Paul v. State Board of Elections

10 Va. Cir. 421, 1988 Va. Cir. LEXIS 14
CourtRichmond County Circuit Court
DecidedFebruary 24, 1988
DocketCase No. N-5652-4
StatusPublished

This text of 10 Va. Cir. 421 (Paul v. State Board of Elections) 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
Paul v. State Board of Elections, 10 Va. Cir. 421, 1988 Va. Cir. LEXIS 14 (Va. Super. Ct. 1988).

Opinion

By JUDGE RANDALL G. JOHNSON

Plaintiffs have filed this action seeking an injunction requiring the State Board of Elections to provide, on the official ballot for the November, 1988 general election, space to write in the names of candidates of the Libertarian Party for President and Vice-President of the United States, and the names of such candidates of the American party, as well as the names of the candidates for electors nominated by the Libertarian Party and the American Party and expected to vote for those parties’ nominees for President and Vice-President. Plaintiffs are Ron Paul, the Libertarian Party’s candidate for President in the November, 1988 general election; Delmar Dennis, the American Party’s candidate for President in said election; and the Virginia affiliates of the Libertarian and American Parties. The State Board of Elections (the "Board") is the named defendant. The complaint alleges that in spite o the provision in Article II, § 3, of the Constitution of Virginia that "[i]n elections other than primary elections, provision shall be made whereby votes may be cast for persons other than the listed candidates or nominees," the Board has taken the position that voters will not be allowed to [422]*422write in the names of the Libertarian and American Parties’ candidates.

The Board has demurred to the complaint and has also filed a motion to dismiss. The demurrer lists six grounds:

1. That the provisions of the Virginia Code dealing with presidential elections §§ 24.1-158 through 24.1-162 do not provide for write-in voting in presidential elections;

2. That the election laws of Virginia have consistently been interpreted and applied as not requiring or permitting write-in voting in presidential elections;

3. That Va. Code § 24.1-159 provides a clear and simple method by which electors for candidates for President and Vice-President for groups other than "political parties" may be placed on the ballot;1

4. That plaintiffs have not alleged that they will be irreparably injured should the court deny the requested relief;

5. That the Board has no authority to provide relief which is contrary to Va. Code §§ 24.1-158 through 24.1-162; and

6. That the language of Article II, § 3, of the Constitution of Virginia concerning write-in voting is not self-executing.

The Board’s motion to dismiss is based on what the Board contends is the res judicata effect of an order entered by the Supreme Court of Virginia on October 29, 1984, in Libertarian Party of Virginia v. State Board of Elections, Record No. 841506, granting the Board’s motion to dismiss the Libertarian Party’s application for a writ of mandamus which contained the same allegations and sought the same relief -- though for the November, 1984 general election and with regard to the Libertarian Party only -- as are involved here. The parties have briefed all of the issues, and the court has heard oral argument of counsel. Because the doctrine of res judicata, if applicable, would be a complete bar to this action, it will be addressed first.

[423]*423The controlling principles applicable to res judicata are set out in Storm v. Nationwide Insurance Company, 199 Va. 130, 97 S.E. 2d 759 (1957):

A judgment is not res adjudicata if it does not go to the merits of the case. To constitute a bar, it must appear either upon the face of the record or be shown by extrinsic evidence that the previous question was raised and determined in the former suit, and that the former suit was determined on its merits
A judgment is on the merits when it amounts to a decision as to the respective rights and liabilities of the parties, based on the ultimate fact or state of facts disclosed by the pleadings or evidence, or both, and on which the right of recovery depends, irrespective of formal, technical, or dilatory objections or contentions
The true test of the conclusiveness of a former judgment with respect to particular matters is identity of issues. If a particular point or question is in issue in the second action, and the judgment will depend on the determination of the particular point or question, a former judgment between the same parties will be final and conclusive in the second if that same point was in issue and adjudicated in the first suit. ...
The issue decided in the former action must have been identical with the issue presented in the second action, and the party now sought to be barred or one in privity with the party against whom the judgment was rendered. . . 199 Va. at 134.

Applying those principles here, it is obvious that the issue raised in this action is identical to the issue raised in the 1984 application to the Supreme Court; that is, whether Article II, § 3, of the Constitution [424]*424of Virginia requires the Board of Elections to allow write-in voting in presidential elections. The remaining question, then, is whether "it appear[s] either upon the face of the record or. . . [from] extrinsic evidence that the previous question was. . . determined in the former suit, and that the former suit was determined on the merits." Id. (emphasis added). I conclude that it was not.

In response to the application for a writ of mandamus in the Supreme Court, the Board filed a motion to dismiss which contained two grounds: first, that there is no clear legal duty imposed on the Board to allow write-in voting, nor any clear legal right of the applicant to the availability of such voting; and second, that issuance of the writ "at this time would be harmful to the interests of the public and third persons, in that preparations for the November election are virtually complete and votes have already been cast by absentee ballot."2 The entire order of the Supreme Court granting the motion to dismiss is as follows:

On October 4, 1984, came the applicant, by counsel, and filed an application in the above-styled case.
Thereupon came the respondent, by counsel, and filed its brief and motion to dismiss the application, to which the applicant filed an opposition thereto. [Sic]
On consideration whereof, the Court, for the reasons stated in the motion to dismiss, is of opinion that said motion is granted and the application for writ of mandamus is refused.
It is therefore ordered that the respondent recover of the petitioner its costs by it expended about its defense herein.

The instant plaintiffs contend that the above order is not a definitive ruling on the constitutional issue presented. Instead, they claim that the Supreme Court denied the writ because of the nearness of the election [425]*425only. In support of their position, plaintiffs cite Klarfeld v. Salsbury, 233 Va. 277, 355 S.E.2d 319 (1987), in which it is stated:

Firmly established in the field of constitutional law is the doctrine that a court will not rule upon the constitutionality of a statute unless such a determination is absolutely necessary to the decision of the case on the merits. 233 Va. at 286.

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Related

Robb v. Shockoe Slip Foundation
324 S.E.2d 674 (Supreme Court of Virginia, 1985)
Klarfeld v. Salsbury
355 S.E.2d 319 (Supreme Court of Virginia, 1987)
County School Board of Prince Edward County v. Griffin
133 S.E.2d 565 (Supreme Court of Virginia, 1963)
Storm v. Nationwide Mutual Insurance
97 S.E.2d 759 (Supreme Court of Virginia, 1957)
City of Newport News v. Woodward
51 S.E. 193 (Supreme Court of Virginia, 1905)

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Bluebook (online)
10 Va. Cir. 421, 1988 Va. Cir. LEXIS 14, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paul-v-state-board-of-elections-vaccrichmondcty-1988.