Camp v. Williams

• Decision Date: 30 September 2022
• Docket Number: S23A0073
• Citation: 314 Ga. 699,879 S.E.2d 88
• Parties: CAMP v. WILLIAMS et al.
• Court: Georgia Supreme Court

314 Ga. 699

879 S.E.2d 88

CAMP

v.WILLIAMS et al.

S23A0073

Supreme Court of Georgia.

Decided: September 30, 2022

Scott Kelly Camp, Camp & Camp, P. O. Box 99, Douglasville, Georgia 30133-0099, Bryan Paul Tyson, Bryan Francis Jacoutot, Taylor English Duma LLP, 1600 Parkwood Circle, Suite 200, Atlanta, Georgia 30339, for Appellant.

Leslie Joy Suson, Michael Victor Coleman, Jonathan M. Nussbaum, Thompson Hine, LLP, Two Alliance Center, 3560 Lenox Road, Suite 1600, Atlanta, Georgia 30326-4266, Aaron Watson, Thompson Hine LLP, Two Alliance Center, 3560 Lenox Rd., Suite 1600, Atlanta, GA, 30326, 1745 Homestead Ave NE, Atlanta, Georgia 30306, Jeremy Todd Berry, Chilivis, Grubman, Dalbey & Warner, LLP, 3127 Maple Drive, NE, Atlanta, Georgia 30305, Joseph Jay Siegelman, Chilivis Grubman Dalbey & Warner, LLP, 1834 Independence Square, Atlanta, Georgia 30338, for Appellee.

Peterson, Presiding Justice.

This case is a dispute over who can run for Chief Magistrate Judge of Douglas County in the November 2022 election. After the incumbent successfully challenged the qualifications of the only person who qualified to run for the Democratic nomination, the Douglas County Democratic Party Executive Committee purported to name a replacement. That led to another challenge, this one by the incumbent's husband (a registered voter eligible to vote in the election), contending that the substitution was improper. The superior court agreed that the Douglas County Board of Elections and Registration (the "Board") was not legally authorized to allow the substitution, but ruled that the statutory vehicle through which the challenge was asserted — OCGA § 21-2-6 — covers only challenges to a candidate's qualifications to hold office (like age, residence, and bar membership), not whether the candidate fulfilled the necessary prerequisites to seek office (like a proper substitution).

We granted an application for discretionary appeal, expedited consideration in the light of the rapidly approaching election, and now reverse. Code section 21-2-6 allows the challenge here because "qualifications," as that term is used in the statute, includes all of the prerequisites for seeking and holding office. The substitute candidate did not properly qualify to seek office, so the Board lacked authority to put him on the ballot. And because electors have an interest in having the community's government offices filled by duly qualified officials, the Board's decision allowing an unqualified candidate on the ballot violated a substantial right of an elector. Accordingly, the decision below must be reversed.

1. This controversy began when the incumbent Chief Magistrate Judge (and Republican nominee),¹ Susan Camp, successfully challenged in superior court the qualifications of her would-be-opponent, Sylvia Baker, on the grounds that Baker is not a member of the State Bar of Georgia. Baker was the only Democratic candidate who qualified to run for Chief Magistrate, so her removal from the Democratic Primary ballot meant that Camp would run without a Democratic challenger in the general election.

In response, the Douglas County Democratic Party purported to substitute a new candidate before the primary election — Ryan Christopher Williams — who had qualified to run for superior court judge. Scott Camp, Susan Camp's husband and a registered voter eligible to vote in the election for Chief Magistrate, challenged that action in a written submission to the Board.

After a hearing, the Board dismissed the challenge, despite the fact that Williams was not on the list of certified Democratic candidates for the chief magistrate seat. See OCGA § 21-2-154 (b). The Board announced that Williams would appear on the general election ballot as the Democratic nominee for Chief Magistrate Judge. Camp sought judicial review under OCGA § 21-2-6, naming Williams, the Board, the Board's members, and its director, Milton Kidd, as respondents.

The superior court agreed that the Board should not have replaced Baker with Williams, but refused to reverse the Board's decision. The challenge allowed by OCGA § 21-2-6, the court said, "does not encompass the process by which [a candidate is] placed on the ballot — it is limited to challenges upon his qualifications to hold the office." The court reasoned that subsection (a) of the statute refers to "the constitutional and statutory qualifications for holding the office being sought," which the court took to mean personal characteristics like residence, age, citizenship, voter registration, and education. See OCGA § 21-2-6 (a) ; see also OCGA § 15-10-22 (identifying the "Qualifications of magistrates"). The court therefore believed that reversing the Board's decision to allow Williams's substitution "would require it to add language to the statute that is simply not there."

Following that decision, Camp sought and obtained discretionary review from this Court. We directed the parties to address one question: "[d]id the Superior Court err in concluding that OCGA § 21-2-6 did not authorize the court to reverse the decision of the Superintendent and the Douglas County Board of Elections?"

2. The answer to that question is yes. Code section 21-2-6 does authorize voters to challenge a candidate who has not satisfied the procedural prerequisites to appearing on the ballot. As explained below, the word "qualifications" is not as a semantic matter limited to the prerequisites for holding office. Moreover, the permission to challenge a candidate's qualifications to "seek" office indicates that prerequisites to appearing on the ballot are included in the challengeable qualifications. And this understanding is confirmed by subsection (d) of the statute, which provides that failure to satisfy one particular procedural prerequisite — payment with a valid check — requires an automatic finding of failure to meet the "qualifications" (albeit for "holding" the office) even without any challenge.

Code section 21-2-6 provides that "[e]very candidate for county office who is certified by the county executive committee of a political party or who files a notice of candidacy ... shall meet the constitutional and statutory qualifications for holding the office being sought." OCGA § 21-2-6 (a). "[A]ny elector who is eligible to vote for any such candidate may challenge the qualifications of the candidate ... giving the reasons why the elector believes the candidate is not qualified to seek and hold the public office for which the candidate is offering." OCGA § 21-2-6 (b). And if that happens, "[t]he superintendent shall determine if the candidate is qualified to seek and hold the public office for which the candidate is offering." OCGA § 21-2-6 (c).

"When we consider the meaning of a statute, ‘we must presume that the General Assembly meant what it said and said what it meant.’ " Deal v. Coleman , 294 Ga. 170, 172 (1) (a), 751 S.E.2d 337 (2013) (quoting Arby's Restaurant Group, Inc. v. McRae , 292 Ga. 243, 245 (1), 734 S.E.2d 55 (2012) ). "To that end, we must afford the statutory text its plain and ordinary meaning, we must view the statutory text in the context in which it appears, and we must read the statutory text in its most natural and reasonable way, as an ordinary speaker of the English language would." Id. at 172-173 (1) (a), 751 S.E.2d 337 (citations and punctuation omitted).

(a) Starting with the text, the ordinary meaning gleaned from a review of dictionary definitions of "qualification" offers little support for Williams's and the Board's argument that the word as used in the statute can refer only to the attributes required to hold office. And although examination of dictionary definitions of a single word is not a substitute for a broader consideration of context and history, see, e.g., Jones v. State , 304 Ga. 594, 602 (3), 820 S.E.2d 696 (2018) (declining to apply dictionary definitions when an argument based on them "views one word in isolation and ignores the context"), "reviewing dictionaries from the era of the statute's enactment may assist in determining its meaning." State v. Henry , 312 Ga. 632, 637 (3) (a), 864 S.E.2d 415 (2021) (citing Sandifer v. U.S. Steel Corp. , 571 U.S. 220, 227-228, 134 S.Ct. 870, 187 L.Ed.2d 729 (2014) ).

So understood, contemporary dictionaries do not indicate a limited scope to the meaning of "qualifications." Instead, contemporary dictionaries show that the ordinary meanings of "qualifications" and "qualified" both encompass necessary prerequisites generally — not merely traits or attributes.

Around the time the statute was enacted, see Ga. Laws 1980 p. 312, 313-314, § 2, "qualification" was commonly defined to mean things like "the act of qualifying or the state of being qualified"; "any quality, knowledge, ability, experience, or acquirement that fits a person for a position, office, profession, etc." or "a condition that must be met in order to exercise certain rights." Webster's Deluxe Unabridged Dictionary, 1473 (2d ed. 1983); see also Webster's Ninth New Collegiate Dictionary, 963 (1985); Webster's Third New International Dictionary, 1858 (1976).

Along the same lines, "qualified" was commonly defined to mean things like "having met conditions or requirements set"; and "having the necessary or desirable qualifications." Webster's Deluxe Unabridged Dictionary, supra at 1473; see also Webster's Ninth New Collegiate Dictionary, supra at 963; Webster's Third New International Dictionary, supra at 1858.

As a matter of ordinary meaning, therefore, there is no reason to believe that the General Assembly's use of the words "qualifications" or "qualified" compels the conclusion that OCGA § 21-2-6 allows challenges only to attributes like age, residency, and bar status.

(b) Moreover, "[a]s we have said many times before when interpreting legal text, ‘we do not read words in isolation, but rather in context.’ " City of Guyton v. Barrow , 305 Ga. 799, 805 (3), 828 S.E.2d 366 (2019) (quoting Smith v. Ellis , 291 Ga. 566, 573 (3...