In the

I

atourt of Apptal

of the

&tatt nf Ctralifnrnfa

THIRD APPELLATE DISTRICT

C062321

FILED

ALAN KEYES, et al.,

Plaintiffs-Appellants,

APR - 1 2010

v.

COURT OF APPEAL - THIRD DISTRICT DEENA C. FAWCrn

BY Deputy

DEBRA BOWEN, et al.,

Defendants-Respondents.

APPEAL FROM THE SUPERIOR COURT OF SACRAMENTO COUNTY HON. MICHAEL P. KENNY· NO. 34200880000096CUWMGDS

REPLY BRIEF OF APPELLANTS

GARY G. KREEP, ESQ. (066482)

UNITED STATES JUSTICE FOUNDATION 932 "D" Street, Suite 2

Ramona, California 92065

(760) 788-6624 Telephone

(760) 788-6414 Facsimile

Attorney for Appellants,

Dr. Alan Keyes, Dr. Wiley S. Drake and Markham Robinson

_ COUNSEL PRESS' (800) 3-APPEAL

W

PRlNTED ON RECYCLED P APER ~&

TABLE OF CONTENTS

I

TABLE OF AUTHORITIES iii

I. INTRODUCTION 1

II. STANDARD OF REVIEW 1

III. LEGAL DISCUSSION 2

A. The Writ of Mandate is Not Moot Since it is Capable of Repetition Yet Evading Review........ 2

B. This Case Is Not a Political Question, Since it Involves Judicial Review as to Whether the Duties of the Secretary of State of California Were Fully

Executed 4

C. There is an Appropriate Remedy Available at the State Level, Rather Than Federal Level, Because a State Court May Compel a State Official to

Perform Ministerial Duties 6

D. RESPONDENT BOWEN has an Implied Ministerial Duty to Verify the Eligibility of Presidential Candidates Because Of Her Responsibilities as California's Chief Election

Officer 12

E. The Defense of Laches is not Available Because APPELLANTS Filed The Underlying Writ in a Timely Manner................................................... 14

F. Election Code Section 6901 is Unconstitutional

and Will Lead to Absurd Results............... 15

IV. CONCLUSION 18

TABLE OF AUTHORITIES

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FEDERAL CASES

Cleaver v. Jordan (1968) 393 U.S. 810 9

Morgan v. United States (D.C. Cir. 1986) 801 F.2d 445 ...... 5,6

Weinstein v. Bradford(1975) 423 U.S. 147,96 S.Ct. 347 3

STATE CASES

California Teachers Assn v. San Diego Community College Dist. (1981) 28 Ca1.3d 692, 699, 170

Cal.Rptr. 817, 621 P .2d 856) 2

Evans v. City of Berkeley (2006) 38 Ca1.4th 1,40

Cal.Rptr3d 205) .. 1

In re Neilson's Estate(1962) 57 Ca1.2d 733, 371 P.2d

745,22 Cal.Rptr. 1 ~ 13, 14

FEDERAL STATUTES

3 United States Code § 15 7

STATE STATUTES

California Bus. & Prof. Code § 25659 10

California Code of Civil Procedure § 1089.5 3

California Elections Code § 6901 15, 16, 17

California Elections Code § 15505 2, 3

California Government Code § 12172 8, 12, 14

111

California Government Code § 12172.5 ~, 5 f

CALIFORNIA CONSTITUTION

California Constitution, Article III, § 1 .. 17

U.S. CONSTITUTION

United States Constitution, Article II 15, 16, 17

United States Constitution, Article II, § 1 5

United States Constitution, Article II, § 5 8

IV

I.

INTRODUCTION

In their brief, RESPONDENTS have attempted to demean our

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efforts to honestly litigate important California and U.S. Constitutional issues concerning past and future elections. Therefore, APPELLANTS are bringing this brief, in part, to respond to attempts by RESPONDENTS to minimize and marginalize the issues raised in this litigation.

II.

STANDARD OF REVIEW

In RESPONDENTS Opening Brief, they attempt to make it appear as if APPELLANTS have multiple barriers of proof as to the standard of review. The appropriate standard of review on appeal from a judgment of dismissal after a demurrer is De Novo, in which there must be a showing of reversible error committed by the trial court (Evans v. City of Berkeley (2006) 38 Ca1.4th 1,40 Cal.Rptr.3d 205). This is a single element standard of review. The appellate courts assume the truth of all facts properly pleaded by the plaintiff appellant (Evans at 5), and all questions of law are reviewed afresh by

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the appellate courts without bounds of the trial courts' findings

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(California Teachers Assn. v. San Diego Community College Dist.

(1981) 28 Ca1.3d 692, 699, 170 Cal.Rptr. 817,621 P.2d 856.).

III.

LEGAL DISCUSSION

A. The Writ of Mandate is Not Moot Since it is Capable of Repetition Yet Evading Review

The window of certification for the Secretary of State of

California is a very narrow one, which lasts for approximately four

weeks [California Election Code, (hereinafter referred to as "CEC")

§ 15505]. RESPONDENT contends that the substantive issues of this

case are also not yet ripe as to the 2012 General Election, and as to

any other future elections. To hold this case to be moot as to the 2008

national election, and not yet ripe as to the 2012 national election as

RESPONDENTS contend, and, therefore, not justiciable would leave

this APPELLANT, and any future plaintiff, subject to a very narrow

window in which to attempt to fully litigate a set of very complex

legal issues. This sliver of an exception has been outlined as a two

prong test:

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"(1) the challenged action was in its duration too short to be . fully litigated prior to its cessation or expiration, and (2) there was a reasonable expectation that the same complaining party would be subjected to the same action again.(Weinstein v. Bradford (1975) 423 U.S. 147, 96 S.Ct. 347).

APPELLANTS can easily satisfy both elements of this exception.

Under the first prong, the time period in which to litigate the Secretary

of State's certification of electorate votes for the winning candidate is

only 32 days after the national election (CEC § 15505). This gives

APPELLANTS a brief period to litigate very complicated issues

which involve the United States Constitution, the California

Constitution, and the California Elections Code, and which also

present questions of first impression. Evidence to support

APPELLANTS' claims is also complex and time consuming, since it

involves researching and dissecting historical evidence and legislative

intent. The answer period for a writ alone proscribed by statute allows

for thirty days to respond, thus taking up the entire period in which

APPELLANT can avoid a mootness argument (See California Code

of Civil Procedure § 1089.5).

APPELLANT'S satisfaction of the Second Prong lies in the fact

that Dr. Keyes has run for President in 1992, 1996, 2000, and 2008,

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and it is reasonable to believe that Dr. Keyes will again seek the office

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of President in 2012, after which the Secretary of State can, again, not

fulfill her duties as outlined in California Government Code

(hereinafter referred to as "CGC") § 12172.5, leaving APPELLANT

to again seek redress from this court, only to be subject again to the

brief window of opportunity to litigate the same or substantially

similar issues. This case is a Mt. Rushmore figure-head on the

"capable of repetition yet evading review" exception to the mootness

doctrine. APPELLANT meets this mootness exception, and should be

allowed to continue to litigate these complex legal questions.

B. This Case Is Not a Political Question, Since it Involves Judicial Rev.iew as to Whether the Duties of the Secretary of State of California Were Fully Executed

RESPONDENTS allege that jurisdiction over Presidential

qualifications lies with the United States Congress, however, this case

is not an issue of the constitutionality of these qualifications, or

attempting to create new qualifications, but whether the Secretary of

State of California has a duty to ensure that Presidential candidates do,

in fact, meet these proscribed requirements, so as to properly put

together the California ballot and certify proper electoral votes to the

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President of the Senate [U.S. Constitution Article (hereinafter referred

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to as "U.S. Const. Art.") II § 1].

"Each State shall appoint, in such Manner as the Legislature

thereofmay direct, a Number of Electors ... " (U.S. Const. Art. II § 1),

therefore each state has been granted the sovereignty of choosing how

to set up their own electorate system, which includes how to certify

which votes go to which presidential candidate. In this instant case

the question presented is whether the Secretary of State of California

complied with her duties of certification under CGC § 12172.5.

RESPONDENTS' citation of Morgan v. United States (D.C.

Cir. 1986) 801 F.2d 445, to uphold their contention that this case is a

prime example of a non-justiciable political question does not hold

water as analogous to this instant case. InMorgan, the questions

presented were based upon the U.S. House of Representatives denial

of seating of Mr. McIntyre, who claimed to have won a seat in the

House, and the House of Representatives then conducting their own

recount of a 1984 Indiana Congressional election. The plaintiffs'

contentions in Morgan were founded primarily on 1 st Amendment

causes of action, and directly challenged the power of the House of

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Representatives to choose whether or not to seat elected House

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members. Unlike Morgan, this case concerns itself primarily with

California state election law and the compliance or non-compliance by

the Secretary of State in fulfilling her ministerial duties as chief

elections officer of California.

Thus, this is not a political question, but is, rather, a question

well within the jurisdiction of this Court to determine, as it is a duty

that may be compelled by this Court's equitable power. Therefore,

RESPONDENTS' argument is without merit because this is a proper

question for a writ of mandate and not a political question better left

to another branch of government.

C. There is an Appropriate Remedy Available at the State Level, Rather Than Federal Level, Because a State Court May Compel a State Official to Perform Ministerial Duties

RESPONDENTS allege that the proper remedy in this matter is

found at the federal level, not at the state level, because it concerns the

office of the President of the United States or candidates for said

office. The only related remedy found in the United States Code is

one which provides members of Congress with the opportunity to

object to Electors who were improperly designated, or whose conduct

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in casting a vote for President of the United States was improper. .

/

This remedy, however, is only infrequently exercised and does not

have bearing on the relief sought in this case. In addition, even if the

remedy were applicable to the issue raised in this appeal, the remedy

is insufficient to prevent the harm addressed by the remedy because,

given the infrequent usage of this remedy, the success of any

challenge raised against an Elector would be based on which party the

objection is made against and which party is in power in the United

States Congress at the time of the objection. This remedy is further

limited because the United States Code only permits challenges to be

made, but does not require the Vice President, who presides over the

Electoral count, to either accept the challenge or act on it. (3 U.S.C.

§ 15). Since this Federal remedy neither directly relates to relief

sought by Appellants, nor provides an adequate solution to the issues

raised, it is not the proper remedy herein.

A remedy is proper at state level where a duty is imposed on a

state officer. The underlying writ does not require anything of any

federal official, but does require Respondent BOWEN, the California

Secretary of State, to fulfill a specific duty to verify that a candidate

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meets the eligibility requirements for the office that the candidate is seeking. This is a matter of first impression, and RESPONDENT'S correctly assert that there is not yet any statutory or judicial rule which requires this duty of the Secretary of State. However, it is a duty that

is reasonably inferred from the already existing duties of said office. First, the California Secretary of State is the Chief elections officer of California (CGC § 12172). This duty requires that she oversee all elections in the state and ensure that no election law is violated. In order to fulfill this duty, the Secretary of State website contains information for all persons seeking elected office, in particular the requirements for eligibility that must be met in order to qualify for the ballot. This also includes information for presidential candidates. (http://www.sos.ca.gov/elections/election 200S/qualifications/wi pres

nov200S.pdt). This information sheet includes the three requirements for eligibility under U.S. Const. Art. II § 5, which are (1) be a natural-born citizen of the United States, (2) be at least

35 years of age, and (3) be a resident of the United States for at least 14 years. Unless these requirements are merely placed on the information sheet for the sole purpose filling space in the document,

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it is reasonable to infer that the Secretary of State should verify that

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a Presidential candidate meets said requirements before placing that

candidate on the ballot, since the Secretary of State is under a duty to

verify the eligibility of all those who run for any state office as well as

those who run for the United States Congress. In fact, the Secretary of

State not only has such a duty to verify the eligibility of a Presidential

candidate, prior Secretary of States have exercised this duty. In 1968,

Eldridge Cleaver ran for President of the United States on the Peace

and Freedom Party ticket, but was removed by then Secretary of State,

Frank M. Jordan. Eldridge Cleaver did not meet the minimum age

requirement for the office. Eldridge Cleaver challenged his removal,

which was upheld by California Supreme Court, whose decision was

affirmed by the Supreme Court of the United States, who refused to

review the decision (Cleaver v. Jordan (1968) 393 U.S. 810).

Finally, even if this remedy is not available for application to

the 2008 Presidential Election, it is available for future elections so as

to avoid this issue in the future and it is within the power of this Court

to compel the Secretary of State to perform this duty. Thus, the

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Secretary of State should be compelled to verify the eligibility of all

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future presidential candidates on the California ballot.

The Constitutional requirements of eligibility for the Office of

President of the United States are not meaningless restrictions on who

may seek the office that may be ignored if inconvenient. Instead, as in

the natural born citizen requirement, these requirements for the office

of President serve an important function of assuring voters in the

United States that the person that they are electing to the office of

President does not have any divided loyalties between the United

States and any other nation. At this time, however, there is no clear

duty on the part of any entity or body other than an implied duty upon

the Secretary of State of California to make a determination of

eligibility for the office of President, at least as far as the California

ballot is concerned. In other arenas that are arguably far less

important than the most powerful elected position in the world, certain

requirements are always verified. Store clerks have a statutory duty to

check the identification of a customer who wants to purchase alcohol

and may not take the customer's word regarding his age. (Cal.Bus. &

Prof Code § 25659). Likewise, any person who submits an

10

D. RESPONDENT BOWEN has an Implied Ministerial I Duty to Verify the Eligibility of Presidential Candidates ; Because Of Her Responsibilities as California's Chief Election Officer

RESPONDENTS argue that the California Secretary of State

has no clear ministerial duty to verify the eligibility of Presidential

candidates and that, since there is no ministerial duty, then the

underlying writ is improper. However, on the California Secretary of

State website (www.sos.ca.gov/elections/electionsabout.htm) there

is a list of duties of the office, including the duty as chief elections

officer of California to ensure election laws are followed (CGC

§ 12172), the duty to investigate election fraud (CGC § 12172), and

the duty to advise candidates and local elections officials on the

qualifications and requirements for running for office (CGC § 12172).

In order to fulfill her duty to advise candidates, there are several

documents on the website informing all who are seeking elected office

as to the qualifications and requirements for each elected position.

Documents listing the qualifications and requirements are provided

for the offices of Governor and Lieutenant Governor; Secretaries of

State, Controller and Treasurer; Attorney General; Insurance

Commissioner; Member of the State Board of Equalization; State

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Senator and Member of Assembly; United States Senator; United f States Representative in Congress; and President of the United States. The Secretary of State currently verifies that every candidate for these positions, except for that of the office of President of the United States, meets the requirements for each respective office. Since the Secretary of State does have a ministerial duty to verify the eligibility for nearly all of the candidates for office, it is not improper to infer that she also has a ministerial duty to verify the eligibility of those who are running for the office of President of the United States. In addition, when APPELLANTS' council inquired of RESPONDENT BOWEN'S attorney on the hearing on this matter on March 13,2009, asking whether or not the Secretary of State has such a duty, he said nothing. This silence on the part of RESPONDENT BOWEN'S attorney amounts to a tacit admission because such an inquiry would normally call for a response. "Where person makes statement in presence of party under circumstances that would normally call for response if statement were untrue, statement is admissible for limited purpose of showing party's reaction, and his silence, evasion, or equivocation may be considered as tacit admission.''ln re Neilson's

13

Estate (1962) 22 Cal. Rptr. 1, 57 Ca1.2d 733,371 P.2d 745. Ifnothing f

else, this duty is implied by the Secretary of State's own list of duties

found on her website as determined by California Statute (CGC

§ 12172), and, thus, she ought to be compelled to fulfill this implied

duty in all future elections.

E. The Defense of Laches is not Available Because APPELLANTS Filed The Underlying Writ in a Timely Manner

RESPONDENTS argue that APPELLANTS are precluded from

any recovery based on the doctrine of Laches because APPELLANTS

waited until after the election to file suit. This argument fails to be

persuasive because, although APPELLANTS filed suit after, but in a

timely manner on November 13,2008 (APPELLANTS Opening

Brief, 5), the 2008 election was concluded, there was no earlier time

that suit could have been filed because prior to the election, any

potential injury was speculative since RESPONDENT Obama might

not have been elected. APPELLANTS filed suit after the results of

. the general election were determined, but before the vote of the

California Presidential Electors was certified by Secretary of State,

before all Presidential Elector votes were certified by the United

14

States Congress, and well before Respondent Obama was inaugu?ted. Had APPELLANTS filed suit prior to the election, they would have

been faced with a problem with ripeness because, if Respondent

Barack Obama had not been elected, then the issue of eligibility

would not matter. There would be no concrete injury to anyone prior

to the 2008 election because someone other than Mr. Obama could

have been elected to the office of President of the United States. For

that reason, it was not an unreasonable act for APPELLANTS to wait

until after election to file suit.

F. Election Code Section 6901 is Unconstitutional and Will Lead to Absurd Results

_ RESPONDENTS raise a provision of the California Elections

Code as the basis for the Secretary of State having no authority to

exclude any candidate chosen by a political party for the general

election (RESPONDENTS Briefpage 14). The code section cited by

RESPONDENTS (CEC § 6901) is wholly inconsistent with Article II

of the United States Constitution because this code places a

mandatory duty on the Secretary of State that could end up with

absurd and ridiculous results. For example, RESPONDENTS would

have this Court believe that if the Republican Party were to nominate

15

Arnold Schwarzenegger, the Secretary of State would be forced to/put him on the ballot for the general election, despite the fact that Arnold

Schwarzenegger is well known as not being a natural born citizen of

the United States. Another example would be if the Libertarian Party

were to nominate Ayn Rand, then the Secretary of State would be

forced to put her on the ballot for the general election, even though

Rand died in 1982. Or for even more ridiculous results, if the

Democratic Party were to nominate Gordon Brown, the current Prime

Minister of Great Britain, then the Secretary of State would be forced

to put him on the ballot for the general election. Such nominations are

absurd, as these individuals clearly do not meet the eligibility

requirements under the United States Constitution, but

RESPONDENTS argue that even here, the Secretary of State has no

discretion to exclude them from the ballot.

In addition, the language of CEC § 6901, compelling the

Secretary of State to place any candidate nominated by a political

party, is in direct conflict with the requirements for presidential

eligibility in Article II of the United States Constitution because it

16

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allows a candidate to be placed on the ballot without any verification

I

of eligibility for the office. The California Constitution states:

"The State of California is an inseparable part of the United States of

America, and the United States Constitution is the supreme law of the

land." (Cal.Const. Art. III, § 1). For this reason, in situations where a

state law is in direct conflict with the United States Constitution, as is

the case here between CEC § 6901 and Article II of the United States

Constitution, then the United States Constitution controls over the

inconsistent state law. Therefore, CEC § 6901 should be held to be

unconstitutional as inconsistent with the United States Constitution

and inconsistent with the Secretary of State's duty to enforce

California election law.

17

.IV.

I

CONCLUSION

Based on the forgoing, APPELLANTS respectfully request a

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reversal on the judgment sustaining RESPONDENTS' demurrer.

Dated: March 29,2010

Respectfully Submitted,

Attorney for APPELLANTS

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CERTIFICATE OF COMPLIANCE

Counsel of Record hereby certifies that pursuant to Rule

8.204(c)(1) or 8.S04(d)(1) of the California Rules of Court, the

enclosed Reply Brief of Appellants is produced using 13-point or

greater Roman type, including footnotes, and contains 3,324 words,

which is less than the total words permitted by the rules of court.

Counsel relies on the word count of the computer program used to

prepare this brief.

Dated: March 29,2010

Respectfully Submitted,

G&Y&

Attorney for APPELLANTS

19

State of California ) County of Los Angeles)

)

Proof of Service by: ./ US Postal Service Federal Express

!

I, Stephen Moore , declare that I am not a party to the action, am over 18 years of

age and my business address is: 354 South Spring St., Suite 610, Los Angeles, California 90013.

On 03/29/2010 declarant served the within: Reply Brief of Appellants

upon:

1 Copies

FedEx .f USPS

Peter A. Krause

Office of the State Attorney General Post Office Box 944255 Sacramento, California 94244-2550

Attorney for Defendant-Respondent, Debra Bowen as Secretary etc.

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1

Copies

FedEx .f USPS

Clerk for the Hon. Michael P. Kenny Superior Court of California Sacramento County Superior Court Gordon D. Schaber

Sacramento County Courthouse 720 9th Street

Sacramento, California 95814

Copies

FedEx .f USPS

the addressees) designated by said attorney(s) for that purpose by depositing the number of copies indicated above, of same, enclosed in a postpaid properly addressed wrapper in a Post Office Mail Depository, under the exclusive custody and care of the United States Postal Service, within the State of California, or properly addressed wrapper in an Federal Express Official Depository, under the exclusive custody and care of Federal Express, within the State of California

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,

I further declare that this same day the original and copies has/have been hand delivered for

filing OR the original and 4 copies has/have been filed by .f third party commercial carrier for next business day delivery to:

Michael J. Strumwasser Strumwasser & Woocher LLP

10940 Wilshire Boulevard, Suite 2000 Santa Monica, California 90024

Attorney for Defendants-Respondents, Barack Obama et al.

4

FedEx .f USPS

Copies

Office of the Clerk

Supreme Court of California 350 McAllister Street

San Francisco, California 94102-4797

Office of the Clerk

CALIFORNIA COURT OF APPEAL Third Appellate District

621 Capitol Mall, 10th Floor Sacramento, California 95814-4719

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I declare under penalty of perjury that the foregoing is true and correct: signature:SlefMI\ /110&18. .............

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