McEachin v. Bolling

84 Va. Cir. 76, 2011 WL 10909615, 2011 Va. Cir. LEXIS 189
CourtRichmond County Circuit Court
DecidedDecember 16, 2011
DocketCase No. CL11-5456
StatusPublished
Cited by2 cases

This text of 84 Va. Cir. 76 (McEachin v. Bolling) is published on Counsel Stack Legal Research, covering Richmond County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McEachin v. Bolling, 84 Va. Cir. 76, 2011 WL 10909615, 2011 Va. Cir. LEXIS 189 (Va. Super. Ct. 2011).

Opinion

By Judge Beverly W. Snukals

This case is before the Court on the Plaintiff’s Motion for Temporary Injunction pursuant to Va. Code § 8.01-620 etseq. The Plaintiff, A. Donald McEachin, is a Member of the Senate. The Defendant, William T. Bolling, is the Lieutenant Governor of Virginia.

On December 5, 2011, the Plaintiff filed a declaratory judgment action requesting this Court to declare that the Lieutenant Governor is not entitled to vote to break a tie on certain matters during the upcoming session of the General Assembly. To date, the Court has no record of the Lieutenant Governor’s being served with the Complaint. In addition, on the same day, the Plaintiff filed a Motion for Temporary Injunction requesting this Court to enjoin the Lieutenant Governor from casting any tie-breaking vote on Senate organization, tax matters, election of judges, amendments to the Constitution, and other matters requiring a majority vote of the members elected to each house. The Parties appeared before this Court to argue the Plaintiff’s Motion for Temporary Injunction on December 9, 2011. Upon reviewing the memoranda submitted by the Parties and hearing oral arguments, the Court denies the Plaintiff’s Motion for Temporary Injunction for the following reasons.

[77]*77 Temporary Injunction Standard

The Virginia Supreme Court has consistently stated “the granting of an injunction is an extraordinary remedy.” Levisa Coal Co. v. Consolidation Coal Co., 276 Va. 44, 60, 662 S.E.2d 44, 53 (2008). Although there are no Virginia Supreme Court cases directly setting forth the standard for an injunction, the United States Supreme Court articulated what factors must be shown in Winter v. NRDC, Inc., 555 U.S. 7, 129 S. Ct. 365, 172 L. Ed. 2d 249 (2008). The test established in Winter requires the Plaintiff to show (1) he is likely to succeed on the merits, (2) he is likely to suffer irreparable harm in the absence of preliminary relief, (3) a balance of the equities tips in his favor, and (4) an injunction is in the public interest. Id. at 20 (citing Munaf v. Geren, 553 U.S. 674, 689-90, 128 S. Ct. 2207, 2219, 171 L. Ed. 2d 1, 16 (2008)). The Plaintiff must clearly show all four factors. The Real Truth About Obama, Inc. v. F.E.C., 575 F.3d 342, 346 (4th Cir. 2009), vacated in part on other grounds, 130 S. Ct. 876, 175 L. Ed. 2d 753 (2010) (citing Winter, 555 U.S. at 22, 129 S. Ct. at 374, 172 L. Ed. 2d at 261 (2008)). Both Parties have agreed that this is the applicable standard in Virginia. The Defendant suggests that the Plaintiff might have to meet a higher burden of proof because the temporary injunction would afford the Plaintiff substantially all of the relief he may recover at the conclusion of the declaratory judgment action. However, because the Court does not believe the Plaintiff even meets the Winter standard, it is unnecessary to address the higher standard.

Likelihood of Success on Merits

The parties present procedural as well as substantive arguments as to whether the declaratory judgment action is likely to be successful. It is only necessary for the Court to address the procedural reasons for the deficiencies in the underlying action.

A. Ripeness

Standing was not raised by the Defendant as a possible bar to the declaratory judgment action.

This Court’s power to issue a declaratory judgment is limited to “cases of actual controversy.” Va. Code Ann. § 8.01-184 (2011). The actual controversy must be “one that is justiciable, that is, where specific adverse claims based upon present rather than future or speculative facts, are ripe for judicial adjustment.” Board of Supervisors of James City County v. Rowe, 216 Va. 128, 132, 216 S.E.2d 199, 204-05 (1975) (citing City of Fairfax v. Shanklin, 205 Va. 227, 229, 135 S.E.2d 773, 775 (1964)). If there is no actual controversy, this Court is without jurisdiction to hear the case [78]*78as “the rendering of advisory opinions is not a part of the function of the judiciary in Virginia.” Liberty Mut. Ins. Co. v. Bishop, 211 Va. 414, 418, 177 S.E.2d 519, 522 (1970) (citing Criterion Ins. Co. v. Grange Mut. Cas. Co., 210 Va. 446, 449, 171 S.E.2d 669, 671 (1970)). There are significant ripeness issues related to the underlying matter that prevent the Plaintiff from clearly showing he will likely succeed on the merits.

The Plaintiff contends that the Lieutenant Governor should be enjoined from breaking a tie on matters requiring the majority vote of members elected, such as tax and budget matters, appointments, and constitutional amendments. However, in those instances, a series of events would have to occur for the Plaintiff to suffer any injury. The matter would have to get through committee, the Senate would have to vote on the issue, the vote would have to end up in a tie, the Lieutenant Governor would have to vote to break the tie, and the Governor might ultimately have to approve the matter or sign the legislation. For this Court to intervene at this point before the legislative process has even begun would be tantamount to issuing an impermissible advisory opinion. The declaratory judgment statute was not intended to vest courts with authority to render advisory opinions, decide moot questions, or answer inquiries which are merely speculative. See Patterson’s Ex’rs v. Patterson, 144 Va. 113, 119-20, 131 S.E. 217, 219 (1926).

The Plaintiff also seeks to enjoin the Lieutenant Governor from breaking a tie on organizational matters such as rule-making and committee appointments. It is equally speculative that an evenly divided Senate will vote along party lines on such matters. In fact, as pointed out by the Defendant, the Senate was able to organize itself following the 1995 election.

The Plaintiff argues there is an actual controversy before this Court because the Defendant has proclaimed his ability to vote on essentially all matters that result in a tie. The Plaintiff cites two cases in which threatened actions were ripe for decision in a declaratory judgment. However, reliance on these cases is misplaced.

In Cupp v. Board of Supervisors of Fairfax County, 227 Va. 580, 318 S.E.2d 407 (1984), the Virginia Supreme Court held that a property owner aggrieved by local government action was entitled to declaratory relief. In that case, the dispute between the parties was documented in correspondence, official written reports, and in a newly adopted ordinance. Furthermore, the Planning Commission had already made a formal decision on the application for a permit. The other case cited, Terry v. Wilder, 29 Va. Cir.

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Cite This Page — Counsel Stack

Bluebook (online)
84 Va. Cir. 76, 2011 WL 10909615, 2011 Va. Cir. LEXIS 189, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mceachin-v-bolling-vaccrichmondcty-2011.