the limitations of section 2. In counties under 75,000, upon the effective date of this act, the hoards of supervisors of such counties shall have not to exceed 30 days into which to apportion their county into supervisor districts in accordance with the provisions of this act. If at the expiration of the time as set forth in this section a board of supervisors has not so apportioned itself, the county apportionment commission shall proceed to apportion the county under the provisions of this act. Notwithstanding any other provision of law, the initial plan for apportionment of the boards of supervisors shall be filed not later than 4 p.m. June 25,1968. In any county in which a plan is not filed by 4 p.m. on June 25, 1968, 7 supervisors shall be elected at large in 1968 for 2-year terms. In 1968 only, the deadline for filing nominating petitions or filing fees shall be 4 p.m. July 2, 1968. Because of the necessity of insuring orderly election procedures for the year 1968, in no event will litigation affect, alter, change, amend or delay any apportionment plan adopted under this act insofar as 1968 supervisor elections are concerned.” (Emphasis added.)

Section 1 was again amended by 1969 PA 137 (effective March 20, 1970), and presently states:

“Within 60 days after the publication of the latest United States official decennial census figures, the county apportionment commission in each county of this state shall apportion the county into not less than 5 nor more than 35 county commissioner districts as nearly of equal population as is practicable and within the limitations of section 2. In counties under 75,000, upon the effective date of this act, the hoards of commissioners of such counties shall have not to exceed 30 days into which to apportion their county into commissioner districts in accordance with the provisions of this act.

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Bluebook (online)
195 N.W.2d 884, 38 Mich. App. 239, 1972 Mich. App. LEXIS 1578, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kizer-v-livingston-county-board-of-commissioners-michctapp-1972.