Leslie v. Bendl

BUTTLER, P. J.,

dissenting.

Plaintiff, as the successful defendant in an action brought by Friends of Tax Limitation, a political committee, under the Corrupt Practices Act, ORS 260.532(4), was awarded attorney fees against the committee pursuant to ORS 260.532(5). Rather than levy execution on that judgment,1 she *524filed this “action on a debt” against defendants, who are directors or officers of the committee, contending that they are jointly and severally liable for the debt of the committee as an unincorporated association. Because I disagree with the majority’s conclusion that plaintiff may maintain this action, I dissent.

ORS 260.532 prohibits the knowing or reckless publication of any false statement relating to a candidate, a political committee or an election measure. In the original statute, the prohibition was enforced by criminal sanctions. In 1973, the statute was amended to create a civil action for compensatory damages, Or Laws 1973, ch 744, § 36; the action may be brought only by a candidate or a political committee. However, a political committee may not be sued as a defendant in such an action. ORS 260.532(6). The statute defines “a political committee” as “a combination of two or more individuals, or a person other than an individual, the primary or incidental purpose of which is to support or oppose any candidate, measure or political party, and which has received a contribution or made an expenditure for that purpose.” ORS 260.005(11). It is clear that only a candidate or a political committee, as defined, is authorized to bring an action for violation of the statute. It is also clear that the remedies granted by the statute are the exclusive remedies for its violation. ORS 260.532(9).

Before ORS chapter 260 was enacted, no unincorporated association had the capacity to bring an action in its own name; it was not a legal entity and no action could be brought by or against it. Fennell v. Hauser, 145 Or 351, 27 P2d 685, 28 P2d 245 (1934), overruled on other grounds, Beglau v. Albertus, 272 Or 170, 536 P2d 1251 (1975). The Corrupt Practices Act changed the common law rule with respect to an action for damages under its provisions, but only to the extent that it granted standing to political committees to sue; in fact, only a candidate or a political committee may sue. A political committee may not be sued as a defendant in such an action, although a judgment may be entered against it for attorney fees if it does not prevail in an action that it brings. Accordingly, it appears to me that plaintiff in this action, having obtained a judgment against the committee for attorney fees in the Corrupt Practices Act action, is limited to recovery against the political committee, the only non-prevailing party in that action and the only one authorized to maintain it.

*525I do not believe that the later enactment of ORCP changes the result. It is true that ORCP 26B permits an unincorporated association to sue or be sued in its name and that ORCP 67E provides that a judgment in an action against an unincorporated association shall bind the joint property of all of the associates. However, the Corrupt Practices Act specifically provides that a political committee may not be sued as a defendant, contrary to ORCP 26B. Furthermore, given the limitation in ORS 260.532(6) that a recovery made by a political committee in an action under that section shall be distributed pro rata among the persons making contributions to the committee, it seems clear to me that the legislature did not have in mind the common law rules applicable to unincorporated associations when it enacted the Corrupt Practices Act, or amended it in 1973. Plaintiff does not claim that she is entitled to a pro rata recovery from each person making contributions to the committee. Neither does she claim that the committee transferred assets to its members in order to defeat her judgment.

The Corrupt Practices Act stands by itself and provides the exclusive remedies for aggrieved persons. Neither ORCP nor common law rules should be applied to change the exclusive remedy provided by the legislature. Plaintiffs remedy is against the committee. I would reverse.

Accordingly, I respectfully dissent.

It is understandable that plaintiff would prefer to avoid the risk of a wrongful execution by bringing this separate action.