Catoosa Cnty. Republican Party v. Henry, 906 S.E.2d 750 (Ga., 2024)
The appellants, who are the Catoosa County Republican Party (“CCRP”) and its executive officers (collectively, “the CCRP Defendants”), tried to stop certain candidates from qualifying for the May 2024 Republican primary for certain county commission seats, citing a statute that provides in part that “[u]nless otherwise provided by law, all candidates for party nomination in a state or county primary shall qualify as such candidates in accordance with the procedural rules of their party[.]” OCGA § 21-2-153 (b). A document introduced as an exhibit before the trial court, purporting to be the local rules of the CCRP, provides that “[i]n order to qualify for office as a Republican, a potential candidate must be approved by the [CCRP] County Committee by a majority vote within twelve (12) months prior to the date he or she attempts to qualify.” And the document also provides that “[i]n order to qualify for office as a Republican in Catoosa County, a potential candidate must present, at the time of qualifying, a signed and notarized affidavit from the [CCRP] Chairman or Secretary, stating the date and location of the meeting that the [CCRP] County Committee voted to allow the proposed candidate to qualify for office as a Republican.”
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In their appeal, the CCRP Defendants ask this Court to reverse the trial court’s ruling below — which declared that each of the Candidates was “entitled to qualify with the Catoosa County election superintendent” under OCGA § 21-2-153 (c) (2) — and dismiss the Candidates’ petitions. Thus, it appears that the CCRP Defendants essentially seek a ruling that honors the CCRP Defendants’ decision to block the Candidates’ qualification.2 Although the record provides little indication of what happened after the trial court on March 8 ordered that the Candidates be permitted to qualify, the CCRP Defendants’ requested relief would appear to require upending the results of a completed primary election as to one or more commission seats.
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Our precedent required the CCRP Defendants to do all they could to ensure that their claims were resolved before the primary election occurred. But they chose delay instead. “Under these circumstances, the prudential concerns recognized by this Court, as informed by the relevant statutory framework, when considering similar dilatory election challenges counsel us to dismiss this appeal.”
