Shannon's Election

5 Pa. D. & C. 12, 1924 Pa. Dist. & Cnty. Dec. LEXIS 8
CourtDauphin County Court of Quarter Sessions
DecidedJanuary 11, 1924
DocketNo. 524
StatusPublished

This text of 5 Pa. D. & C. 12 (Shannon's Election) is published on Counsel Stack Legal Research, covering Dauphin County Court of Quarter Sessions primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Shannon's Election, 5 Pa. D. & C. 12, 1924 Pa. Dist. & Cnty. Dec. LEXIS 8 (Pa. Super. Ct. 1924).

Opinion

Fox, J.,

On Dec. 5, 1923, a petition signed by forty-four citizens, representing themselves as qualified electors of the 4th Ward of the Election District in the Borough of Steelton, who voted at the municipal election held on Nov. 6, 1923, was presented, setting forth, inter alia: That at that municipal election, pursuant to law, the electors of said election district voted for one person for the office of councilman from said ward; that the candidates for that office were Harry Shannon, Republican; James J. Coleman, Democratic and Prohibition, and John P. Schlessman, Socialist, whose respective names appeared and were printed, together with the party appellation or designation, upon the official ballot prepared and furnished by the county commissioners in conformity to law; that the election board publicly returned and announced, inter alia, the number of votes cast in the said election district for the office of councilman as follows: Harry Shannon received [13]*13344 votes as the Republican candidate; James P. Coleman received 318 votes as the Democratic candidate and 17 votes as the Prohibition candidate; John P. Schlessman received 6 votes as the Socialist candidate. That the return of the election board was erroneous and incorrect, in that two or more persons voted whose names were on the registry of voters, but who had removed from the ward prior to the day of the election; that three or more persons voted whose names appeared on the registry of voters, but who had not resided in the 4th Ward long enough to become qualified electors thereof; that seven or more persons voted, when their names did not appear on the registry of voters, without making the required affidavit; that three or more persons voted after having taken the required affidavit as being entitled to vote on “age,” but that said affidavits were false, in that these voters were not over twenty-one but under twenty-two years of age; that one or more persons voted without having paid a State or county tax within two years prior to said election; that two or more persons are shown by the ballot check-list as having voted, when in fact they did not vote; and that one or more persons who did vote are not shown as having done so, and that these votes were all cast for Harry Shannon, the respondent. Whereupon the court made an order adjudging, inter alia,, that the petition was sufficient and that it be filed, and that Dec. 28, 1923, at 10 o’clock A. M., was fixed for hearing the same. A rule was granted upon Harry Shannon to answer the same on' or before Dec. 28, 1923, the time fixed for hearing.

On Dec. 17, 1923, the respondent presented a petition praying for a rule upon the contestants to show cause why they should not be required to file a bill of particulars, setting forth the names of the said persons who are alleged to have voted illegally and wherein the votes were so illegally returned, which rule was granted and made returnable in five days. On Dec. 22, 1923, an answer of the contestants to the rule was filed, and on Dec. 24, 1923, upon motion by the respondent, the time for filing an answer in the above stated matter by the respondent was extended and the hearing was continuel until Jan. 25, 1924, at 10 o’clock A. M.

No objections to the original petition of the contestants have been filed, and the sole question before us is, should a bill of particulars, as requested, be furnished by the contestants?

“The proper office of a bill of particulars is to inform the opposite party and the court of the precise nature and character of the cause of action or defence for which the pleader contends in respect to any material or issuable facts in the case and which is not specifically set out in his pleadings. It is properly an amplification of the proceedings designed to make more specific general allegations appearing therein and thus avoid a surprise at the trial:” 31 Cyc., 565. In the case of Liscomb v. Agate, 51 Hun (N. Y.), 288, it was said: “The real purpose of ordering a bill of particulars is to make justice between the parties by evolving the truth from their discordant statements, and to give the parties every reasonable facility for coming to the trial fully prepared for all that may be produced by the other side.”

In the Election Cases, 65 Pa. 36, our Supreme Court said: “The only safe course in such a case is to proceed in analogy to the practice in other cases, by a notice of particulars, ordered and governed by the discretion of the court. It would be an intolerable technicality if the petitioners were required to set forth in their complaint, within ten days after the election, every illegal vote, every illegal act of the election boards, and every instance of fraud. Such a nicety would prevent investigation and defeat the remedy itself. The general rule in all pleadings is that certainty to a common intent is all that is required: [14]*14Heard’s Stephen’s PL, 380. The early decisions in this city were too stringent. A much truer exposition of the law, and one to be adhered to, is found in the opinion of the late Judge Thompson, in Mann v. Cassidy, 1 Brewst. 26, 27. As remarked by him: ‘The rule must not be held so strictly as to afford protection to fraud, by which the will of the people is set at nought, nor so loosely as to permit the acts of sworn officers, chosen by the people, to be inquired into without adequate and well-defined cause.’ ”

And then, further along: “Whether a bill of particulars or specification of facts shall be required is exclusively in the discretion of the presiding judge.” (Citing authorities.) In the case of Warren Borough Election, 274 Pa. 352, the Supreme Court said: “While a court should not be captious in viewing petitions of the character of the one here involved, yet a complaint of an undue election or a false return must be stated with clearness and precision, and the petitioners held to the exercise of due diligence to ascertain and specify the facts which, if sustained by proof, would require the court to set aside the result of the election. It was well said by Judge Allison, in Weaver v. Given, 6 Phila. 65, that ‘the court will not grope in the dark, or follow a contestant on a fishing expedition, in the hope of being able to find enough to enable him by the investigation to make out his case.’ ”

One of the best considered cases upon this subject is the case of Northampton County Contested Elections, No. 2, 6 Dist. R. 150, decided by Judge Scott, and, because of its clearness and fairness, we shall quote it quite fully. The court, at page 151, said: “The practice of requiring bills of particulars in election contests, while formerly doubted to some extent, is now sanctioned by all later authorities. But it is not well settled when the demand may be made for them by the parties who may be called upon to answer or reply. It is sometimes said that an order will be made upon both parties, in the first instance, upon petition and answer being filed; sometimes an order has not been asked until progress has been made before an examiner, or upon proofs in court; sometimes the contestant is required to furnish them, upon demand made, before the respondent files his answer. This last seems to conform more closely to the analogies of other legal proceedings, and should be followed whenever the petition for contest is general and does not embrace a specification of the illegal votes alleged as a foundation for the complaint. If a petitioner includes full particulars of this complaint in his petition, nothing further may be demanded.

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Related

Election Cases
65 Pa. 20 (Supreme Court of Pennsylvania, 1870)
Kelly's Contested Election
50 A. 248 (Supreme Court of Pennsylvania, 1901)
Warren Borough Election
118 A. 256 (Supreme Court of Pennsylvania, 1922)
Commonwealth v. Cameron
42 Pa. Super. 347 (Superior Court of Pennsylvania, 1910)

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Bluebook (online)
5 Pa. D. & C. 12, 1924 Pa. Dist. & Cnty. Dec. LEXIS 8, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shannons-election-paqtrsessdauphi-1924.