Smith v. Ladner

288 F. Supp. 66, 1968 U.S. Dist. LEXIS 9386
CourtDistrict Court, S.D. Mississippi
DecidedAugust 8, 1968
DocketCiv. A. 3905
StatusPublished
Cited by10 cases

This text of 288 F. Supp. 66 (Smith v. Ladner) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Ladner, 288 F. Supp. 66, 1968 U.S. Dist. LEXIS 9386 (S.D. Miss. 1968).

Opinion

COLEMAN, Circuit Judge:

This litigation challenges § 5310.1 of the Mississippi Code of 1942 1 regulating *68 and prescribing the procedure for the issuance of charters to non-profit corporations, as being unconstitutional and void. Specifically, it is alleged that the statute vests unconstitutionally broad discretion in the Governor to grant or deny nonprofit corporate charters. To the extent hereinafter indicated, we agree with the challengers.

Section 5310.1 provides that an application for a charter of incorporation for a non-profit corporation must be submitted to the Secretary of State, who in turn submits it to the Attorney General. After receiving the application,

“the Attorney General, or his assistants at his direction, may, in his discretion, make such investigation as he may deem necessary to determine in his opinion whether the issuance of the charter to the corporation as applied for is contrary to the best interest of the State of Mississippi.”

The Attorney General then submits his opinion to the Governor, who has the absolute power to approve or disapprove the charter. The statute includes no guides or standards to regulate this approval or disapproval. Thus it may be said that discretion thus granted by § 5310.1 is unlimited in scope.

I

Courts have repeatedly held that any statute which confers such absolute and arbitrary discretion on a state official to grant or deny a right or privilege is unconstitutional. The landmark case is Yick Wo v. Hopkins, 118 U.S. 356, 6 S.Ct. 1064, 30 L.Ed. 220 (1886). The Supreme Court there considered a statute granting absolute discretion to a public officer to grant or deny licenses to operate laundry businesses in San Francisco.

The Court said:

“When we consider the nature and theory of our institutions of govern *69 ment, the principles upon which they are supposed to rest, and review the history of their development, we are constrained to conclude that they do not mean to leave room for the play and action of purely personal and arbitrary power. * * * For, the very idea that one may be compelled to hold his life, or the means of living, or any material right essential to the enjoyment of life, at the mere will of another, seems to be intolerable in any country where freedom prevails, as being the essence of slavery itself.” Id. at 369-370, 6 S.Ct. at 1071.

The Mississippi Supreme Court has held that statutes vesting unlimited discretion in a state official are violative of both the Fourteenth Amendment and the Mississippi Constitution. In Broadhead v. Monaghan, 238 Miss. 239, 117 So.2d 881 (1960) the Court held that :

“In delegating powers to an administrative body with respect to the administration of statutes, the legislature must ordinarily prescribe a policy, standard, or rule for their guidance and must not vest them with an arbitrary and uncontrolled discretion with regard thereto.”

A similar holding was made in State v. Allstate Ins. Co., 231 Miss. 869, 97 So.2d 372 (1957), concerning a licensing statute for insurance companies. See also Louisiana State Board of Embalmers v. Britton, 244 La. 756, 154 So.2d 3,89 (1963); Lee v. Renfro, 257 Ala. 679, 60 So.2d 849 (1952).

Unless there are specific standards for the granting or denying of a charter, all charters which comply with the statutes and Constitution of Mississippi and of the United States must be granted. In Hornsby v. Allen, 5 Cir., 1964, 326 F.2d 605, 612, it was held that in the absence of any standards for the issuance of liquor licenses, the courts must enjoin the denial of licenses to any applicants who comply with existing law.

Similar findings of the unconstitutionality of regulatory statutes for lack of specific standards have been made by state courts. In a recent decision concerning a New York statute much like § 5310.1, requiring judicial approval for charters for non-profit corporations, the New York Court of Appeals held that, in the absence of a clearly expressed legislative standard for approval, approval could only be denied if the charter failed to satisfy some specific requirement of New York law, Association for Preservation of Freedom of Choice, Inc. v. Shapiro, 9 N.Y.2d 376, 214 N.Y.S.2d 388, 174 N.E.2d 487 (1961).

That Court held that a judge could not deny a charter because he found it not to be “in accord with public policy” or to be “injurious to the community.” Otherwise, the court said:

“[the] individual Justice would be at liberty to indulge in his own persona] predilections as to the purpose of a proposed corporation, and impose his own personal views as to the social, political, and economic matters involved.” Id. at 382, 214 N.Y.S.2d at 391, 174 N.E.2d at 489.

II

Even if it is argued that § 5310.1 does not grant absolutely unlimited discretion to the Governor, but that it limits his disapproval to those charters which are not in the best interest of the State of Mississippi that standard is so vague as to be unconstitutional on its face.

Many courts have held that similarly vague standards do, in effect, grant unlimited discretion to a licensing officer, and that they are unconstitutional. In Staub v. City of Baxley, 355 U.S. 313, 322, 78 S.Ct. 277, 2 L.Ed.2d 302 (1958) the Supreme Court considered a statute in which the standard was the “effects upon the general welfare of citizens of the City of Baxley.” The Court held that:

“[t]hese criteria are without semblance of definitive standards or other controlling guides governing the action of the Mayor and Council in granting or withholding a permit.”

*70 III

If it is necessary for a state to limit the number of charters granted, all the safeguards of due process must be observed before any applicant for this reason can be denied a charter. Horns-by v. Allen, supra; Glicker v. Michigan Liquor Control Commission, 6 Cir., 1947, 160 F.2d 96. In Hornsby the Court held that an applicant for a liquor license was entitled to a hearing at which she could present evidence and cross-examine witnesses, to have the administrative findings disclosed, and to be informed of the specific regulations and statutes governing her application. Id. at 608, 610, of 326 F.2d. In the absence of such procedural safeguards a denial of a license, particularly when other applicants are granted such licenses, violates an applicant’s constitutional rights.

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Bluebook (online)
288 F. Supp. 66, 1968 U.S. Dist. LEXIS 9386, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-ladner-mssd-1968.