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Maxfield v. Herbert
2012 UT 44
Utah
2012
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Background

  • 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)
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Case Details

Case Name: Maxfield v. Herbert
Court Name: Utah Supreme Court
Date Published: Jul 20, 2012
Citation: 2012 UT 44
Docket Number: No. 20110425
Court Abbreviation: Utah