Untitled Texas Attorney General Opinion

Honorable W. C. McClaln District Attorney Opinion No. Q-2298 Conroe, Texas Re: Interpretation of law regulating absentee Dear Sir: voting, Article 2956j Revised Civil Statutes, This is in reply to your letter of April 26, 1940, requesting the opinion of this Department interpreting Article 2956, Vernon’s Annotated Civil Statutes, dealing with absentee voting. Your request was prompted by an inquiry from the County Clerk of Montgomery County and the following questioni are asked: “Question 11 Is it legal to send out a ballot or t6 permit a Notary Public to take out a ballot and application and have the elector slgn the application and vote the ballot not In the presence of the County Clerk, vhereas the law provides that the ballot shall be returned by mail? “Question 2: In Section 2 a provision is made that if the. application is on account of sickness or. physical disability a certificate of a licensed physi- clan.‘ shall accompany it. It seems to me it would be impossible for a physSclan to determine 35 or 20 days ahead In many cases whether or not an elector would be able to attend the polls, and I will ask you, where sickness Is the basis of the application, if under that section an elector would not have to make his ap- plication and vote on the day of election, there.being no time specified. “Question 3: Does not subdivision 3 have applica- tion only to electors who are absent from the county of their residence?” Artlclti 2956 reads, in part, as follows: “Subdivision 1. Any qualified, elector of thls State who 1s absent from the county of hls residence, or because of sickness or physical dlsablllty can not appear at the poll place in the election precinct Honorable W. C. McClaln, Page 2 of his residence, on the day of holding any general, special, or primary election, may, nevertheless, cause his vote to be cast at such an election in the precinct of his residence by compliance with one or other of the methods hereinafter provided for absentee voting. “Subdivision 2. Such elector shall make application for an official ballot to the county clerk in writing signed by the elector, or by a witness at the direction of said elector in case of latter’s inability to make such written application because of physical disability. Such application shall be accpmpanied by the poll tax receipt or exemption certificate of the elector, or, in lieu thereof, his affidavit in writing that same has been lost or mislaid. If the ground of application can be sickness or physical disability by reason of which the elector cannot appear at the polling place on election day, a certificate of a duly licensed physician certifying as to such sickness or physical dlsabllltg shall accompany the application. , “Subdivision 3. At any time not more than twenty (20) days, nor less than three (3) days, prior to the date of such an election, such elector making his personal appear- ance before the county clerk of the county of his resi- dence at his office and delivering to such clerk his application aforesaid, shall be entitled to receive,from said clerk one official ballot which has been prepared in accordance with law for use in such election, which ballot is t-hen and there, In the office of said clerk of said county, and In the presence of said clerk and Of no other person, except the vltness who is authorized to assist elector in certain cases as hereafter provided, to bejmarked by the elector, or by sa,ld witness in case of. physical dlsabilltg of elector, so as to conceal the marklncr and same shall. In the presence of the clerk, be dep&ted ln[a ballot envelope furnished by said cierk, vhlch envelope shall bear upon the face thereof the name, official title and post office address of such county clerk, and upon the other side a printed affidavit in sub- stantially the following form, to be filled out and signed by the elector; provided, however, that in case of the physical disability of elector preventing him from fllllng out and signing such affidavit, then the witness who assisted the elector in marking his ballot shall fill out and slgn affidavit for and in behalf of elector and shall also sign his, wltness”.nsme as prescribed In the following form: Honorable W. C. McClain, Page 3 State of C,ounty of T -, do solemnly svear that I am a Resl- dent ‘0; Precinct No. in -~~ I l;ounr;y, ana am lawfully entitled to vote at’the election to be held in said precinct on the day of that~ I am prevented from appearing at the polling ilace in said Precinct on the da,te of such election ness). (physical dlsabllltg), (or because County) (elector to signify one of foregoing reasons I that the eiclosed ballot expresses my wishes, independent of any d%ctatlon or undue persuasion of any person; that I did not use any memorandum or device to aid me in the marking of said ballot. Signature of elector By: Name of :wltness who assisted elector in event of physical dlsablllty. “Subdivision 4. At any time’ not more than twenty (20) days, nor- less than three (3) days .prlor to the date of such an election, such.elector who makes written appllcatlon.for a ballot as provided for in Subdivision 2 hereof, shall be entitled to have his ballot cast at such an election on com- pliance with the following proVisIons:. “The ,appllcatlon, including fifteen cents (15#) to cover postage, shall be mailed to the County Clerk of the elector’s resi’dence whose duty it &all be forthwith %o mail to such :eledttir a’blank .offlcitil ballot and ballot envelope as prqvlded in Subdivision 3, which ballot shall be marked by elector, or by witness at the direction of said elector in case of the ‘latter~‘s lnabllltg ~to mark suoh ballot because of physical disability, in the presence of a Notary Public or other persons qualified under the law to take acknowledgements, and in the presence of no other person except said witness and/or such officer, and in such manner that~s~ueh officer cannot know how the ballot is marked, and such ballot shall then in the presence of such officer be folded by the elector or by said witness in case of physical disability of said elector, deposited in said envelope, the envelope sec~urely sealed, the endorsement filled out, signed and sworn to by the elector, or in case of physical dlstibillty, then bjr the said witness for and In behalf of ~said elector,. and “ce&ifled by ‘such officer and then ‘mailed by ‘said ofHceP, postage, prepaid, to the County Clerk.’ (Underscoring ours) Honorable W. C. McClaln, Page 4 You may note from reading this article that two methods are provided for voters who, because of absence from the county of their residenoe or because of sickness or physl- cal disability, cannot appear at the poll place on the day of election. The first method is by written application signed by the elector or a vltness at his direction, accompanied by a poll tax receipt or exemption certificate, or, in lieu thereof, his affidavit in writing that the same has been lost or mislaid. If the elector claims the privilege of voting by absentee ballot on the ground of sickness or physical disability a certificate of a duly licensed physician certifying as to such sickness or physical disability must accompany the application. The appllca- tlon, together with fifteen cents to cover postage, must be mailed to the County Clerk. Upon compliance with these requi- sites, the elector will be entitled to have his ballot cast at any time not more than twenty norlless than three days prior to the date of the election, and it is the duty of the county clerk within this time, forthwith to mall the elector a ballot vhich will be re-mailed to the county clerk by the elector. For further particulars, ve refer you to Subdivisions 2 and 4 of Article 2956. The se~cond method is provided in Subdivision 3 of Article 2954, namely, by the personal appearance of the elector before .the county clerk at any time not more than twenty or less than three days prior to the date of the election. For further particulars, refer to Subdivision 3 of Article 2956. In ansver to your first question, therefore, we must advise that Article 2956 regulating absentee voting does not provide as a method the suggested procedure by vhlch a notary public will take out blank application and ballot, and have the elector sign the application and vote a ballot which will then be returned to the county clerk by the notary. In this connection we call. your attention to the case of Sartwelle v. Dunn (C.C.A. 1938) 120 S.W. (26) 130. There almost the identical procedure was followed. It appeared that ballots were taken from the county clerk’s office by a notary and a candidate who vere soliciting votes, to the residences of certain electors without request from them. Each expressed a willingness to vote, however, and the ballots vere then and there marked by the notary at their direction. The court said: I,. . . We recognize the general rule that the will of the electors should be respected when expressed at the ballot, but we are of the opinion that an elector exercising the right of suffrage through the medium provided by the absentee voting statute should at least substantially comply Vlth the requirements of such statute. Honorable W. C. McClaln, Page 5 To hold that ballots such as these were cast in substantial compliance with the statute vould Ignore the plain and ex- press provisions thereof and open the avenues of fraud, deception and intimidation through absentee voting In the conduct of electioni. "We are of the opinion that the trial court erred In refusing to sustain the challenge to these votes." We wish to point out that we are not passing upon the validity of absentee votes cast In a manner other than that pro- vided by Article 2956. We confine our opinion to the duties of th$ county clerk with respect to the casting of absentee ballots. It is his duty to see that there is a substantial compliance with the terms of the statute; and Insofar as his duties are concerned the suggested procedure does not so conform. In answer to your second question, the time for absentee voting is s eclfled as 'not more than twenty(20) days, nor less than three P3) days' prior to the date of the election. This 'Urn6 is set forth in subdivision 4 for those absentee voters deslr- $ng to follov the procedure provided in subdivisions 2 and 4 of Article 2956. The last day application may be made and ballbt cast by one unable to participate because of physical disability or sickness Is the third day prior to the date of the election. If the election Is to be held on a Saturday, Tuesday midnight is the deadline. Your third question 1s whether or not Subdivision 3 relates only to electors absent from the county of their resi- dence. If you will refer to Article 2956, quoted above, you vi11 note that we have underscored those portions of subdivision3 wherein specific attention has been given by the Legislature to cases of physical disability of the elector or illness. You. are, therefore, respectfully advised that not only electors who.will be absent from the .county of their residence on the day of holding the'electlon, dut also those unable to atteng beCause of sickness or physlcal~dlsablllty may avail themselves of the method provided in subdivision 3 of Article 2956 for casting absentee ballots. Yours very truly APPROVEDJUN 7, 1940 ATTORNEY GENERALOF TEXAS S/ GROVERSELLERS By ,S/.WALTERR. KOCH, FIRST ASSISTANTATTORNM Assistant GENERAL By S/ JAMESD. SMULLEN JDS:BBB Am! APPROVED Opinion Committee, by BWBChairman