Middleton v. Smith

Benham, Chief Justice,

dissenting.

The majority opinion in this case shows the danger of focusing so completely on individual trees that the forest cannot be seen. Because the majority views too narrowly the scope of election irregularities which can justify setting aside an election, and gives too little weight to the trial court’s findings of misconduct by an official charged with protecting the integrity of the polling place, I must dissent to the reversal of the trial court’s order requiring a new election.

The majority’s decision is based on the notion that one seeking to overturn election results must be able to point to specific voters whose ballots should be disallowed, basing that rule on cases in which the facts were such that specific voters or votes were objectively identifiable. McCranie v. Mullis, 267 Ga. 416 (478 SE2d 377) (1996); Taggart v. Phillips, 242 Ga. 454 (249 SE2d 245) (1978). To further that restrictive view of what may justify the overturning of an election, the majority opinion dismisses the holding in Stiles v. Earnest, 252 Ga. 260 (312 SE2d 337) (1984), with the suggestion that the conduct here is not so egregious. On the contrary, Stiles is the case most on point to the problem presented by this case - a systematic debasement of the election process by those with an interest in it - and is itself precedent for the proposition which should govern this case: egregious and persistent violations of the election laws can in themselves constitute an irregularity sufficient to place the entire election result in doubt. See also Johnson v. Rheney, 245 Ga. 316 (264 *205SE2d 872) (1980) (the plaintiffs burden in an election contest is “to affirmatively show that the facially valid results were invalid due to an irregularity sufficient to place the entire election result in doubt”).

The fatal flaw of the majority opinion’s excessively narrow focus only on specific ballots is that it ignores situations such as the present case in which the debasement of our most honored democratic institution has been effectively accomplished. Where it appears, as the trial court found here, that one official has utilized the taxpayer-provided resources of his office to advance the private interest of other politicians whose offices have influence over his, has blatantly ignored and violated the law he has sworn to uphold, and has done so with such efficiency as to render it virtually impossible to identify defective ballots or intimidated voters individually, the approach taken by the majority opinion requires the judiciary to put on blinders and declare itself impotent to protect the rights of the citizenry.

By reciting in general terms the trial court’s findings, the majority opinion gives lip service to the principle that a trial court’s findings are upheld unless shown to be clearly erroneous (Streeter v. Paschal, 267 Ga. 207 (1) (476 SE2d 759) (1996)), but then proceeds immediately to ignore those findings and their import. Those findings paint a picture of organized and persistent violations of the election laws. The sheriff, a sworn official of the county, was found to have used county employees working in a county facility to process and mail 1,200 items of partisan political material on stationery on which the sheriffs name and official title appeared.1 The trial court also found that the sheriff used his influence over persons involved in the criminal justice system either to influence a vote or to obtain labor in advancing partisan political campaigns. Though charged with upholding the election laws, including those which limit how close to the polling place campaign activities may be pursued, the sheriff established an open and obvious presence within that limit at which campaign activities were pursued, at the same time that his office enforced the distance restriction against a representative of a candidate the sheriff did not support. The unmistakable effect of the sheriff’s illegal campaign activities and abuse of power is to constitute, as the trial court found, “a grave threat to the integrity of the electoral process.” The threat was not to the validity of a clearly determined number of votes, but to the validity of every vote in the precinct where the sheriff set up a tent within 150 feet of the polling place, openly defying the law in order to garner votes for the candi*206dates he supported. Yet the majority opinion stands for the proposition that regardless of flagrant abuses of authority, regardless of the trial court’s specific finding that the sheriff’s testimony was not credible, regardless of the trial court’s finding that witnesses were intimidated, the results of the election must stand for want of sufficient specificity and detail in determining how the election was influenced.

Decided November 29, 2000 Reconsideration denied December 1, 2000. Jones, Osteen, Jones & Arnold, Billy N. Jones, Richard Phillips, Robert F. Pirkle, R. Joseph Hammill, James C. Nobles, Jr., for Middleton et al. John D. Harvey, L. Catharine Cox, for Smith and Harold.

This dissent must echo the lament in the dissent in Walls v. Garrett, 247 Ga. 640 (277 SE2d 903) (1981): “The trial court found the election system in [the county] in disarray. This decision approves that ‘system.’ ” Because I believe the trial court was correct in holding that the “system” in effect on the date of the election in issue here was so irregular as to place in doubt the validity of every vote cast in the first precinct, and that this Court’s decision in this case fosters the compromise of the election laws which clearly characterized the balloting here, I must dissent to the reversal of the trial court’s judgment.

I am authorized to state that Justice Hunstein joins this dissent.

Although not included in the trial court’s findings, it was uncontested at the hearing that the sheriff also prepared 38 applications for absentee ballots for the Democratic primary, filling in all the necessary information save the elector’s signature.