Lay v. Cherokee Nation Election Commission

2 Am. Tribal Law 16
CourtCherokee Nation Judicial Appeals Tribunal
DecidedMarch 26, 1999
DocketJAT Case No. 99-10
StatusPublished
Cited by1 cases

This text of 2 Am. Tribal Law 16 (Lay v. Cherokee Nation Election Commission) is published on Counsel Stack Legal Research, covering Cherokee Nation Judicial Appeals Tribunal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lay v. Cherokee Nation Election Commission, 2 Am. Tribal Law 16 (cherokeeapp 1999).

Opinion

ORDER

DARRELL DOWTY, Justice.

On the 23rd day of March, 1999, a hearing was held before this Court upon the Petition and Application of Nick Lay seeking relief from the decision of the [19]*19Cherokee Nation Election Commission [hereinafter “Commission”], entered on or about the 16th day of March, 1999, wherein, by written Order, the Commission permanently disqualified the Plaintiff from holding elected office in the Cherokee Nation. The Plaintiff, Nick Lay, appeared in person and with James Wilcoxen, his Attorney. The Defendant Commission appeared by Donald G. Hopkins and Christine P. Folsom-Smith, its Attorneys.

This matter is properly before this Court pursuant to the provisions of Legislative Act 7-97 [hereinafter the Act], enacted by the Council of the Cherokee Nation on the 12th day of May, 1997. Specifically, the Commission acted under the provisions of § 38 of the Act and these proceedings are governed by § 37 thereof Plaintiff timely filed his appeal on the 17th day of March, 1999, pursuant to § 37(B) of the Act within five (5) days of receipt of notice of his disqualification and this Court gave notice and timely set hearing in this matter pursuant to § 37(C) of the Act.

STATEMENT OF THE CASE

On the 26th day of February, 1999, the Commission issued its Notice of Hearing in case No. CNEC-99-01, directed to Nick Lay and commanding him to appear before the Commission on the 11th day of March, 1999, to answer to two (2) counts of interference with the Commission in the performance of its duties, citing 26 CNCA § 38 and § 2.10 of the Rules and Regulations of the Commission. On said date, hearing was held in executive session before the Commission with all members in attendance with Christine P. Folsom-Smith, its Attorney and Nick Lay appearing in person and with James Wilcoxen, his Attorney. The filings, exhibits and transcript of that proceeding have been made available to this Court together with a copy of the relevant Rules and Regulations. Subsequently, on or about the 16th day of March, 1999, the written Order of the Commission issued as hereinabove cited. From said Order, Plaintiff filed his appeal on the 17th day of March, 1999.

THE ISSUES AND THE FACTS

The Plaintiff has timely filed his Declaration of Candidacy with the Commission for the office of Council Member for District 8 and is an incumbent candidate for the office. The Constitution of the Cherokee Nation (1976) provides that “Any member by blood of the Cherokee Nation at least twenty-five (25) years of age on the date of the election may be a candidate for the Council”. The right to run for political office upon meeting these threshold requirements, is granted and guaranteed by the Constitution and any action by the Government which infringes on this right must be subjected to the strict scrutiny of this Court, both as to procedural and substantive issues. It is from this posture that our inquiry must begin.

This is a case of first impression asking this Court to review the action of the Commission under LA 7-97 and specifically, § 38 thereof Legislative Act 7-97 at § 38, delegates to the Commission the authority and duty to permanently disqualify a candidate who “... directly of indirectly interferes or attempts to interfere with the Election Commission in the performance of its duties..1”. The Rules and Regulations [20]*20adopted by the Commission control the proceedings of the Commission hearing and the Commission must prove by “a preponderance of the evidence” that the acts alleged occurred before permanent disqualification to hold elected office is mandated2.

The allegations contained in the Commission’s Notice were twofold, to-wit that Plaintiff interfered with the Commission in the performance of its duties by:

1. usurping the authority of the Commission in assuming the responsibility for determining the eligibility of precinct workers based on possible relationships by affinity or consanguinity to candidates, and
2. diverting time, services and limited funds supporting the duties of the Commission to the voters, by the filing of lawsuits in JAT-97-05, JAT-97-06 and JAT-99-08 and by bringing protest petitions without merit before the Commission.

In the Commission’s Order issuing from the hearing, the Plaintiff was permanently disqualified to hold elected office with the Cherokee Nation by attempting to interfere with the duties of the Commission based upon the following grounds by a preponderance of the evidence:

1. By attempting to usurp the authority of the Cherokee Nation Election Commission in the hiring of precinct workers;
2. By committing perjury in a letter to the Cherokee Nation Election Commission, a letter that became an exhibit to JAT 99-08, a petition submitted under an affidavit sworn to and signed by the Respondent as true and correct; and
3. By diverting time and money from the 1999 Cherokee Nation voters to obtain the heretofore nonexistent 1995 actual voters list and further, causing the limited funding allocated to the Cherokee Nation Election Commission to be diverted to attorney’s fees rather than critical voter-oriented projects.

This Court must first take notice that the Order of the Commission is defective on its face in that it fails to recite findings of fact and conclusions of law as required by the Rules and Regulations of the Commission3. Under our duty of strict scrutiny, for this reason alone, the Order of the Commission cannot stand. However, given the gravity of the lower decision and critical time frame of the [21]*21approaching election, the Court will address the substantive issues of law and fact attendant to the Commission’s decision.

As to the first finding by the Commission in its Order, the facts adduced at the hearing before this Court were as follows:

On or about February 15, 1999, Plaintiff sent a letter to the Cherokee Nation Election Commission requesting the names and addresses of the precinct workers in the next election4. On February 19, 1999, the Commission responded to Plaintiffs request by letter from its Attorney denying his request5. On February 23, 1999, the Plaintiff filed his appeal of the denial by the Commission for the precinct workers list in JAT-99-08, which matter is presently pending before this Court.

The Court has listened to the argument of counsel in light of the evidence above and can see no basis upon which the Commission could have concluded by a preponderance of the evidence that the delivery of the letter request by the Plaintiff to the Commission constituted a usurpation of the authority of the Election Commission to determine the eligibility of precinct workers. The evidence upon which the Commission’s finding was made was purported to be the content of the letter stating the reason for which the Plaintiff needed the precinct worker's list. There was no evidence to indicate that the Plaintiff was intending to use the lists to usurp the authority delegated to the Commission.

The Defendant argued that the timing of the request was premature since the lists were not yet available and precinct workers had not been contracted.

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

Related

Mayes v. Cherokee Nation Election Commission
4 Am. Tribal Law 52 (Cherokee Nation Judicial Appeals Tribunal, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
2 Am. Tribal Law 16, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lay-v-cherokee-nation-election-commission-cherokeeapp-1999.