Steve Hale v. State of Mississippi Democratic Executive Committee, Rickey Cole, Chairman and Bill Stone

Summary

The Mississippi Supreme Court affirmed the circuit court’s determination that Bill Stone had established domicile in Marshall County and therefore satisfied the residency requirement for candidacy for Mississippi Senate District 10. The court held that the circuit court did not commit manifest error in weighing evidence of Stone’s residence and intent, including voting registration, homestead exemption, tax filings, and community affiliations. The court also upheld the exclusion of a utility-usage expert’s testimony and deemed the alternative tacking issue moot.

Holdings

1. The circuit court did not commit manifest error in finding that Stone established his domicile in Marshall County in October 2013 and was qualified to run for Senate District 10.
2. The absolute-proof requirement applies to proving that a candidate will meet the qualifications on or before the election date; it does not impose an absolute-proof burden on the candidate's underlying qualifications themselves when determining domicile.
3. The court did not decide the tacking issue because its holding that Stone independently established domicile in Marshall County rendered the issue moot.
4. The circuit court did not abuse its discretion by excluding Majors's proposed expert testimony because the record did not establish that his methodology was reliable or scientifically grounded.

Questions Presented

1. Whether the circuit court committed manifest error in finding that Stone had moved his domicile from Benton County to Marshall County and satisfied the constitutional residency requirement for Senate District 10.
2. Whether Stone could establish the required residency through the doctrine of tacking.
3. Whether the circuit court abused its discretion by excluding Wallace Majors's proposed expert testimony concerning utility usage and whether a residence was occupied.

Disposition

affirmed