In re Marion Barnett

Summary

The Supreme Court of Texas considered whether Marion Barnett was eligible for placement on the ballot for Dallas Independent School District Trustee, District Six, despite listing his street address in the mailing-address field rather than the permanent-residence field of his application. The court held that the application, considered as a whole and together with undisputed voter-registration information, provided sufficient information to establish his residence in District Six. The court conditionally granted mandamus relief and ordered the respondents to certify Barnett and place his name on the ballot.

Holdings

1. A candidate's application contains sufficient residence information when, considered as a whole, the application and undisputed public records allow election officials to determine that the candidate resides in the district sought to be represented, even if the candidate places the street address in the mailing-address field rather than the permanent-residence-address field.
2. Respondents abused their discretion by rejecting Barnett's application because the application contained sufficient information, corroborated by undisputed public records, to determine that he resided in District Six.

Questions Presented

1. Whether Barnett's ballot application satisfied the statutory residence-address requirement when his street address appeared in the mailing-address field rather than the permanent-residence-address field.
2. Whether election officials abused their discretion by rejecting the application despite the information in the application and undisputed public records establishing Barnett's residence in District Six.
3. Whether the Supreme Court of Texas should conditionally grant mandamus relief ordering respondents to place Barnett on the ballot.

Disposition

writ_granted