MacKey v. Thiel

262 Cal. App. 2d 362, 68 Cal. Rptr. 717, 1968 Cal. App. LEXIS 2320
CourtCalifornia Court of Appeal
DecidedMay 22, 1968
DocketCiv. 32101
StatusPublished
Cited by8 cases

This text of 262 Cal. App. 2d 362 (MacKey v. Thiel) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MacKey v. Thiel, 262 Cal. App. 2d 362, 68 Cal. Rptr. 717, 1968 Cal. App. LEXIS 2320 (Cal. Ct. App. 1968).

Opinion

LILLIE, J.

In January of 1967 petitioner was a candidate for city councilman in the 14th district and requested defendant to provide him with an appropriate form on which to set forth a statement of his qualifications as provided by section 10012.5, Elections Code. 1 Defendant refused to comply, asserting that the provisions of the statute do not apply to the City of Los Angeles as a chartered city (art. XI, § 8, Cal. Const.). An alternative writ of mandate was issued and subsequently, upon submission of the cause, a peremptory *364 writ which ordered defendant to provide the form sought and otherwise comply with the statute in question. Thé instant appeal is from the judgment directing the issuance of the peremptory writ.

In his answer to the petition for the peremptory writ, defendant alleged that section 8% of article XI specifically grants to chartered cities the right to provide the manner in which municipal elections shall be conducted; that pursuant thereto and further pursuant to charter authority (§ 306) an Election Code for the City of Los Angeles was adopted in 1946 providing for a comprehensive set of rules governing all phases of city elections; and that the Election Code thus adopted provides for certain information of a substantive nature respecting issues to be included with the mailing of sample ballots but not candidate qualification booklets as provided in section 10012.5. It is pointed out on this appeal that the enactment by the City of the above section 306 (Los Angeles Charter) had constitutional sanction in that section 8%, supra, declares that “It shall be competent in any charter framed in accordance with the provisions of this section . . . for any city or consolidated city and county, and plenary authority is hereby granted ... to provide therein or by any amendment thereto, the manner in which, the method by which, the times at which, and the terms for which the several county and municipal officers and employees whose compensation is paid by such city or city and county, excepting judges of the superior court, shall be elected or appointed, and for their recall and removal. ...” (Italics added.) Such “plenary authority” having been given the City, pursuant to which section 306 and its own Election Code were thereafter adopted, it is contended that the latter code, wherein no provision is made for the mailing of candidate qualification pamphlets, should prevail over the provisions of section 10012.5 (Elections Code) which conflict with “the manner in which, [and] the method by which” the City has decided that its various “municipal officers . . . shall be elected.” Such contention, it is further asserted, has the support of decisional law to the effect that local municipal elections are strictly municipal affairs.

Respondent, on the other hand, invokes Professional Fire Fighters, Inc. v. City of Los Angeles, 60 Cal.2d 276 [32 Cal.Rptr. 830, 384 P.2d 158], to the effect that since the. yariqW sections of article XI fail to define “municipal affairs,” the courts must decide under the facts of each case whether the subject matter is of municipal or statewide concern; sueffi *365 question, the court therein stated, “must be determined from the legislative purpose of each individual instance.” (P. 294.) There it was held that the legislative object of pertinent provisions of the Labor Code was to create uniform fair labor practices throughout the state, the court concluding that “Labor relations are of the same statewide concern as workmen’s compensation, liability of municipalities for tort, perfecting and filing of claims, and the requirement to subscribe to loyalty oaths.” (P. 295.) By analogy respondent argues that the enactment of section 10012.5 had for its purpose the creation of an informed and educated electorate on a statewide basis; assertedly illustrative of this claim is the “Truth in Endorsements Law” (Elec. Code, § 8600 et seq.) the constitutionality of which was upheld in California Democratic Council v. Arnebergh, 233 Cal.App.2d 425 [43 Cal.Rptr. 531], and certain language quoted from a Kansas case in Canon v. Justice Court, 61 Cal.2d 446, 458 [39 Cal.Rptr. 228, 393 P.2d 428], for the proposition that discussion by the voters of the “character and qualifications of candidates” is “of the utmost consequence.” He makes the not implausible argument that since three-fifths of the 1966-1967 state budget was spent within the boundaries of chartered cities, it would seem a matter of state concern that this money was wisely spent by elected officials whose qualifications previously were made known to the voters in the manner provided by the statute in suit. .

The difficulty with respondent’s reliance on Professional Fire Fighters, Inc., and his argument otherwise, is that California courts have already determined that the conduct of municipal elections is a municipal affair and subject to municipal control. (Socialist Party v. Uhl, 155 Cal. 776, 788 [103 P. 181].) More recently (in 1965) the general rule adhered to in Uhl was followed by the appellate court in City of Redwood City v. Moore, 231 Cal.App.2d 563 [42 Cal.Rptr. 72], it there being held that “election procedures” in a chartered city are municipal affairs (p. 585). Too, in light of the observation in Professional Fire Fighters that “Not one of the cases cited [by the City] is authority for the statement which they are supposed to support” (supra, p. 292), the decisions just mentioned carry some added significance. On the other hand, such cases as People v. Elkus, 59 Cal.App. 396 [211 P. 34], are not helpful to respondent since it involves the right to vote, not the details thereof, by imposing a so-called “proportional representation” system of voting; the above dis *366 tinction is borne out by the same court that decided Elkus which subsequently held that a chartered city (Sacramento) has control over the alphabetical listing on the ballot of candidates’ surnames. (Harder v. Denton, 9 Cal.App.2d 607 [51 P.2d 199].) In the light of the Harder holding, and as appellant properly points out, state provisions as to the form of ballots, including the sequence of names thereon, should prevail over conflicting municipal provisions if, as urged by respondent, the whole matter of sample ballots is one of educating the voters beforehand and, therefore, one of statewide concern. Such conflict exists, of course, in that section 10202, Elections Code, provides for the placing of the incumbent first whereas section 326 of the charter (Los Angeles) requires all candidates to be listed in alphabetical order.

Finally, we perceive no substantial difference between the problem here and that which confronted the court in Lawing v. Faull,

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Bluebook (online)
262 Cal. App. 2d 362, 68 Cal. Rptr. 717, 1968 Cal. App. LEXIS 2320, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mackey-v-thiel-calctapp-1968.