Meade v. Williamson
293 Ga. 142
| Ga. | 2013Background
- Meade and Williamson were candidates in a Baker County Democratic primary run-off for Sheriff on Aug. 21, 2012; Meade, the incumbent, won by 39 votes amid a total of 1,353 ballots.
- Williamson contested the results in Superior Court, which held a bench trial and invalidated the election, ordering a new run-off.
- The trial court found irregularities in both voting and the election process that supposedly cast doubt on the result.
- This Court reviewed the evidence de novo, applying the standard that election returns are presumed valid and that the contestant must show sufficient irregularities to alter or cast doubt on the result.
- The Court reversed, concluding the evidence did not establish a sufficient number of irregular ballots or systemic irregularities to cast doubt on the results.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether sufficient irregular or illegal ballots existed to change the result | Williamson contends irregular ballots could alter outcome | Meade contends insufficient irregular ballots to change result | No; insufficient specific irregular ballots to change the result |
| Whether unqualified individuals who assisted voters invalidated ballots | Williamson asserts assistants were unqualified, invalidating ballots | Meade argues burden incorrectly placed; assistants not proven unqualified | No; ballots not invalidated; burden on Williamson to prove qualification failed |
| Whether altered absentee ballots could cast doubt on the results | Williamson argues alterations raise doubt on outcome | Meade argues alteration evidence insufficient to cast doubt | No; even if altered, did not demonstrate sufficient impact to change result |
| Whether systemic irregularities in the election process cast doubt on the results | Williamson relies on systemic misconduct | Meade argues irregularities were speculative and not systemic | No; evidence of systemic irregularities was insufficient to cast doubt on the results |
Key Cases Cited
- McCranie v. Mullis, 267 Ga. 416 (Ga. 1996) (sufficient irregular ballots to change election results)
- Stiles v. Earnest, 252 Ga. 260 (Ga. 1984) (systemic irregularities may render election results doubtful)
- Middleton v. Smith, 273 Ga. 202 (Ga. 2000) (cannot rely on speculation; need specific defective ballots)
- Hunt v. Crawford, 270 Ga. 7 (Ga. 1998) (election integrity concerns; avoid disenfranchisement from officer error)
- Jones v. Jessup, 279 Ga. 531 (Ga. 2005) (substantial compliance; not all information missing invalidates ballot)