Local Government

Paul Martin

Statute requiring a candidate to timely file a financial interest held constitutional. Coyne v. Edwards, No. 93194 (Mo. banc,March 25, 2013), J. Stith.

Bernard Edwards filed a declaration of candidacy for the office of director of the Community Fire Protection District. He received and acknowledged the District’s notice informing him of the dates by which he was required to file a financial disclosure statement, pursuant to § 105.492 RSMo. Edwards failed to file the statement by either the initial or final permissible dates, even though he received an intervening notice from the Missouri Election Commission. The commission sent a notice to the district of the failure, and the district, through Chief Coyne, filed suit to remove Edwards from the ballot. The trial court removed Edwards, and he appealed, claiming that § 105.492 was unconstitutional in various respects.

After transfer due to the constitutional challenge, the Supreme Court rejected Edwards’ claims that the statute denied him ballot access in violation of the First Amendment and equal protection and due process in violation of the Fourteenth Amendment.