Price v. Indep. Party of CT, 147 A.3d 1032

Background

Two factions of Connecticut's Independent Party (Waterbury-based Independent Party of Connecticut and Danbury-based Independent Party of CT‑State Central) held separate caucuses in August 2016 and certified competing U.S. Senate nominees: Price (Waterbury) and Carter (CT‑State Central).
The Secretary of the State notified both factions that neither nominee would appear on the Independent Party ballot line unless one withdrew.
Plaintiffs (Price and an elector) filed in the Supreme Court under Conn. Gen. Stat. § 9‑323 seeking to invalidate the CT‑State Central caucus and to compel placement of Price on the ballot, alleging caucus procedural and statutory violations (e.g., non‑party presiding officers, lack of verification of attendee affiliation).
Defendants moved to dismiss, arguing § 9‑323 requires a ruling by an "election official" in an "election," and caucus administrators are not election officials; the Secretary also invoked laches.
The Supreme Court held an expedited hearing, concluded it lacked jurisdiction under § 9‑323 because caucus administrators are not "election officials," and alternatively found the plaintiffs’ delay barred relief by laches; the injunction and mandamus requests were denied.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 9‑323 authorizes original jurisdiction over alleged errors by minor party caucus administrators	§ 9‑323 covers "rulings of any election official" and caucus administrators made binding procedural decisions affecting nominations	Caucus administrators are not "election officials" under § 9‑323 and the statute pertains to elections/primaries run under statutory election framework	Held: No jurisdiction under § 9‑323; caucus officials are not "election officials."
Whether a party caucus qualifies as an "election" under statutory definition	Caucus is the functional equivalent of an election for purposes of challenging rulings that affect ballot access	Statutory definition of "election" requires elector meetings choosing public officials by ballot; caucuses nominate candidates and are governed by party rules, not election statutes	Held: Caucuses are distinct from statutory "elections," supporting exclusion from § 9‑323.
Whether alleged caucus procedural breaches constitute "rulings of an election official"	Plaintiffs claimed statutory procedural violations (unauthorized presiding officer, failure to verify attendees) that implicitly interpret statutes	Defendants argued even if errors occurred, those were party procedures, not rulings by trained, sworn election officials contemplated by statute	Held: Court declined to decide merits of "ruling" point because caucus officials are not election officials under § 9‑323.
Whether plaintiffs’ delay bars equitable relief (laches)	Plaintiffs acted promptly after caucuses became known and after Secretary’s notice	Defendants/Secretary: plaintiffs waited too long given imminent ballot printing and absentee/overseas ballot issuance causing prejudice and large costs	Held: Even if jurisdiction existed, plaintiffs’ inexcusable delay and resulting prejudice to state election administration warranted dismissal on laches grounds.

Key Cases Cited

Caruso v. Bridgeport, 285 Conn. 618 (construing "rulings of an election official" where statute mandates procedures)
Bortner v. Woodbridge, 250 Conn. 241 (explaining when a ruling of an election official exists for ordering new elections)
Wrotnowski v. Bysiewicz, 289 Conn. 522 (applying prior analysis of "ruling of any election official" under § 9‑323 context)
Scheyd v. Bezrucik, 205 Conn. 495 (discussing "rulings of an election official" in statutory context)
Butts v. Bysiewicz, 298 Conn. 665 (recognizing judicial role in structuring elections and reviewing election‑related claims)
In re Election for Second Congressional District, 231 Conn. 602 (treating moderators, ballot callers, talliers as election officials)
Cummings v. Tripp, 204 Conn. 67 (doctrine of laches elements and burden on party asserting it)