Untitled Texas Attorney General Opinion

THEATTORNEY GENERAL OF TEXAS September 23, 1960 Honorable Zollie Steakley Opinion No. WW-943 Secretary of State Austin, Texas Re: Based on the certificate on behalf of the Prohibition Party filed in the Secretary of State's office, whether It is the duty of the Secre- tary of State to certify for the general election ballot the candidates of said party for President and Vice-President. Dear Mr. Steakley: You have asked our advice on whether, upon the basis of the following certificate which has been filed in your office, it Is your duty to certify for the general election ballot the candi- dates for President and Vice-President listed in the certificate: "TO THE HONORABLE SECRETARY OF STATE OF TEXAS Austin, Texas "THIS IS TO CERTIFY that at a Convention of the Prohibition Party of Texas, official notice of which was published and mailed ten (10) days in advance of said Convention, which was held in the City of Houston, Texas on the 18th day of August 1960, the following persons were nominated as candidates of the aforementioned Prohibition Party as Presidential Electors. "We hereby request, In accordance with the laws of the state of Texas, that their names be filed as electors of the Prohibition Party, and WHEREAS the National Convention of the Prohibition Party, assembled at Winona Lake, Indiana, September l,2,3, 1960, nominated for President of the United States, Rutherford L. Decker of Missouri, and for Vice President of the United States, E. Harold Munn Honorable gollie Steakley, page 2 (WW-943) of Michigan, we request that their names also be placed on the ballot. "The persons nominated as Presidential Electors by the Texas State Convention are as follows: Bhere are then listed the names and addresses of 24 indi- viduals, all of whom are shown to be residents of Houston, TexasJ /is/ W. 0. HICKS W. 0. Hicks -- Chairman of Convention S/ LLOYD WYSONG Lloyd Wysong -- Secretary of Convention / / W. 0 HICKS W. 0. iicks --'Chairman of State Prohibition Committee /s/ LLOYD WYSONG Lloyd Wysong -- Secretary of State Prohibition Committee" The authority of the Secretary of State to raise and pass on questions of the legality of nominations which have been certified to him is confined to matters which appear on the face of the certificate itself or in official records. If a certifi- cate is regular on its face and there is nothing in the official records to impeach the validity of the nomination, it is his duty to act upon the nomination as one having been lawfully made, and any question of illegality depending upon facts dehors the record must be left to the courts to decide. Weatherly v. Fulgham, 153 Tex. 481,271 S.W.2d 938 (1954); Ferris v. Carlson, 314 S.W.2d 577 (Tex.Sup. 1958); Baker v. Porter, 333 S.W.2d 594 (Tex.Sup. 1960); Att'y Gen. Op. V-1529 (1952). Under the provisions of Articles 11.02-11.03 and Article 6.05 of the Election Code, the names of party nominees for President and Vice-President are printed on the general elec- tion ballot and a vote for the party nominees is counted as a vote for the electors of the same party. There is no statute regulating the time and manner for selecting party nominees for President and Vice-President, but by custom this is done at national conventions composed of delegates from the participating states. Article 11.04 of the Election Code provides for the Honorable Zollie Steakley, Page 3 (WW-943) certification of the nominees to the Secretary of State as fol- lows: "The names of the candidates for President and Vice-President, respectively, of the Political Party as defined in the Law, shall, at least 35 days prior to the election, be certified to the Secretary of State by the chairman and secretary of the State Committee of said party." On its face, the certificate which has been filed in your office complies with this statute and with Article 13.39 of the Election Code, which provides that every certificate of nomination made by the president of the State convention, or by the chairman of any executive committee, must state when, where, by whom, and how the nomination was made. There is no express statutory provision for certification of the party's candidates for presidential electors. In the absence of an express statute, we are of the opinion that certification in accordance with Articles 11.04 and 13.39, as was done in this instance, would clearly be sufficient. The certificate recites that the presidential elector candidates were nominated at a state convention held on August 18, 1960.There is no statute prescribing how or when presiden- tial elector candidates are to be selected, and "a party is free to follow any method which it may choose in keeping with party usages and customs, so long as it does not purs:lea method ex- pressly prohibited by law." Stanford v. Butler, 142 '?ex.692, 181 S.W.2d 269 (1944); Seay v. Latham, 143 Tex. I, 182 S.W..2d 251 (1944). These cases recognize tEaatthe candidates mav be selected at state conventions; which is the customary method for their selection. If the Prohibition Party could lawfully hoid a state convention on August 1.8, it cculd nominate its presidential elector candidates at that convention. Article 13.35 of the Election Code fixes the third Tuesday in September as the date on which parties that cast 200,000 votes or more for Qovemor at the last preceding general election shall hold th? state convention for canvassing the pri- mary election returns for state offices and for announcing a party platform and transacting other business as set out in Articles 13.37 and 13.38. Article 13.45 fixes the Monday pre- ceding the last Tuesday in May as the date on which a state con- vention for nominating candidates for state cffices and for United States Senator shall be held by parties whose nominee for Governor In the last preceding general election received as many as 10,000 votes and less than 200,000 votes. Artinle 13.58 Honorable Zollie Steakley, page 4 (WW-943) fixes the second Tuesday following the second primary election as the date on which any political party desiring to elect dele- gates to a national convention shall hold a state convention for that purpose. These are the only statutes fixing the dates for state conventions. The Prohibition Party did not have a nominee for Governor at the general election in 1958. It therefore does not come within the provisions of any statute prescribin the time for holding a state convention other than Article 13.58 , relating to the conven- tion for electing delegates to a national convention. =5% Latham, supra, held that a party is not required to select presidential elector candidates at this convention. The courts have held that matters not regulated by stat- ute are within the control of the arty itself. Wall v. Currie, 147 Tex. 127, 213 S.W.2d 816 (19487; Morris v. Miw7 (Tex.Civ.App. 1920). Since there Is no statute which would pro- hibit the Prohibition Party from holding a state convention for nomination of presidential elector candidates on a date not desig- nated by statute for the conventions of parties within existing statutory regulations, we are of the opinion that the party could lawfully hold the convention at some other time. It is our opinion that the certificate you have received does not on its face show any invalidity in the nomination pro- cedures followed by the Prohibition Party. The next inquiry is whether an examination of official records reveals any defect in these procedures which would invalidate the nomination. You have informed us that the State Committee of the Prohibition Party did not certify to your offise a decision as to whether the party would nominate state, district and county officers by convention or primary elections, as provided in Article 13.46 of the Election Code, nor did you receive any notice as to the hour and place at which a convention for selecting delegates to a national convention was to be held, as provided in Article 13.58. You have asked whether the failure to comply with these statutory provisions would affect your duty to certify the party's nominees for President and Vice-President. Article 13.46 reads as follows: "The State Committee of political part.ieswhich are not required by law to make nominations by a primary election shall meet at some place in the State to be designated by the chairman thereof on the second Monday in February and shall decide, and by resolution declare, w'hetherthey will nominate Honorable Zollie Steakley, page 5 (WW-943) State, district and county officers by convention or primary elections, and shall certify their decision to the Secretary of State." Presidential electors are not "state officers" within the meaning of this statute. Stanford v. Butler, supra. Even though the State Committee had decided to hold primaries for nominating state, district and county officers and had certified this decision to the Secretary of State, the party would still have been free to select its presidential elector candidates by convention. Since ncmination of presidential elector candidates is not controlled by this statute, it follows that the failure to give notice to your office would not affect the validity of these nominations. It therefore becomes unnecessary to consider whether the record of certificates received in your office under this statute is within the class of official records which you could examine in the present instance, or whether failure to file the notice under Article 13.46 wculd vitiate nominations for offic.es which do come within its provisions. Article 13.58 provides that the State Executive Com- mittee shall notify the Secretary of State as to the kour and place at which the state convention fs elect delegates to a national convention will be held. As already pointed out, the presidential elector candidates for the Prohibition Party were not nominated at a convention held under the provisions of this statute. There is no ststute requiring that the Sesretary of State be notified of other state -onventions heli by t'nisparty, and the failure to file a notice would be immateriai~to the validity of ac~tiontaken by the convention held on August 18. Whether the PrShibit.ion Party is .adv.lyrorganized political party entitled to have its nominees for President and Vice-President,placfsdon the ballot, ,lwhether I.tscomina.tingcon- ventions were legally oonstit.uted,an'?w+ther the party has failed to comply with any statutory requirements going to the validity of the nominations, are matt,erswh2ch ycu are not authorized to determine. These are q-esfions of mixed law and fact, and their determination would :?ependon an asc.ertainment of facts dehors the certiX"2:at.e s,ndcff'Lc'?al. re:ords Since t'he certificate complies with statutory reqairements and"n0 illegality in the making of the nominations is n'k.?wn by the .certificateor other official records3 we are of th? cpin!,onthat it is your duty to certify the pa=ty's candidates i:orp?eai$ent and.Vi:-e- President to the county clerks. Honorable Zollie Steakley, page 6 (WW-943) SUMMARY Where a certificate of the nomination of candi- dates by a political party for President and Vice- President and for presidential electors has been filed with the Secretary of State in compliance with statutory requirements and no illegality in the making of the nominations is shown by the certificate or other official records, it Is the duty of the Secretary of State to certify the candidates for President and Vice- President to the county clerks for placement on the general election ballot. A political party which did not cast as many as 10,000 votes for Qovernor In the preceding general election may nominate presidential elector candidates at a state convention held on some date other than a date fixed by statute for the conventions of parties within existing statutory regulations. The party is not required to notify the Secretary of State of the time and place at which the convention will be held. Presidential electors are not state officers within the scope of Article 13.46 of the Election Code, and failure to notify the Secretary of State whether nomi- nations for state, district and county offices was to be made by conventions or by primary elections would not affect the validity of the party's nominations for presidential electors. Yours very truly, WILL WIISON Attorney General of Texas MKW:ljb APPROVED: OPINION COMMITTEE W. V. Geppert, Chairman Houghton Brownlee, Jr. REVIEWED FOR THE ATTORNEY GENERAL Gordon C. Cass BY: Leonard Passmore J. C. Davis, Jr. Tom I. McFarli.ng