Triantaphyllis, Tasso v. Gamble, Brent

Court of Appeals of Texas·Decided September 26, 2002·No. 14-02-00403-CV·Published

Opinion

Affirmed and Majority, Concurring, and Dissenting Opinions filed September 26, 2002

Affirmed and Majority, Concurring, and Dissenting Opinions filed September 26, 2002.

In The

Fourteenth Court of Appeals

____________

NO. 14-02-00403-CV

TASSO TRIANTAPHYLLIS, Appellant

V.

BRENT GAMBLE, Appellee

On Appeal from the 234th District Court

Harris County, Texas

Trial Court Cause No. 02-08865

M A J O R I T Y  O P I N I O N

            In this appeal, appellant, Tasso Triantaphyllis, the Democratic candidate for Judge of the 270th District Court of Harris County, seeks a reversal of the trial court’s final judgment and order granting a permanent injunction.  The permanent injunction directed Harris County Republican Party officials to extend the filing deadline to accept the corrected application of appellee, Brent Gamble, for the Republican primary election as a candidate for Judge of the 270th District Court, and to confirm that Gamble is the Republican Party nominee for Judge of the 270th District Court on the November general election ballot.  We affirm.

Background

            The relevant background facts in this case may be found in this Court’s opinion conditionally granting mandamus relief to Triantaphyllis.  In re Triantaphyllis, 68 S.W.3d 861 (Tex. App.—Houston [14th Dist.] 2002, orig. proceeding).  In that original proceeding, this court ordered that Gamble’s name be removed from the Republican Party general primary ballot as a candidate for the office of Judge of the 270th District Court because his application was defective.  Id. at 869-70.  The party officials complied with our directive and removed Gamble’s name. 

            Gamble then filed a petition for writ of mandamus in the Texas Supreme Court.  Although the majority opinion disagreed with this court’s construction of the Election Code, the Texas Supreme Court denied mandamus relief.  In re Gamble, 71 S.W.3d 313 (Tex. 2002).  The Texas Supreme Court found that equitable remedies may be available under limited circumstances to permit a candidate to amend a defective application after a statutory deadline has expired when an election official has violated a statutory duty.  Id. at 318.  The determination of a party’s entitlement to equitable relief must “be decided after a hearing on the merits where interested parties have an opportunity to be heard.”  Id.  A plurality of the court opined that injunctive relief in this case would be appropriate if the facts Gamble alleged, that the defect in his application was merely a clerical error that party officials should have noticed and called to his attention, were true.  Id.  The court then explained that Triantaphyllis had a right to contest those facts at a hearing.  Id. 

            Accordingly, on February 20, 2002, Gamble filed a new lawsuit and requested an immediate temporary injunction hearing and an expedited hearing on his request for a permanent injunction.  See Tex. Elec. Code Ann. § 273.081 (“A person who is being harmed or is in danger of being harmed by a violation of threatened violation of this code is entitled to appropriate injunctive relief to prevent the violation from continuing or occurring.”)  An evidentiary hearing was held on February 26, 2002.  At the conclusion of the hearing, the trial court granted the temporary injunction and set the case for trial on April 15, 2002.  Triantaphyllis filed his notice of appeal on March 1, 2002, and the interlocutory appeal was assigned to this Court on March 5, 2002.  Triantaphyllis also sought a stay and expedited consideration.  The Court denied the stay but granted expedited consideration, hearing oral argument on March 26, 2002.  See Triantaphyllis v. Gamble, No. 14-02-00190-CV, 2002 WL 1042076 (Tex. App.—Houston [14th Dist.] May 23, 2002, pet. filed) (not designated for publication). 

            On April 15, 2002, the trial court held a hearing on Gamble’s permanent injunction request.  The parties entered into a Rule 11 agreement stipulating that the permanent injunction request would be tried on the basis of the record that was adduced at the temporary injunction hearing.[1]  Based upon this record and additional argument of counsel, the trial court granted a permanent injunction allowing Gamble’s name to be placed on the general election ballot.  The trial court filed findings of fact and conclusions of law in support of the injunction.  Triantaphyllis then appealed from the permanent injunction.  He requested, and this Court agreed, that the record from the temporary injunction appeal would be transferred to the appeal of the permanent injunction.  This Court then dismissed the appeal from the temporary injunction as moot.  Triantaphyllis v. Gamble, 2002 WL 1042076.

Standard of Review in an Appeal of a Permanent Injunction

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