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Pearson v. Bartlett

Citations: 577 N.E.2d 981; 1991 Ind. App. LEXIS 1517; 1991 WL 183939Docket: No. 49A02-9010-CV-577

Court: Indiana Court of Appeals; September 16, 1991; Indiana; State Appellate Court

Narrative Opinion Summary

This case involves a dispute regarding the results of an election for the Board of Education of the Metropolitan School District of Decatur Township, Indiana. The appellant, a candidate who lost by 82 votes, challenged the recount commission's decision to declare her opponent the winner. The crux of the legal issue revolved around the interpretation of Indiana Code 20-4-1-26.4(g), which the appellant argued mandates the disqualification of entire ballots when voters selected more candidates than allowed from a district. In contrast, the appellee argued that Indiana Code 3-12-1-12 should apply, emphasizing the importance of voter intent. The trial court affirmed the recount commission's approach, which prioritized discerning voter intent and counting votes accordingly. The court found that only votes exceeding the district's candidate limit should be invalidated, rather than entire ballots, aligning with a broader legislative goal to reflect the true will of the voters. The court's decision upheld the recount commission's findings and confirmed the appellee's election, demonstrating judicial deference to established election procedures and voter intention.

Legal Issues Addressed

Ballot Validity in School District Elections

Application: The court interpreted the statute to mean that ballots should only be invalidated where specific voting violations occur, not entirely.

Reasoning: The legislature's wording does not imply that a ballot is entirely invalid when a voter exceeds the candidate limit; instead, a more reasonable interpretation allows for ballots to be invalidated only in specific instances where the violation occurs.

Election Procedures under Indiana Code 20-4-1-26.4(g)

Application: This statute addresses the disqualification of ballots when voters select more candidates than allowed from a district.

Reasoning: Pearson argues that Indiana Code 20-4-1-26.4(g) mandates disregarding entire ballots when both candidates from district two are selected.

Judicial Deference to Recount Commission Decisions

Application: The court upheld the recount commission's decision, emphasizing the principle of reflecting the voters' true will.

Reasoning: The recount commission and trial court's decision to count the disputed ballots for Bartlett, but not for Pearson or her opponent, is upheld, affirming the trial court's judgment.

Voter Intent under Indiana Code 3-12-1-12

Application: The court applied this statute to prioritize voter intent over technical ballot errors in school board elections.

Reasoning: Bartlett cites Indiana Code 3-12-1-12, which emphasizes voter intent. The court concluded that the remaining ballots indicated a clear intent to vote for Bartlett, affirming the recount commission's rulings and confirming Bartlett's election.