State ex rel. Corrigan v. Cleveland-Cliffs Iron Co.

169 Ohio St. (N.S.) 42
CourtOhio Supreme Court
DecidedMarch 25, 1959
DocketNo. 35819
StatusPublished

This text of 169 Ohio St. (N.S.) 42 (State ex rel. Corrigan v. Cleveland-Cliffs Iron Co.) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State ex rel. Corrigan v. Cleveland-Cliffs Iron Co., 169 Ohio St. (N.S.) 42 (Ohio 1959).

Opinion

Taft, J.

Since no question is raised as to the propriety of quo warranto as a remedy in the instant case, we will not consider that question in deciding this case.

In contending that the complained of payment and use of respondent’s $500 were unlawful, relator must rely principally upon Section 3599.03, Bevised Code, which reads so far as pertinent :

“(A) No corporation engaged in business in this state shall, directly or indirectly, pay, use, offer, advise, consent, or agree to pay or use the corporation’s money or property [a] for or in aid of a political party, committee, or organization, or [b] for or in aid of a candidate for political office, or for a nomination thereto or [c] use such money or property for [44]*44any other partisan political purpose, or [d] violate any law requiring the filing of an affidavit respecting such use of such funds.” (Emphasis added and portions in brackets added to enable ready reference in subsequent analysis.)

In the remainder of that statutory section, criminal penalties are specified for violations thereof.

There is no claim that the Citizens Committee FOR City and County Issues, hereinafter referred to as the citizens committee, did anything “for or in aid of any candidate” or failed to file any affidavit required by law. Hence the above-quoted portions of the statute appearing after [b] and [d] are not involved.

It is obvious that, in the above-quoted emphasized portion of the statute appearing after [a], the word “political” modifies not only “party” but also the words “committee or organization.” The words “political party” have a well understood ordinary meaning. Those words describe an association of individuals whose primary purposes are to promote or accomplish elections or appointments to public offices, positions or jobs. Although the word “political” may have a very broad meaning, its meaning may be considerably narrowed where it is thus used to modify the word “party.” See Heidtman v. City of Shaker Heights, 163 Ohio St., 109, 126 N. E. (2d), 138. Obviously, in referring to “a political party, committee or organization” in this statute, the General Assembly intended by the words “committee or organization” to refer only to a committee or organization which is an adjunct of a political party or an association formed for substantially the same purposes or performing substantially the same functions as a political party.

It is contended however that the contribution to the citizen’s committee is prohibited by the above-quoted words of the statute appearing after [c] as a payment “for any other partisan political purpose.” This argument might have more force if the word “partisan” had not been used by the General Assembly. See Commonwealth v. McCarthy, 281 Mass., 253, 183 N. E., 495, 85 A. L. R., 1141, where “partisan” was not used to modify “any political purpose whatever.” But see [45]*45Heidtman v. Shaker Heights, supra (163 Ohio St., 109). Thus, although the words “political purpose” may he given a broad construction as including any purpose related to the principles of civil government and the conduct of public affairs, they may also be given a much narrower construction as including only a “partisan” political purpose. In the instant case, we must so limit those words because the General Assembly has used the word “partisan” to limit them.

It is apparent from a consideration of the ratio decidendi in Heidtman v. Shaker Heights, supra (163 Ohio St., 109), that the words “partisan political purpose” can reasonably be construed so as not to include a mere purpose to advocate the passage of issues such as the citizen’s committee advocated in the November 1957 election.

All reasonable doubts in the interpretation of a criminal statute should be resolved in favor of the accused. See State v. Meyers, 56 Ohio St., 340, 47 N. E., 138; City of Cleveland v. Jorski, 142 Ohio St., 529, 53 N. E. (2d), 513. Where a word may reasonably have either a wide or a restricted meaning and there is reasonable doubt as to which meaning was intended by the General Assembly, such doubt, in the interpretation of a criminal statute, should be resolved against the state. See State v. Terre Haute Brewing Co., 186 Ind., 248, 115 N. E., 772.

In our opinion, therefore, the words “partisan political purpose,” as used in Section 3599.03, Bevised Code, do not include a purpose merely to advocate the adoption of a constitutional amendment or the passage of a bond issue or of a tax levy; and a committee organized for such purpose is not, within the meaning of that statute, a “political party, committee or organization. ’ ’

This conclusion is fortified by considering the origin and history of Section 3599.03, Bevised Code. The prohibitory provisions of that section were first enacted in 1908 as Section 1 of “ an Act to Prevent the Corruption of Elections and Political Parties by Corporations.” The somewhat modified provisions of section 2 of that act are now found in Section 5733.27, Bevised Code, requiring a corporation to file with its returns, statements and reports to the Tax Commissioner “an affidavit [46]*46* * * setting forth that such corporation has not, during the preceding year, * * * paid, used or offered, consented, or agreed to pay or use any of its money or property [a] for or in aid of any political party, committee or organization, or [b] for or in aid of any candidate for political office or for nomination for any such office, or [c] in any manner used any of its money or property for any political purpose whatever.” (Emphasis added and portions in brackets added to enable ready reference in subsequent analysis — the quoted portions after [a] were found in Section 1 of the Act of 1908 and apparently later used to replace the words originally in section 2 of that act and reading : “To the funds of any political- organization, committee or candidate, or used as money or property in violation of section 1 of this act.”) Section 3 of the 1908 Act specified criminal penalties for violations of sections 1 and 2.

In the General Code of 1910, section 1 and the penalty provisions of section 3 became Sections 13320 and 13322, General Code, and section 2, with respect to filing the affidavit, became Section 8729 (repealed in 1927), and in 1911 section 2 also became Section 5522, General Code (now Section 5733.27, Revised Code).

In 1929, the General Assembly recodified the election laws and, in doing so, replaced Sections 13320 and 13322, General Code, with Section 4785-192, General Code, and changed the words “for any political purpose whatever” to read “for any other partisan political purpose.” Section 4785-192 also contained the provision now found in Section 3599.03, Revised Code, prohibiting any violation of “any law requiring the filing of an affidavit respecting such use of such funds.” Since there was apparently no other penalty for violating the affidavit-filing requirements of Section 5522, General Code (now Section 5733.27, Revised Code), it is clear that “the filing of an affidavit” referred to in Section 4785-192, General Code, was the filing required by Section 5522, General Code.

It is suggested that, since the broad words “any political purpose whatever” are used in what is now Section 5733.27, Revised Code, and since that section and what is now Section 3599.03, Revised Code, should be read

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Related

City of Cleveland v. Jorski
53 N.E.2d 513 (Ohio Supreme Court, 1944)
Commonwealth v. McCarthy
183 N.E. 495 (Massachusetts Supreme Judicial Court, 1932)
State v. Terre Haute Brewing Co.
115 N.E. 772 (Indiana Supreme Court, 1917)
State v. Fairbanks
115 N.E. 769 (Indiana Supreme Court, 1917)
People v. Gansley
158 N.W. 195 (Michigan Supreme Court, 1916)

Cite This Page — Counsel Stack

Bluebook (online)
169 Ohio St. (N.S.) 42, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-corrigan-v-cleveland-cliffs-iron-co-ohio-1959.