Wheatley v. Secretary of the Commonwealth

792 N.E.2d 645, 439 Mass. 849, 2003 Mass. LEXIS 575
CourtMassachusetts Supreme Judicial Court
DecidedAugust 5, 2003
StatusPublished
Cited by3 cases

This text of 792 N.E.2d 645 (Wheatley v. Secretary of the Commonwealth) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wheatley v. Secretary of the Commonwealth, 792 N.E.2d 645, 439 Mass. 849, 2003 Mass. LEXIS 575 (Mass. 2003).

Opinion

Cowin, J.

Acting pursuant to its powers under Part II, c. 1, § 3, art. 10, of the Massachusetts Constitution, to “be the judge of the returns, elections, and qualifications of its own members,” the House of Representatives determined that Matthew C. [850]*850Patrick was duly elected the representative from the Third Barn-stable Representative District in the November, 2002, election. We are asked to determine whether a judge’s order that a new election be held, an order that entered after the House had taken up the matter, may stand. We decide that it may not, and we therefore vacate the judgment.

1. Facts. The facts are not disputed. An election for State representative to the General Court from the Third Barnstable Representative District was held on November 5, 2002. Patrick, the incumbent, appeared to be the winner, by twelve votes. Petitions for recount were timely filed on behalf of Larry F. Wheatley, the challenger, and on behalf of Patrick. On November 20, 2002, the Acting Governor and the Executive Council, pursuant to G. L. c. 54, § 115,2 examined the records of votes cast and the Secretary of the Commonwealth, acting pursuant to G. L. c. 54, § 135,3 issued a district-wide recount order. This recount was held on November 23 and 25, 2002.4 Patrick’s lead increased to seventeen votes. The Secretary again transmitted the returns to the Acting Governor and Council for examination [851]*851pursuant to G. L. c. 54, § 115, and certification pursuant to G. L. c. 54, § 116.* **5 The Acting Governor issued Patrick a certificate of election on December 18, 2002.

Wheatley filed this action in the Superior Court the same day that the Acting Governor issued the certificate of election. In his complaint, Wheatley alleged irregularities in the November 5 election and asked the judge to set aside that election and order a new one. He also sought to enjoin the Secretary from transmitting to the sergeant-at-arms of the General Court the records of votes cast. See G. L. c. 3, § 1. A judge in the Superior Court (who acted conscientiously and expeditiously throughout) held an evidentiary hearing on December 27, 2002. He denied injunctive relief but, in a memorandum dated December 30, 2002, ordered a new election.

In his memorandum, the judge found three voting irregularities, which he believed cast doubt on the outcome of the election. First, thirteen voters in a Bourne precinct received ballots containing candidates for the wrong district, resulting in votes for representative being counted as blank. Second, one voting location ran out of ballots, causing a thirty-five minute delay during which some three dozen people left the voting area. Third, eight absentee ballots cast contained candidates for the wrong district, resulting in votes counted as blank. The judge concluded that these were statutory violations and, given the close vote, the judge concluded that they “could realistically have influenced the outcome of the election.” He therefore ordered that a new election be held at the earliest possible date but no sooner than sixty days from entry of judgment. Judgment (styled a declaratory judgment pursuant to G. L. c. 231 A) entered January 16, 2003.

On January 1, 2003, the House of Representatives assembled for the 2003-2004 session. Patrick presented the certificate of election issued to him by the Acting Governor. Performing his [852]*852duties under G. L. c. 54, § 117, and G. L. c. 3, § 1,6 the Secretary presented the results of the election to the House on the same day. The House referred the return of votes in the election to a special committee. That committee ordered that Patrick be seated as a holdover until the House made its determination as to the duly elected representative. See art. 64 of the Amendments to the Constitution of the Commonwealth, as amended by art. 82 (terms of representatives extend until successors are chosen and qualified).

The special committee held a hearing on January 13, 2003, at which the two candidates and their attorneys participated. In addition, the committee had in its possession the pleadings, exhibits, and transcripts of the Superior Court proceedings in this case. On March 18, 2003, the committee issued a majority report recommending that Patrick be seated and a minority report recommending (a) that the House allow the Superior Court order to stand or (b) that the House ask this court whether it has jurisdiction to decide the matter and, if it does, then (c) that the House order a new election. The House debated the matter on March 20, 2003, and voted to seat Patrick.6 7

The next day, the Secretary (making essentially the same arguments he makes to this court) moved for relief from judgment pursuant to Mass. R. Civ. P. 60 (b) (4), (b) (5), and (b) (6), [853]*853365 Mass. 828 (1974). The judge denied this motion on May 1, 2003. The Secretary appealed, and the parties stipulated to a stay of the order for a new election. We granted the Secretary’s application for direct appellate review.

2. Discussion. As the Secretary failed to appeal from the original January 16 judgment, the only question before us is whether rule 60 (b) entitles the Secretary to relief from the judge’s election order in the wake of the decision of the House to seat Patrick.8 General Laws c. 56, § 59, grants the Superior Court both the jurisdiction to enforce the various laws regulating the conduct of elections and the power to grant equitable relief to those injured by violations of those laws.9 Although § 59 was enacted in 1946, see St. 1946, c. 537, § 11, the judiciary’s power to provide a remedy for persons harmed by defects in election procedures was recognized as far back as the beginning of the Nineteenth Century. See Coffin v. Coffin, 4 Mass. 1, 35 (1808) (“an elector illegally deprived of his right of voting, may demand redress for this wrong against the selectmen by a suit at law”). A court’s power to remedy election irregularities, however, has a limitation: Part II, c. 1, § 3, art. 10, provides that “[t]he house of representatives shall be the judge of the returns, elections, and qualifications of its own members . . . .” This language is as old as the Constitution itself, having remained unchanged since that document was adopted by the people in June of 1780. Despite this long history, however, the parties differ significantly as to the meaning of art. 10. In the opinion of the Secretary, the article grants the House the final authority to decide who it will seat as a member. Wheatley, on the other hand, reads art. 10 to reserve for the House only the ability to count the returns of a valid election. He argues that [854]*854when a court, pursuant to § 59, declares an election to be invalid, the House may not act to seat a member.

Our precedent indicates that the Secretary’s position is the correct one. The House’s role as the sole arbiter of a petitioner’s claim to a seat as a representative is by now firmly settled as a matter of State constitutional law. See Opinion of the Justices, 375 Mass. 795, 815 (1978) (“The constitutional authority of each branch of the Legislature to judge the elections, returns, and qualifications of its members is exclusive, comprehensive, and final”); Greenwood v. Registrars of Voters of Fitchburg, 282 Mass.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Feehan v. Marcone
Supreme Court of Connecticut, 2019

Cite This Page — Counsel Stack

Bluebook (online)
792 N.E.2d 645, 439 Mass. 849, 2003 Mass. LEXIS 575, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wheatley-v-secretary-of-the-commonwealth-mass-2003.