Filed Date: Oct. 13, 2016
Closed Date: March 21, 2017
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This is a case about whether a federal court had jurisdiction to order different relief than what was ordered by a state court with respect to a town council election where, after being elected, a candidate was disqualified due to being a convicted felon.
On October 13, 2016, the Town of Hayneville ("Hayneville") filed this lawsuit in the U.S. District Court for the Middle District of Alabama (the "Federal Court"). Represented by private counsel, Hayneville sued the four qualified candidates for the town council election and petitioned the Federal Court to order that either (i) a new election be held for the four qualified candidates or (ii) the top three qualified candidates from the initial election be declared the winners, thereby overriding the order by the Circuit Court for the Second Judicial Circuit of Alabama (the "State Court") that the vacancy be filled by appointment. Hayneville claimed the Federal Court had jurisdiction over this matter pursuant to a 1988 Middle District of Alabama Consent Decree in Dillard v. Crenshaw County Alabama, Civil Action 2:87-cv-1230-MHT.
This case was initially assigned to Magistrate Judge Gray M. Borden but was reassigned to Judge Myron H. Thompson on January 10, 2017; however, the reasoning of the decision was articulated by Judge Borden in his February 21, 2017 Report and Recommendation, which Judge Thompson fully adopted without further commentary on March 21, 2017.
On August 23, 2016, Hayneville held an election for three open seats on its District "A" Town Council. Five candidates ran. On September 13, 2016, the State Court determined that one of the winning candidates was ineligible to run due to being a convicted felon and that his election was therefore void. The State Court then ordered that the vacancy should be filled by appointment, as prescribed by Alabama law. Dissatisfied with this outcome, Hayneville filed this lawsuit against the four qualified candidates, arguing that the Federal Court should override the State Court's order and, instead, require that either (i) a new election be held for the four qualified candidates or (ii) the top three qualified candidates from the initial election be declared the winners. While Hayneville admitted that appointment was permissible under Alabama law, it argued that it would disenfranchise hundreds of voters and fail to comply with a 1988 Middle District of Alabama Consent Decree.
On October 26, 2016, three of the defendants filed answers admitting the allegations in Hayneville's complaint and submitting to the jurisdiction of the Federal Court. However, one defendant filed a response asking the Federal Court to deny Hayneville's request and uphold the State Court's appointment order. On November 8, 2016, Judge Borden ordered Hayneville to articulate the basis for the Federal Court's subject matter jurisdiction, which Hayneville attempted to do through an amended complaint asserting that the Consent Decree was still operative. On November 30, 2016, the challenging defendant filed a Motion to Dismiss Hayneville's amended complaint, which Judge Thompson granted on March 21, 2017 per Judge Borden's February 21, 2017 Report and Recommendation.
In recommending grant of the Motion to Dismiss, Judge Borden determined that the Consent Decree--which Hayneville claimed was the basis for the Federal Court's subject matter jurisdiction--was no longer operative as it was codified into Alabama state law and subsequently dissolved by the Federal Court. According to Judge Borden, the Consent Decree itself provided that it would only remain in effect until its provisions were enacted as state law and that, after that occurred, the Federal Court expressly dissolved the Consent Decree and the subject matter therein (i.e., the system by which Hayneville elects its Town Council) became exclusively a state law issue over which federal courts have no jurisdiction.
Hayneville has not filed any objections or appeals following the Judgment entered by Judge Thompson on March 21, 2017.
Summary Authors
Nathaniel Hsieh (6/7/2024)
Dillard v. Crenshaw County, AL, Middle District of Alabama (1985)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/5606797/parties/town-of-hayneville-v-tyson-bailey-mag/
Strickland, Michael Glen (Alabama)
Borden, Gray M.
See docket on RECAP: https://www.courtlistener.com/docket/5606797/town-of-hayneville-v-tyson-bailey-mag/
Last updated Aug. 12, 2025, 11:49 p.m.
State / Territory: Alabama
Case Type(s):
Special Collection(s):
Law Firm Antiracism Alliance (LFAA) project
Key Dates
Filing Date: Oct. 13, 2016
Closing Date: March 21, 2017
Case Ongoing: No reason to think so
Plaintiffs
Plaintiff Description:
Town of Hayneville
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Case Details
Causes of Action:
Available Documents:
Outcome
Prevailing Party: Defendant
Nature of Relief:
Source of Relief:
Amount Defendant Pays: $0
Issues
Voting: