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RIGBY Et Al. v. BOATRIGHT Et Al.
330 Ga. App. 181
| Ga. Ct. App. | 2014
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Background

  • Satilla disqualified Boatright from Bacon County Board seat; Boatright sought injunctive/declaratory relief and mandamus to place his name on the ballot.
  • Trial court on remand held Elections Committee’s disqualification arbitrary and capricious and granted declaratory/injunctive relief to place Boatright on ballot.
  • Appellants (Rigby, Morris, Sellers, Day, Harrison) appealed, arguing good faith of the decision and improper mandamus relief.
  • Elections Committee had discretion to determine qualification; prior attorney advised no disqualifying financial conflict; Boatright had divested Pike stock before the meeting.
  • Record showed Boatright’s second petition timely filed after divestment; Committee declined to meet and treated earlier decision as final.
  • Georgia appellate court affirmed, recognizing trial court’s broad equitable discretion and upholding injunction ordering placement on ballot.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the Elections Committee acted arbitrarily and capriciously Boatright Rigby Yes; decision lacked good faith and honest judgment
Whether the relief enforcing placement on ballot was proper equitable relief Boatright Rigby Proper; injunction, not mandamus, compelled by bylaws
Whether the trial court abused its discretion in granting injunctive relief Boatright Rigby No; court properly crafted injunctive relief

Key Cases Cited

  • Planning Technologies, Inc. v. Korman, 290 Ga. App. 715 (Ga. App. 2008) (good faith and honest judgment standard governs discretionary decisions)
  • Goode v. Mountain Lake Investments, LLC, 271 Ga. 722 (Ga. 1999) (courts may craft equitable remedies with broad discretion)
  • State Farm Mut. Auto. Ins. Co. v. Mabry, 274 Ga. 498 (Ga. 2001) (trial court findings not set aside unless clearly erroneous)
  • Taylor v. Evans, 232 Ga. 685 (Ga. 1974) (mandatory injunctions upheld when appropriate)
  • Mabry, 274 Ga. 498 (Ga. 2001) (mandamus context and equitable relief distinctions clarified)
Read the full case

Case Details

Case Name: RIGBY Et Al. v. BOATRIGHT Et Al.
Court Name: Court of Appeals of Georgia
Date Published: Nov 19, 2014
Citation: 330 Ga. App. 181
Docket Number: A14A1369
Court Abbreviation: Ga. Ct. App.