Wallace v. Metro. Gov't of Nashville & Davidson Cnty.
546 S.W.3d 47
| Tenn. | 2018Background
- March 6, 2018: Nashville Mayor resigned; Metropolitan Clerk notified Davidson County Administrator of Elections.
- March 9, 2018: Davidson County Election Commission voted 3–2 to schedule the mayoral vacancy election for August 2, 2018 (a municipal general election date), and declined to file for judicial guidance or set the May 1 date.
- March 12–14, 2018: Wallace (qualified mayoral candidate) sued in Chancery Court seeking certiorari, mandamus, and declaratory relief arguing the Charter required a special election within 75–80 days; expedited hearing followed.
- Trial court ruled for defendants, holding that the August 2, 2018 municipal general election qualified as the next “general metropolitan election” and therefore no special election was required; Wallace appealed to the Tennessee Supreme Court.
- Tennessee Supreme Court reversed: it construed “general metropolitan election” in Charter § 15.03 as the specific August election held every fourth odd-numbered year for mayor (next one Aug. 2019), held the vacancy required a special election, and ordered the Commission to set one per Tenn. Code Ann. § 2-14-102(a).
Issues
| Issue | Plaintiff's Argument (Wallace) | Defendant's Argument (Metro/Commission) | Held |
|---|---|---|---|
| Meaning of “general metropolitan election” in Charter § 15.03 | Means the regularly scheduled mayoral general metropolitan election (every 4th odd-numbered year); next is Aug. 2019, >12 months away, so special election required | Any municipal general election (including Aug. 2, 2018 municipal general) is a “general metropolitan election,” so vacancy is within 12 months and no special election required | Court held “general metropolitan election” is the specific quadrennial mayoral election in § 15.01; Aug. 2019 is the next such election, so § 15.03 requires a special election |
| Whether § 15.03 is ambiguous and merits deference to Commission | N/A — asks court to construe text; seeks relief | Commission claimed its interpretation and State Election Coordinator should be afforded deference | Court found § 15.03 unambiguous and gave no deference to Commission’s contrary interpretation |
| Whether Wise v. Judd controls | N/A — Wallace distinguished Wise | Metro argued Wise decided similar issue and supported their view | Court held Wise did not address these specific Charter phrase distinctions and does not control |
| Whether equitable/prospective relief or judicial timing can validate Aug. 2, 2018 date | Wallace sought immediate relief to force timely special election | Metro/Commission asked court to apply ruling prospectively or treat court’s ruling date as trigger so Aug. 2 could stand | Court declined to retroactively rewrite statute or judicially amend timing; ordered Commission to set a special election under statutory timeframe |
Key Cases Cited
- State ex rel. Wise v. Judd, 655 S.W.2d 952 (Tenn. 1983) (distinguishing scope of “preceding general election” language; did not decide § 15.03 phrase at issue)
- Tenn. Dep’t of Corr. v. Pressley, 528 S.W.3d 506 (Tenn. 2017) (statutory interpretation principles; de novo review)
- Lee Med., Inc. v. Beecher, 312 S.W.3d 515 (Tenn. 2010) (plain-meaning rule and use of statutory context)
- Ray v. Madison Cnty., 536 S.W.3d 824 (Tenn. 2017) (legislative intent and harmonizing statutory provisions)
- City of Memphis v. Shelby Cnty. Election Comm’n, 146 S.W.3d 531 (Tenn. 2004) (agency’s duty to make initial determinations; limits of mandamus/certiorari review)
- McFarland v. Pemberton, 530 S.W.3d 76 (Tenn. 2017) (distinguishing review routes for legislative vs. quasi-judicial administrative acts)