Rigby v. Boatright
Annotate this CaseJulian Rigby and other members of the Board of Directors of the Satilla Rural Electric Membership Corporation appealed a trial court's order granting a writ of mandamus to Jerry Boatright, acting individually and derivatively on behalf of the members of the Satilla Rural Electric Membership Corporation. Boatright was a member of the Satilla Rural Electric Membership Corporation. Boatright submitted to Satilla's Credentials and Elections Committee a petition that nominated him as a candidate for election to Satilla's Board of Directors for the seat that Rigby held. Rigby challenged Boatright's qualifications to be a member of the Board, based upon Boatright's financial interest in Pike Electric, LLC. Satilla's Credentials and Elections Committee formally ruled that Boatright was not qualified to serve on the Board, citing the financial interest provision of the bylaws. Boatright filed what the parties stipulate was a second petition for nomination as a candidate for a seat on the Board. The Credentials and Elections Committee declined to have a meeting to address this petition and considered its earlier decision regarding Boatright's qualifications based on the earlier petition to be final. Boatright then brought this action, naming Satilla, members of the Board of Directors, and members of the Credentials and Elections Committee as defendants. Boatright asked for a temporary restraining order, interlocutory and permanent injunctions preventing the election for the Board position from proceeding without Boatright's appearance on the ballot, and a writ of mandamus compelling the defendants to consider his second petition for nomination, determine that he was qualified to serve on the Board, and proceed accordingly with the election for Rigby's Board seat. The trial court concluded that the decision of the Credentials and Elections Committee was arbitrary and capricious, and granted Boatright a writ of mandamus. Rigby and other Board members then brought this appeal. The Supreme Court reversed the grant of mandamus relief: mandamus is not a remedy available to enforce the purely private right that Boatright was asserting. The right Boatright sought to enforce could be addressed by a court of equity. Boatright requested in his pleadings temporary and permanent injunctive relief, but the trial court's order did not rule upon these requests. Accordingly, the judgment of the trial court was reversed and the case is remanded to the trial court for consideration of Boatright's requests for injunctive relief.
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