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Matter of Plunkett v. Mahoney

Appellate Division of the Supreme Court of New York, Fourth Department
Aug 23, 1990
164 A.D.2d 976 (N.Y. App. Div. 1990)

Opinion

August 23, 1990

Appeal from the Supreme Court, Erie County, Joslin, J.

Present — Callahan, J.P., Boomer, Balio, Davis and Lowery, JJ.


Order modified on the law and as modified affirmed without costs, in accordance with the following memorandum: The Erie County Board of Elections properly invalidated the designating petition because the certificate of authorization was untimely filed (see, Matter of Fotopoulos v Board of Elections, 45 N.Y.2d 807; cf., Matter of Grieco v Bader, 43 Misc.2d 245, affd 21 A.D.2d 751). Supreme Court erred, therefore, in authorizing the Committee on Vacancies to designate a substitute candidate.

Since the defect which required the invalidation was technical in nature, an "opportunity to ballot" is an appropriate alternative remedy (Matter of Harden v Board of Elections, 74 N.Y.2d 796). The record discloses no evidence of impropriety and there is a clear demonstration by the Democratic Party to have a candidate (Matter of Venezia v Albanese, 153 A.D.2d 723). Here the petition contained three times the number of signatures required and a certificate of authorization was filed. The "opportunity to ballot" would provide the enrolled electorate an opportunity to express their choice at the polls (Matter of Harden v Board of Elections, supra; Matter of Brown v Ulster County Bd. of Elections, 48 N.Y.2d 614; Matter of Walker v Salerno, 89 A.D.2d 1031, affd 57 N.Y.2d 739).

All concur, except Boomer and Lowery, JJ., who dissent in part, in the following memorandum.


The "opportunity to ballot" remedy fashioned in Matter of Hunting v Power ( 20 N.Y.2d 680) should be used only in exceptional cases where the defects are technical in nature (Matter of Harden v Board of Elections, 74 N.Y.2d 796). We disagree with the majority that the failure to file the certificate of authorization timely is a technical defect (see, Matter of Mundt v Lomenzo, 34 A.D.2d 1035; Byer, Election Law § 61 [1st ed]).


Summaries of

Matter of Plunkett v. Mahoney

Appellate Division of the Supreme Court of New York, Fourth Department
Aug 23, 1990
164 A.D.2d 976 (N.Y. App. Div. 1990)
Case details for

Matter of Plunkett v. Mahoney

Case Details

Full title:In the Matter of JOHN M. PLUNKETT, Appellant, v. EDWARD J. MAHONEY et al.…

Court:Appellate Division of the Supreme Court of New York, Fourth Department

Date published: Aug 23, 1990

Citations

164 A.D.2d 976 (N.Y. App. Div. 1990)
560 N.Y.S.2d 535

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