State ex rel. Hemmons v. Cuyahoga Cty. Bd. of Elections

2023 Ohio 1148
CourtOhio Court of Appeals
DecidedApril 4, 2023
Docket112403
StatusPublished

This text of 2023 Ohio 1148 (State ex rel. Hemmons v. Cuyahoga Cty. Bd. of Elections) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State ex rel. Hemmons v. Cuyahoga Cty. Bd. of Elections, 2023 Ohio 1148 (Ohio Ct. App. 2023).

Opinion

[Cite as State ex rel. Hemmons v. Cuyahoga Cty. Bd. of Elections, 2023-Ohio-1148.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, EX REL., WILLA HEMMONS, :

Relator, : No. 112403 v. :

CUYAHOGA COUNTY BOARD OF ELECTIONS, ET AL., :

Respondents. :

JOURNAL ENTRY AND OPINION

JUDGMENT: WRIT DENIED DATED: April 4, 2023

Writ of Procedendo Order No. 563279

Appearances:

Willa M. Hemmons, pro se.

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Mark R. Musson, Assistant Prosecuting Attorney, for respondents.

EILEEN T. GALLAGHER, J.:

On February 14, 2023, the relator, Willa Hemmons, commenced this

writ action against the respondents the Cuyahoga County Board of Elections and its board members, Jeff Hastings, Imajo Chappell, Terrence McCafferty, and Lisa

Stickan (“the Board”). The gravamen of this action is to compel the Board to

schedule a special recall election for three city of East Cleveland council members,

Korean Stevenson, Patricia Blochowiak, and Juanita Gowdy. The specific claims

stated in the complaint are for (1) declaratory judgment that the Board violated

Hemmons’s due process rights under the Ohio and United States Constitutions, (2)

a Title 42 United States Code § 1983 claim for deprivation of equal protection and

selective enforcement, and (3) a § 1983 claim for deprivation of substantive and

procedural due process. Hemmons claims that she is seeking a writ of procedendo

to have the Board schedule the recall election. She further seeks to have this court

declare that the recall petitions are valid and that the Board erred in denying the

signatures of over a thousand registered voters to have recall elections for the three

council members. In paragraph 41, she includes the sentence: “a writ of mandamus

is appropriate.”

This court set a briefing schedule ordering the parties to submit

evidence and briefs by March 3, 2023, and reply briefs by March 10, 2023. The

parties have complied with the order and have also filed notice of the outcome of

ancillary litigation. This court has reviewed the filings, the evidence, the briefs, and

the decision resolving the ancillary litigation, State ex rel. Richardson v. Gowdy,

Slip Opinion No. 2023-Ohio-976. This case is ripe for resolution. Factual and Procedural Background

The city of East Cleveland is a charter municipality, and Charter

Sections 49 through 54 govern recall elections. The recall procedure is started by a

qualified elector of the city obtaining from the Clerk of Council blank recall petitions.

The elector must make and submit to the Clerk of Council an affidavit stating the

name of the council member whose removal is sought. Upon issuing the petitions,

the Clerk of Council shall record the name of the elector to whom the petitions were

issued and the date of issuance. In order for the recall election to be held, the

petition must be signed by East Cleveland electors who voted in the last regular

election of each municipal officer whose recall is sought, equal in number to at least

25 percent of the total number voting at the last regular election of each such

municipal officer in which his or her office was contested.

Upon obtaining sufficient signatures within 30 days, the elector must

file the petition with the Clerk of Council, who must then certify upon the petition

whether the signatures amount to at least 25 percent of the voters voting in the last

regular municipal election of officers. If sufficient valid signatures are obtained,

then the Clerk of Council must notify the subject council member and deliver to the

election authorities a copy of the original petition with the certificate that the

petition has at least 25 percent of the voters voting in the last municipal election, i.e.,

that it is a valid recall petition. If the subject council member does not resign within

five days of being presented with the recall petition, the Clerk of Council shall notify

the elections authorities of the fact, and the election authorities shall forthwith schedule the recall election. Such election shall be held not less than 60 days nor

more than 90 days after the expiration of the five-day period.

Charter Section 111.03(a) provides that the President of Council shall

appoint and/or terminate the Clerk of Council, and Council may also elect such other

officers and employees of Council, as it deems necessary. Subsection (b) provides

that an assistant Clerk of Council may also be appointed in the same manner as

specified in subsection (a). Subsection (c) allows Council to appoint a Clerk Pro

Tempore or Deputy Clerk, in the absence of the Clerk upon such terms and

conditions as Council may determine.

On December 21, 2022, Clerk of Council Tracy Udrija-Peters issued

blank recall petitions to electors seeking to recall the three council members. On

January 3, 2023, the East Cleveland City Council elected Korean Stevenson as

Council president, and he terminated Udrija-Peters as Clerk of Council and the

Deputy Clerk of Council. This left the Council without a clerk. On January 4, 2023,

Council Member Nathaniel Martin solely on his own initiative named Law Director

Willa Hemmons as temporary Clerk of Council. This appointment was ineffective

because it was contrary to the Charter provisions.

On January 20, 2023, Hemmons accepted the recall petitions. She

reviewed the petitions for valid signatures and certified that the three petitions had

a sufficient number of valid signatures to hold a recall election. She so notified the

three subject council members pursuant to the requirements of the charter and

submitted the petitions to the Board of Elections along with her certification that there were sufficient, valid signatures, so that the Board should schedule the recall

elections.

On February 13, 2023, the Board of Elections conducted a hearing on

whether it should schedule the recall elections. During the hearing, Hemmons

admitted that she was not the Clerk of Council. (Tr. 5.) Accordingly, the Board of

Elections did not schedule the recall elections, because the recall petitions were not

processed and presented as required by the East Cleveland Charter. Hemmons then

commenced this action.

Legal Analysis

This court first notes that the specific claims Hemmons avers to are not

appropriate. Her first claim is for a declaratory judgment that the Board of

Elections’ selective action is unconstitutional as applied as alleged in the complaint.

However, this court does not have jurisdiction to issue such declaratory judgments.

State ex rel. Hogan v. Ghee, 85 Ohio St.3d 150, 707 N.E.2d 494 (1999), and State

ex rel. Williams v. Trim, 145 Ohio St.3d 204, 2015-Ohio-3372, 48 N.E.2d 501.

Similarly, this court has original jurisdiction only over the five extraordinary writs.

It does not have jurisdiction to adjudicate § 1983 actions. State ex rel. Rodgers v.

Corrigan, 8th Dist. Cuyahoga No. 55503, 1988 Ohio App. LEXIS 4993 (Dec. 5,

1988).

The claim for procedendo is also problematic. The writ of procedendo

is merely an order from a court of superior jurisdiction to one of inferior jurisdiction

to proceed to judgment. Yee v. Erie Cty.

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Related

State ex rel. Williams v. Trim (Slip Opinion)
2015 Ohio 3372 (Ohio Supreme Court, 2015)
State ex rel. Taylor v. Glasser
364 N.E.2d 1 (Ohio Supreme Court, 1977)
State ex rel. Harris v. Rhodes
374 N.E.2d 641 (Ohio Supreme Court, 1978)
Yee v. Erie County Sheriff's Department
553 N.E.2d 1354 (Ohio Supreme Court, 1990)
State ex rel. Watkins v. Eighth District Court of Appeals
696 N.E.2d 1079 (Ohio Supreme Court, 1998)
State ex rel. Hogan v. Ghee
707 N.E.2d 494 (Ohio Supreme Court, 1999)
State ex rel. Richardson v. Gowdy
2023 Ohio 976 (Ohio Supreme Court, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 1148, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-hemmons-v-cuyahoga-cty-bd-of-elections-ohioctapp-2023.