Price v. Independent Party of CT--State Central
SC19769
| Conn. | Nov 1, 2016Background
- Two rival factions of Connecticut's Independent Party (Waterbury "Independent Party of Connecticut" and Danbury "Independent Party of CT—State Central") held separate August 2016 caucuses and each certified a different U.S. Senate nominee (Price and Carter).
- Secretary of the State notified both factions that neither nominee would appear on the Independent Party ballot line unless one withdrew; competing litigation ensued in Superior Court and then in the Supreme Court.
- Plaintiffs (Price and Telesca) sued in the Connecticut Supreme Court under Gen. Stat. § 9-323, alleging caucus officials of the State Central faction violated party nomination statutes (e.g., improper presiding officer, unverified attendees, cross‑enrollment issues) and sought declaratory, injunctive relief and mandamus ordering the secretary to place Price on the ballot.
- Defendants moved to dismiss arguing § 9-323 does not reach caucus officials because a caucus is not an "election" and caucus administrators are not "election officials;" Secretary also invoked laches and lack of any ruling by the secretary.
- The Supreme Court held caucus administrators for minor party nominations are not "election officials" under § 9-323 and, alternatively, that plaintiffs’ delay in pressing claims prejudiced the state’s election preparations (laches), so relief was denied and dismissal granted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 9-323 covers rulings by minor‑party caucus administrators (i.e., are they "election officials") | Caucus officials made rulings (failed to verify enrollment, allowed non‑members to preside) that aggrieved plaintiffs under § 9-323 | Statute’s term "election official" is limited to officials tied to statutory election/primary procedures; caucuses are party‑run and not covered | Held: caucus administrators are not "election officials" for § 9-323; plaintiffs not aggrieved under that statute |
| Whether a caucus is an "election" under statutory definitions | Caucus voting to nominate is functionally an electoral act and should be reviewable | A statutory "election" is an electors' meeting to choose public officials; caucuses merely nominate and are governed by party rules, not the same statutory scheme | Held: Court rejects treating minor party caucus as an "election" for § 9-323 purposes (supports limiting reach of statute) |
| Whether plaintiffs adequately identified specific statutory rulings/errors | Plaintiffs asserted violations of §§ 9-372 and 9-452 but did not identify precise statutory provisions or specific rulings | Defendants emphasized plaintiffs’ failure to specify the particular statutory errors and that secretary made no erroneous ruling | Held: Court noted plaintiffs’ allegations lacked necessary specificity but resolved case on election‑official issue instead of deciding merits |
| Whether the doctrine of laches bars pre‑election equitable relief | Plaintiffs filed suit close to ballot printing despite knowing factional dispute; urged urgency due to secretary's notice | Defendants (secretary) argued plaintiffs delayed, prejudicing election preparations (absentee/military ballots issued, printing/programming imminent) | Held: Even if § 9-323 applied, laches would bar injunctive relief because plaintiffs’ delay was inexcusable and prejudicial to election administration |
Key Cases Cited
- Caruso v. Bridgeport, 285 Conn. 618 (construing "ruling of an election official" and holding statutory procedure failures may constitute a ruling)
- Bortner v. Woodbridge, 250 Conn. 241 (definition of "ruling of an election official" and limits on judicial intrusion into elections)
- Wrotnowski v. Bysiewicz, 289 Conn. 522 (application of the "ruling of any election official" standard; standing and scope under § 9-323 context)
- Scheyd v. Bezrucik, 205 Conn. 495 (discussing judicial review of election official rulings in related statutory contexts)
- Butts v. Bysiewicz, 298 Conn. 665 (recognizing secretary of the state as an election official and addressing limits of judicial intervention)