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