EVANSTON — The civil lawsuit against the Uinta County Republican Party, president Elisabeth “Biffy” Jackson, Karl Allred, Lyle Williams and Jana Williams — which asserted that the four had voted illegally in the March 2021 party leadership elections — has reached a long-awaited conclusion.
After two opposing motions for summary judgment, the Third District Court ruled on July 14 that the defendants voted within the confines of the law, as they were all sitting officers of the Uinta County Central Committee, and GOP bylaws state that officers may vote alongside the committee.
This ruling comes after a special prosecutor chose not to prosecute the four following an investigation by the Wyoming Division of Criminal Investigation (DCI).
The plaintiffs — Jon Conrad, Danny Eyre, Wendy Schuler, Ron Micheli, Clarence Vranish, Clara Vranish and Troy Nolan — made accusations shortly after the defendants allegedly acted as deciding votes in their own reelections.
DCI opened a formal investigation at the request of Uinta County Attorney Loretta Howieson-Kallas. An e-mail Howieson-Kallas sent at the time reads, “The Uinta County Clerk determined there was sufficient merit to transfer this matter to my office for investigation and, if appropriate, prosecution. The Wyoming Division of Criminal Investigation consented to my request that they address the relevant investigation…”
The criminal investigation, carried out under Uinta County Clerk Amanda Hutchinson, came to a halt after special prosecutor Michael Crosson found that, “While my interpretation of Wyoming Statute 22-4-105 is that the legislature most likely intended that only members of the county central committee should cast votes to select state committeeman and committeewoman and other offices as provided by party bylaws, and thus the letter of the law was probably violated, this conclusion is not absolute.”
Despite Crosson’s dismissal of the criminal case, civil proceedings moved forward before concluding on Thursday, July 14. The civil case was decided based on interpretation of Wyoming statutes and party bylaws, which served to determine the propriety of actions made by the defendants.
The plaintiffs alleged — and the defendants agreed — that during the 2021 meeting, the defendants had been defeated in the election for precinct committeepersons, and also that they were not members of the County Central Committee and that the four defendants were outgoing officers at the time.
Williams allowed himself and the other officers to vote, allegedly leading to the election of Allred as state committeeman, Williams as state committeewoman and Jackson as chairman of the committee.
The plaintiffs sought a declaration of wrongdoing based upon a perceived violation of the Election Code, including Wyoming Statute 22-4-105, allowing improper electors to vote in the Central Committee election. This facet of the plaintiffs’ argument was based upon one sentence in the statute, which reads, “At the meeting, the county central committee shall elect the chairman of the county central committee, one state committeeman and one state committeewoman and other offices as provided by the party bylaws.” The plaintiffs argued that “as provided by the party bylaws” modifies “other offices,” rather than “shall elect.”
Plaintiffs further argued that the plain meaning of those words would require that only central committee members hold the right to vote to elect a candidate to each office.
While the court agreed with the plaintiffs’ interpretation of the modifier, it found that such a modification did not adequately deny the ability of committee officers to vote in committee elections or set a punishment for those who did.
Additionally, the court ruled that legal precedent had determined the legislature can regulate the “time, place and manner of elections,” but cannot limit “fundamental rights, such as the freedom of political association.”
The court decided that the procedure by which the Uinta County Republican Party should hold elections would be under the discretion of the party. The court’s ruling reads, “When considering the Plaintiffs’ motion for summary judgment, the Court holds there is no issue of fact. …The county central committee followed Uinta County Republican Party bylaws at the March 16th meeting. There is no dispute of fact that under the Uinta County bylaws, the election at the March 16th meeting was proper.”
The court found the plaintiffs unable to cite relevant information in statutes or caselaw that would support that the election of Uinta County Republican Party leadership is not an internal party matter. The court also noted that the plaintiffs made no assertions which adequately distinguished their argument from those of preceding cases that made the same ruling.