Maxfield v. Herbert
2012 UT 44
Utah2012Background
- Maxfield challenged the 2010 Utah gubernatorial election under Utah Code title 20A, chapter 4, contest provisions.
- Maxfield and running mate Anderson finished third in the election; prior petitions alleged campaign-finance violations by Herbert and Corroon.
- Maxfield sought extraordinary relief from this court and later pursued a district-court election contest under §20A-4-402(1)(b).
- The district court dismissed the contest as misapplied to campaign-finance violations and ruled against eligibility-based challenges.
- Maxfield timely appealed, challenging both the procedural handling and the substantive grounds for contest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural compliance with election-contest rules | Maxfield argues rules should yield to statutory procedures. | Herbert/Corroon contend motions and timing complied with statute and rules. | Rules apply; 12(b)(6) motions proper; hearing timing discretionary. |
| Campaign-finance violations as grounds under §20A-4-402(1)(b) | Maxfield contends violations render Herbert ineligible for office. | Herbert contends eligibility is constitutional; finance violations are outside §20A-4-402(1)(b) scope. | Not viable; ineligible refers to constitutional eligibility, not campaign-finance violations. |
| Election-contest grounds other than ineligibility | Maxfield invokes 'offense against the elective franchise' or 'any other cause' grounds. | Corroon/Herbert argue grounds do not authorize inquiry into violations via §20A-4-402. | Grounds not applicable; violations belong to other statutory avenues. |
Key Cases Cited
- Archuleta v. St. Mark's Hosp., 2009 UT 36 (Utah Supreme Court, 2009) (standard of review for district-court decision on motions to dismiss)
- Clayton v. Ford Motor Co., 2009 UT App 154 (Utah Court of Appeals, 2009) (docket-management discretion in trial courts)
- Slisze v. Stanley-Bostitch, 1999 UT 20 (Utah Supreme Court, 1999) (trial court broad discretion in evidentiary relevance)
