VOTE NO ON #2!
It's Overkill!

Transcript of Judge Sauls' Order


          1                                  IN THE CIRCUIT COURT OF THE
                                             SECOND JUDICIAL CIRCUIT, IN
          2                                  AND FOR LEON COUNTY, FLORIDA
                
          3                                  CASE NO.  98-5826
                
          4     THE REV. DR. JAMES ARMSTRONG,
                et al.,
          5     
                          Plaintiffs,
          6     
                vs.
          7     
                SANDRA MORTHAM, in her 
          8     official capacity as
                Secretary of State,
          9     
                          Defendant.
         10     _______________________/
                
         11     PROCEEDINGS:           Hearing
                
         12     
                BEFORE:                N. SANDERS SAULS
         13                            Circuit Judge
                
         14     
                DATE:                  Friday, October 23, 1998
         15     
                
         16     TIME:                  Commenced at  9:30 a.m.
                                       Concluded at 11:30 a.m.
         17     
                
         18     LOCATION:              Leon County Courthouse
                                       Courtroom Number 3D
         19                            Tallahassee, Florida
                
         20     
                REPORTED BY:           NANCY P. VETTERICK, R.P.R.
         21                            Certified Court Reporter
                                       Notary Public in and for the
         22                            State of Florida at Large
                
         23                ACCURATE STENOTYPE REPORTERS, INC.
                                     100 Salem Court
         24                    Tallahassee, Florida 32301
                                     (850) 878-2221
         25     
                




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          1     APPEARANCES:
                
          2               REPRESENTING THE PLAINTIFFS:
                
          3                    RANDALL C. BERG, JR., ESQUIRE
                               Florida Justice Institute, Inc.
          4                    2870 First Union Financial Center
                               200 South Biscayne Boulevard
          5                    Miami, Florida 33131-2310
                               (305)358-2081
          6     
                          REPRESENTING THE DEFENDANT:
          7     
                               JAMES PETERS, ESQUIRE
          8                    Office of the Attorney General
                               PL-01, The Capitol
          9                    Tallahassee, Florida 32399-1050
                               (850)414-3300
         10     
                               -and-
         11     
                               RICHARD B. MARTELL, ESQUIRE
         12     
                               -and-
         13     
                               LOUIS F. HUBENER, ESQUIRE
         14     
                                       * * * * *
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          1                               INDEX
                
          2     ITEM                                             
                
          3     HEARING COMMENCED                                    4
                
          4     HEARING CONCLUDED                                    9
                
          5     
                
          6     CERTIFICATE  OF REPORTER                            10
                
          7     
                
          8     
                
          9     
                
         10     
                
         11     
                
         12     
                
         13     
                
         14     
                
         15     
                
         16     
                
         17     
                
         18     
                
         19     
                
         20     
                
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          1                         P R O C E E D I N G S.


          2                THE COURT:  At this time, the Court is going 


          3           to grant the opposition that's been filed to the 


          4           motion for a preliminary injunction as well as to 


          5           consolidate any further consideration of an 


          6           injunction or a mandamus with the trial on the 


          7           merits and to advance the cause.  


          8                It appears that the count relating to a 


          9           petition for mandamus should be denied as much as 


         10           mandamus would not be an appropriate remedy for 


         11           cause in this particular case.  The acts sought to 


         12           be compelled by the defendant/respondent is not 


         13           purely a ministerial duty where a clear legal right 


         14           to the performance of such ministerial duty has 


         15           been established, and it appears that mandamus is 


         16           not properly grantable or an alternative writ under 


         17           the old procedure or the issuance of a show cause 


         18           order under the new rule where the respondent 


         19           cannot comply with such a writ physically or 


         20           practically at this time.  


         21                It appears that the Fine (phonetic) case and 


         22           the Hess case -- this Court reads further 


         23           decisions, Fine, in particular, held that mandamus 


         24           might properly lie under the particular facts in 


         25           that case because the Court concluded that the 





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          1           violation had been clearly and conclusively 


          2           demonstrated from the face of the proposed 


          3           amendment.  


          4                In this case, this Court cannot find at this 


          5           time that there has been a demonstration that this 


          6           particular proposed constitutional amendment is 


          7           clearly and conclusively defective.  For those 


          8           reasons, it appears that mandamus will not properly 


          9           line, and that count should be dismissed.  


         10                With respect to the count for the declaratory 


         11           relief and an ancillary preliminary injunction in 


         12           connection with this amendment, again it has not 


         13           been demonstrated that the proposed amendment is 


         14           clearly conclusively defective, and as indicated by 


         15           Justice Drew in the case of Golden which the      


         16           Court -- actually it was a case not dealing with 


         17           mandamus, but apparently it was grounded in a 


         18           request for a declaration as well as for an 


         19           injunction.  


         20                The injunction was denied by the trial court, 


         21           and the scenario appears practically the same as in 


         22           that case as in this case where the election in the 


         23           Golden case -- of course, at that time, it was a 


         24           little more than a month away.  Here apparently 


         25           it's 10-days-or-so days away from an election, and 





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          1           an injunction at this time would be highly 


          2           extraordinary under these facts.  


          3                To grant such an injunction would create great 


          4           confusion and disorder which would produce an 


          5           injury to the public which would far outweigh the 


          6           rights of the complainants here to gain any relief 


          7           it may be appropriate from.  


          8                The Court is going to deny the complaint or 


          9           the motion for the preliminary injunction as all 


         10           the prerequisites for the issuance of an injunction 


         11           are not present, and those grounds have been 


         12           adequately covered in the filed opposition to the 


         13           motion.  


         14                Accordingly, at this time, the Court cannot 


         15           find that the valid title in the summary are 


         16           legally sufficient.  It may remain for another day, 


         17           but it does appear that at this time the ballot 


         18           should be retained for the people's consideration. 


         19                With respect to the assertion of laches, it 


         20           does not appear at this time that it would be 


         21           appropriate to grant any dismissal on the basis of 


         22           laches either to the mandamus aspect which the 


         23           Court has already found and indicated that it 


         24           appears that it would not be appropriate in this 


         25           case, nor at this time should there be any 





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          1           dismissal of the request for declaratory relief or 


          2           injunction on that basis.  


          3                Reading the cases, it just appears that 


          4           perhaps the language in the concurrence -- in the 


          5           Gross case -- perhaps it wasn't a concurring 


          6           opinion -- overlooked the distinction of a 


          7           dismissal of an action as opposed to perhaps 


          8           dismissal on a pleading. 


          9                This one does not appear to be an appropriate 


         10           case to dismiss at this stage, there not being any 


         11           clear and irrevocable demonstration of laches that 


         12           would arise to conclusive ultimate defense in this 


         13           case, and it appears that if the defense of laches 


         14           is maintained, it may remain as a viable defense in 


         15           this case, and it may be the subject of discovery 


         16           if that is appropriate if it is to be asserted as 


         17           an additional defense to the complaint for 


         18           declaratory relief and any ultimate permanent 


         19           injunction in this case.  


         20                This Court is not going to dismiss on the 


         21           basis of laches nor hold that laches is 


         22           inappropriate as a defense at this time.  In 


         23           summary, at this time, the Court is going to deny 


         24           the preliminary relief that's been requested at 


         25           this time, and the case will remain pending for 





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          1           further proceedings in due course.  


          2                All right.  I suppose Mr. Peters, you or Mr. 


          3           Martell, would you please submit a proposed order 


          4           if counsel can settle on form and content, then 


          5           please do so.  If not, then perhaps you may each 


          6           wish to submit a proposal.  


          7                All right?  Anything further?  


          8                (No response.)


          9                THE COURT:  If not, that will conclude the 


         10           hearing.  


         11                MR. BERG:  I think for purposes of appeal, I 


         12           would like to request if the Court is going to deny 


         13           the preliminary relief as well as the writ of 


         14           mandamus, that we just go ahead and deny the 


         15           declaratory judgment action so we can go ahead and 


         16           seek relief in the District Court of Appeals or the 


         17           Supreme Court.


         18                THE COURT:  I don't know whether your 


         19           complaint for declaratory judgment or relief is so 


         20           lacking in merit at this time that it should be 


         21           denied, but if you want to voluntarily dismiss it, 


         22           then certainly you can do that.


         23                MR. BERG:  Can I have just a minute?  


         24                THE COURT:  All right.  Counsel for both sides 


         25           wish to jointly move for the Court to deny the 





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          1           second count at this time?  


          2                MR. HUBENER:  Judge, we think it's improper to 


          3           rule on the merits at this time for most of the 


          4           reasons you have said.  It's going to create 


          5           confusion and disorder in the minds of the voters.  


          6           Some are going to go in there thinking, well, the 


          7           Court said it's okay, I don't need to vote on it.


          8                THE COURT:  Well, a joint stipulation.  The 


          9           Court's ruling stands.  Thank you.


         10                (Hearing concluded at 11:30 a.m.)


         11     


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          1                      CERTIFICATE OF REPORTER


          2     


          3     STATE OF FLORIDA:


          4     COUNTY OF LEON:


          5               I, NANCY P. VETTERICK, do hereby certify that 


          6     the foregoing proceedings were taken before me at the 


          7     time and place therein designated; that my shorthand 


          8     notes were thereafter translated under my supervision;  


          9     and the foregoing pages numbered 1 through 9 are a true 


         10     and correct record of the aforesaid proceedings.


         11               I FURTHER CERTIFY that I am not a relative, 


         12     employee, attorney or counsel of any of the parties, nor 


         13     relative or employee of such attorney or counsel, or 


         14     financially interested in the foregoing action.


         15               DATED THIS 23RD DAY OF OCTOBER, 1998.


         16     


         17     


         18                                   ___________________________
                                              NANCY P. VETTERICK
         19                                   100 SALEM COURT
                                              TALLAHASSEE, FL 32301
         20                                   (850) 878-2221
                
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