State Ex Rel. Kay v. Board of Elections

167 N.E.2d 112, 112 Ohio App. 4, 84 Ohio Law. Abs. 267, 15 Ohio Op. 2d 296, 1960 Ohio App. LEXIS 634
CourtOhio Court of Appeals
DecidedApril 18, 1960
Docket25215
StatusPublished

This text of 167 N.E.2d 112 (State Ex Rel. Kay v. Board 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. Kay v. Board of Elections, 167 N.E.2d 112, 112 Ohio App. 4, 84 Ohio Law. Abs. 267, 15 Ohio Op. 2d 296, 1960 Ohio App. LEXIS 634 (Ohio Ct. App. 1960).

Opinion

OPINION

By SKEEL, J.

This appeal comes to this court on questions of law from a judgment entered for the defendant after trial to the court in the Court of Common Pleas of Cuyahoga County. The action was one in mandamus wherein the relator prayed for an order directing the Board of Elections of Cuyahoga County not to print the name of A. L. Kearns on the Republican Primary Ballot as a candidate for the office of County Prosecutor for the primary election to be held May 3, 1960, as provided by law.

The facts, as shown by the transcrpit and bill of exceptions, are:

First: That A. L. Kearns filed five petition papers with the Board of Elections of Cuyahoga County as a candidate for the office of County Prosecutor as the basis for having his name printed on the Republican Party ballot as a candidate to be presented to the Republican voters for the primary election-to be held May 3, 1960.

Second: That seventeen names out of a total of one hundred twenty-five names contained in the petition were duplicated (fifteen of such duplications being on one petition containing twenty-five names) and one signer on the petition was not a registered voter. There were 105 undisputed valid signers on the petition, one hundred signers being the number required by §3513.06 R. C., to qualify for the office for which the petition was filed.

Third: The five petition papers filed by the candidate upon which his declaration of candidacy was printed were acknowledged separately by two notary publics and the date of such acknowledgement was recorded thereon as January 29, 1960. It is also made to appear that the signers affixed their signatures to the petitions on January 28th. This fact appears by affidavits of nine of the signers filed by the relator with the Election Board.

Fourth: Affidavits were also filed with the Election Board by each notary public, who verified the signatures of the candidate on his declaration of candidacy, stating that the declaration was sworn to by the candidate on January 28th and that the date of the 29th was in error. This fact is not otherwise disputed.

*269 Fifth: Some claim is also made by the relator-appellant that in attempting to take depositions of certain witnesses before the trial of this case, the witnesses who were subpoenaed refused to testify until the mileage and one day’s witness fee of three dollars was paid and that upon citation of such witnesses to the court by the notary, the court held, upon trial, that the witnesses acted within their lawful rights. It was the contention of the relator that the witness fee, as provided by law, was one dollar, which it was claimed was tendered, instead of three dollars, the amount demanded by the witnesses.

Sec. 3513.05 R. C., in part, provided, after setting out the manner in which a protest against a primary petition is to be filed and notices of hearing of the protest given:

«<* * *

“At the time fixed such election officials shall hear the protest and determine the validity or invalidity of the declaration of candidacy and petition. If they find that such candidate is not an elector of the state, district, county, or political subdivision in which he seeks a party nomination or election to an office or position, or has not fully complied with §§3513.01 to 3513.32 inclusive, R. C., his declaration of candidacy and petition shall be determined to be invalid and shall be rejected, otherwise it shall be determined to be valid. Such determination shall be final.”

The approach of the Board of Elections in determining a protest is to see to it that every qualified elector who desires to be a candidate for public office and who complies reasonably with the statutory requirements should not be prevented from accomplishing his purpose by inconsequential technicalities in carrying out statutory requirements.

In State, ex rel. McGowan v. Board of Elections of Summit County et al, 157 Oh St 428, 105 N. E. 2d 639, the court said in the syllabus:

“Where a protest against a candidacy is filed pursuant to the provisions of §4785-70 GC, on the sole ground that in 1930 the candidate falsely stated in his registration with the board of elections that he was born in Ohio, whereas, he was born in Ireland, and, upon hearing, it is established that his parents immigrated to America about the time he was born and that he could not determine with certainty whether he was born before or after their arrival in Ohio, but that his honest belief at the time of his said registration was that he was born in Ohio and it is further established that his father became a naturalized citizen of Ohio in 1892 when the candidate was seven years of age, the board of elections is required to overrule the protest and sustain the declaration of candidacy.”

and on page 434 of the opinion, quoting from the Court of Appeals opinion in the same case, said:

“The duty of the election board is to see to it that only those who are privileged by law to vote are permitted to exercise that sovereign right. It is equally their duty not to deprive one who is by the Constitution and laws of the United States and state of Ohio an elector of the right to vote or run for public office.”

In the case of State, ex rel. Slink, v. Eyrich, 157 Oh St 338, 105 N. *270 E. 2d 399, the court concluded that a finding of the Board of Elections regarding the voting residence of a candidate will not be disturbed by a court unless the evidence before the board was such as to require, as a matter of law, a determination that the candidate’s voting residence was not as stated in his declaration of candidacy. In other words, if there is substantial evidence to sustain the decision of the Board of Elections, such decision must be sustained. In passing on a protest against the sufficiency of a candidate’s declaration and petition where there is no claim of fraud or corruption on the part of the board, unless there is shown to be a clear violation of law by the protestant, this court cannot say that the board abused its discretion. The last sentence of the majority opinion on page 339 provides:

“The record of the hearing before the board discloses substantial evidence supporting the finding of the board, and such finding will not be disturbed by this court.”

This conclusion is clearly applicable to the hearing before the board in this case. A transcript of the hearing on this protest, with supporting evidence, was received in evidence upon hearing of this case from which it is clear that the board exercised its sound discretion in finding the essential provisions of the statutes regulating filing of nominating petitions seeking to become a party candidate for a public office.

We hold that the same candidate may make as many separate declarations of candidacy in his petition papers as there are separate petition papers so long as there is no conflict. The statute does not set out the manner in which the Board of Elections is to conduct a hearing of a protest.

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State, Ex Rel. v. Bd. of Edn.
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Bluebook (online)
167 N.E.2d 112, 112 Ohio App. 4, 84 Ohio Law. Abs. 267, 15 Ohio Op. 2d 296, 1960 Ohio App. LEXIS 634, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-ex-rel-kay-v-board-of-elections-ohioctapp-1960.