libertarian party of oregon's reply brief on cross appeal (00712860x9e67

Caption continued and counsel listed on next page May 2015

IN THE COURT OF APPEALS OF THE STATE OF OREGON

TIM REEVES, ERIC SAUB, GREGBURNETT, as the Libertarian Party ofOregon; DAVID TERRY, M.CARLING and RICHARD BURKE, asmembers of the Libertarian Party ofOregon; and LIBERTARIAN PARTYOF OREGON,

Plaintiffs-AppellantsCross-Respondents,

and

CARLA PEALER, as the LibertarianParty of Oregon,

Plaintiff,

v.

WES WAGNER, HARRY JOETABOR, MARK VETANEN, BRUCEKNIGHT, JIM KARLOCK,RICHARD SKYBA, and JEFFWESTON, individuals; andLIBERTARIAN PARTY OFOREGON,

Defendants-RespondentsCross-Appellants,

and

JOSEPH SHELLEY,

Defendant.

Clackamas County Circuit CourtCase No. CV12010345

CA A155618

RESPONDENT / CROSS-APPELLANTLIBERTARIAN PARTY OF OREGON’S

REPLY BRIEF ON CROSS APPEAL

On Appeal from the General Judgment ofDismissal entered on October 25, 2013, and the

Supplemental Judgment entered on May 30,2014, in the Clackamas County Circuit Court by

the Honorable Henry C. Breithaupt

C. Robert Steringer, OSB No. [email protected] Applegate, OSB No. [email protected] LONG GARY RUDNICK P.C.1001 SW Fifth Avenue, 16th FloorPortland, OR 97204503.242.0000

Of Attorneys for Respondent / Cross-Appellant Libertarian Party of Oregon

Tyler Smith, OSB No. [email protected] SMITH & ASSOCIATES, P.C.181 N Grant St., Suite 212Canby, OR 97013503.266.5590

Of Attorney for Plaintiffs-Appellants,Cross-Respondents

Colin Andries, OSB No. [email protected] LAW OFFICES

1001 SW 5th Avenue, Suite 1100Portland, OR 97204503.206.6002

Of Attorney for Respondents / Cross-Appellants Harry Joe Tabor, MarkVetanen, Bruce Knight, Jeff Weston,Jim Karlock and Richard Skyba

James Leuenberger, OSB No. [email protected] E. LEUENBERGER, P.C.P.O. Box 1684Lake Oswego, OR 97035503.679.8473

Of Attorney for Respondent / Cross-Appellant Wes Wagner

i

TABLE OF CONTENTS

Page

I. INTRODUCTION......................................................................................1

II. ARGUMENT IN REPLY ON DEFENDANTS’ CROSS-APPEAL.........2

A. Plaintiffs’ claims lacked an objectively reasonable basisbecause well-established First Amendment jurisprudencebars judicial intervention in intraparty disputes absent acompelling state interest...................................................................2

1. The law is clear: a court cannot grant the relief soughtby plaintiffs. ...........................................................................2

2. Decisions by Judge Redman, Steve Trout and theLibertarian National Committee do not establish theobjective reasonableness of plaintiffs’ claims. ......................5

a. Judge Redman’s decisions on ORCP 21motions do not establish the objectivereasonableness of plaintiffs’ claims. ...........................6

b. Steve Trout’s communications do not shieldplaintiffs.......................................................................7

c. Decisions of the Libertarian NationalCommittee have no bearing on this case. ....................8

B. Plaintiffs’ claims were barred by issue preclusion. .........................9

III. CONCLUSION ........................................................................................12

ii

TABLE OF AUTHORITIES

Cases Page(s)

Cf. Freitag v. Dep’t of Revenue,19 OTR 37, 41-45 (2006) ................................................................................6

Chavez v. Boise Cascade Corp.,307 Or 632, 772 P2d 409 (1989) ...................................................................11

Cousins v. Wigoda,419 US 477, 95 S Ct 541 (1975) .....................................................................3

Decker v. Berean Baptist Church,51 Or App 191, 624 P2d 1094 (1981) .............................................................5

Democratic-Farmer-Labor State Central Comm. v. Holm,227 Minn 52, 55 NW2d 831 (1948) ................................................................4

Eu v. San Francisco Cnty. Democratic Cent. Comm.,489 US 214, 229, 231-32, 109 S Ct 1013 (1989)................................1, 2, 3, 4

State ex rel Fosser v. Lavik,9 ND 461, 83 NW 914 (1900) .........................................................................4

Hope Presbyterian Church of Rogue River v. Presbyterian Church(USA),242 Or App 485, 255 P3d 645 (2011), aff’d 352 Or 668 (2012) ....................5

Jackson v. Riddell,476 F Supp 849 (ND Miss 1979).................................................................3, 4

O’Brien v. Brown,409 US 1, 92 S Ct 2718 (1972) .......................................................................3

Reform Party of U.S. v. Gargan,89 F Supp 2d 751 (WD Va 2000)....................................................................3

Shuler v. Distribution Trucking Co.,164 Or App 615, 994 P2d 167 (1999) rev den, 330 Or 375(2000).......................................................................................................11, 12

State Farm Fire & Cas. Co. v. Reuter,299 Or 155, 700 P2d 236 (1985) ...................................................................10

iii

Williams v. Salem Women’s Clinic,245 Or App 476, 263 P3d 1072 (2011) .........................................................13

Statutes

ORS 20.105.................................................................................................1, 7, 13

Other Authorities

Presidential Election Campaign Fund Act............................................................3

Voting Rights Act of 1965....................................................................................3

1

I. INTRODUCTION

Although the trial court correctly dismissed plaintiffs’ claims on the

ground that they were barred by the First Amendment, it erred by denying

defendants’ request for attorney fees pursuant to ORS 20.105 on the ground that

plaintiffs’ claims lacked an objectively reasonable basis in fact and in law. It is

well established that courts lack the authority to decide who leads a political

party or to adjudicate the validity of matters of internal party governance.

Notwithstanding plaintiffs’ persistence in mischaracterizing the holdings of

judicial decisions on this subject, courts for more than a century have

recognized the constitutional prohibition against, and the perils of, wading into

the internal workings of political parties.

In fact, these plaintiffs should know better than to argue otherwise.

When their ringleader, Plaintiff Richard Burke, was executive director of the

Libertarian Party of Oregon (“LPO”), he successfully directed the party’s

defense in a writ of mandamus proceeding brought by Defendant Wes Wagner

in which Mr. Wagner asked the Washington County Circuit Court to require the

LPO to follow its own bylaws. In that proceeding, the LPO under Plaintiff

Burke’s direction relied heavily on the U.S. Supreme Court’s decision in Eu v.

San Francisco County Democratic Central Committee for the proposition that

the state cannot intervene in an intraparty dispute in the absence of a compelling

state interest. Then-Circuit Court Judge Marco Hernandez agreed, and

2

dismissed the writ. Mr. Burke and his fellow plaintiffs in this case, who purport

to assert their claims on behalf of the LPO, are precluded from arguing that a

circuit court has the authority to enforce the LPO Bylaws now that they

disagree with the process followed by the LPO State Committee to implement

the reform plan adopted at the LPO’s 2010 annual business convention.

In the remaining pages of this brief, the LPO replies to specific

arguments asserted by plaintiffs in their answer to the LPO’s cross-assignment

of error.

II. ARGUMENT IN REPLY ON DEFENDANTS’ CROSS-APPEAL

A. Plaintiffs’ claims lacked an objectively reasonable basisbecause well-established First Amendment jurisprudence barsjudicial intervention in intraparty disputes absent a compellingstate interest.

1. The law is clear: a court cannot grant the relief soughtby plaintiffs.

Plaintiffs simply misunderstand the U.S. Supreme Court’s precedents on

the subject of judicial intervention in intraparty disputes. The rule of law is

straightforward: a state may not interfere with the internal affairs of a political

party in the absence of a compelling state interest, and the state has no interest

in protecting the party from itself. Eu v. San Francisco Cnty. Democratic Cent.

Comm., 489 US 214, 229, 231-32, 109 S Ct 1013 (1989). Still, plaintiffs

continue to argue that, because the Eu case involved a statutory impairment of

the internal affairs of political parties, only legislative impairments are limited

3

by the First Amendment. Pl’s Comb. Reply and Ans. Br. at 29. That argument

ignores the precedents recognizing that judicial action in this area is no more

appropriate than legislative action. See, e.g., O’Brien v. Brown, 409 US 1, 4–5,

92 S Ct 2718 (1972) (reasoning that the party’s “convention itself is the proper

forum for determining intra-party disputes,” and that “the political processes”

should “function free from judicial supervision”); Cousins v. Wigoda, 419 US

477, 95 S Ct 541 (1975) (ruling state court injunction unconstitutional because

it abridged the associational rights of delegates and violated party’s right to

determine the composition of its national convention in accordance with party

standards).

Plaintiffs also persist in their misunderstanding of decisions by other

courts, contending that those courts have settled intraparty disputes in

circumstances that are “almost directly on point.” Pl’s Comb. Reply and Ans.

Br. at 30-32. Plaintiffs start with two Reform Party cases, failing to understand

that the Reform Party had agreed to be bound to certain organizational

requirements in exchange for the receipt of federal money to hold its national

convention, under the Presidential Election Campaign Fund Act. See Reform

Party of U.S. v. Gargan, 89 F Supp 2d 751, 753-54 (WD Va 2000).

The older, pre-Eu cases cited by plaintiffs are no more helpful to them.

Plaintiffs continue to mischaracterize Jackson v. Riddell, 476 F Supp 849 (ND

Miss 1979), a removal action involving the Voting Rights Act of 1965.

4

Plaintiffs argue that the court in Jackson enforced an “intra-party rule that

requires intra-party dispute resolution process before a civil complaint may be

filed.” Pl’s Comb. Reply and Ans. Br. at 30. To the contrary, the court in

Jackson rejected the argument that it should dismiss for failure to exhaust

internal party remedies because the fault for such failure lay with the party

asserting it as grounds for dismissal.

In State ex rel Fosser v. Lavik, 9 ND 461, 462, 83 NW 914 (1900), the

court refused to pass judgment on parliamentary tactics within a convention, but

decided which candidate a county auditor was required to place on a ballot.

And in Democratic-Farmer-Labor State Central Comm. v. Holm, 227 Minn 52,

55 NW2d 831 (1948), the court stated, contrary to what plaintiff would have

this court hold:

“The rule with regard to judicial review of the actionsof political conventions is that in factionalcontroversies within a political party, where there isinvolved no controlling statute or clear right based onstatute law, the courts will not assume jurisdiction, butwill leave the matter for determination within theparty organization.”

Not one of the pre-Eu cases held that a court may involve itself in a purely

intraparty dispute such as the one before this court.

Finally, plaintiffs argue that two decisions of the Oregon Court of

Appeals involving churches establish the objective reasonableness of their

claims. Pl’s Comb. Reply and Ans. Br. at 33-36. Neither of those decisions

5

would trump the doctrines established by the U.S. Supreme Court prohibiting

judicial intervention of courts in intraparty disputes in the absence of a

compelling state interest. It also bears noting that in neither case did a court

declare how the church was to be governed or who would be its leaders. Hope

Presbyterian Church of Rogue River v. Presbyterian Church (USA), 242 Or

App 485, 255 P3d 645 (2011), aff’d 352 Or 668 (2012) (deciding what entity

held legal title to church property); Decker v. Berean Baptist Church, 51 Or

App 191, 624 P2d 1094 (1981) (affirming trial court’s dismissal of the

plaintiffs’ claims). That distinction is critical; even if this court could

adjudicate the ownership of property claimed by two different church

organizations, no one could reasonably argue that this court can decide who

runs one of those churches and which set of bylaws would govern it.

2. Decisions by Judge Redman, Steve Trout and theLibertarian National Committee do not establish theobjective reasonableness of plaintiffs’ claims.

Plaintiffs offer three additional defenses of the objective reasonableness

of their belief that the circuit court could decide who leads the LPO and what

bylaws would govern it: (1) early in the litigation, Judge Redman denied

defendants’ ORCP 21 motion to dismiss the claims; (2) an Elections Division

administrator told them they would need to go to court to get what they wanted;

and (3) the Libertarian National Committee agrees with them. Not one of those

arguments establishes the objective reasonableness of their claims.

6

a. Judge Redman’s decisions on ORCP 21 motions donot establish the objective reasonableness ofplaintiffs’ claims.

Plaintiffs argue that their claims must have had an objectively reasonable

basis because Judge Redman denied defendants’ ORCP 21 motion to dismiss

plaintiffs’ claims on the ground that the circuit court was constitutionally

prohibited from awarding the requested relief. Pl’s Comb. Reply and Ans. Br.

at 19-20. Defendants respectfully disagree with Judge Redman’s ruling, but it

also is beside the point. Judge Redman did not have the benefit of the factual

record that was presented in conjunction with defendants’ summary judgment

motions. That factual record fleshed out the history and nature of the dispute,

establishing without a doubt that plaintiffs’ claims involved an intraparty

political squabble. Plaintiffs were well aware of that history and therefore are

accountable for asserting claims for relief that could not be granted.1 Cf.

Freitag v. Dep’t of Revenue, 19 OTR 37, 41-45 (2006) (court may find that

plaintiff’s claim lacked an objectively reasonable basis even though it

previously survived a motion to dismiss).

1 As they did in the circuit court, plaintiffs apparently try to create theimpression that this Court rejected defendants’ constitutional argument twicebefore, arguing that “Defendants twice briefed and argued their argument aboutjurisdiction under the First Amendment.” Pl’s Comb. Reply and Ans. Br. at 20.As plaintiffs’ counsel was forced to admit under questioning by the court in thesummary judgment hearing, Judge Redman ruled only once on defendants’motion. Trans (5/16/2013) 141:23-142:10. The circuit court deferred ruling ondefendants’ first motion raising the constitutional issue until plaintiffs joinednecessary parties. See Order on Rule 21 Motions signed April 27, 2012.

7

Judge Redman also was not presented with defendants’ argument on the

preclusive effect of the Washington County Circuit Court’s decision in 2006,

discussed below, and made no rulings on that matter. Plaintiffs cannot rely on a

prior decision by Judge Redman to avoid accountability for filing a claim

seeking relief that was precluded by a prior judgment.

b. Steve Trout’s communications do not shieldplaintiffs.

Plaintiffs argue that their claims were objectively reasonable because

Steve Trout, an official with the Oregon Secretary of State’s office, “told the

parties that they have to go to court to adjudicate this matter if there is to be any

change because they do not adjudicate this type of dispute.” Pl’s Comb. Reply

and Ans. Br. at 20-22. That argument fails for at least two reasons. First, Mr.

Trout expressed no opinion on whether a court constitutionally could award the

relief sought by plaintiffs or whether issue preclusion would prevent a second

adjudication of that issue. Mr. Trout only stated that “if there is to be any

change,” it would need to come from a court because the Secretary of State was

not going to grant the relief requested by plaintiffs. ER-23 (Trout Declaration

at page 2). Second, even if Mr. Trout had opined on the First Amendment and

preclusion issues, his opinion is irrelevant to the question of whether there was

an objectively reasonable basis for plaintiffs’ claims. The subjective views of

Mr. Trout or anyone else have no bearing on objective reasonableness. See

ORS 20.105(1) (directing the court to award attorney fees upon a finding “that

8

there was no objectively reasonable basis for asserting the claim”) (emphasis

added).

c. Decisions of the Libertarian National Committeehave no bearing on this case.

Plaintiffs argue that their position is supported by various decisions of the

Libertarian National Committee. Pl’s Comb. Reply and Ans. Br. at 22-23.

Again, plaintiffs’ argument is not responsive to the question of whether they

had an objectively reasonable basis for their claims. There indeed were

conflicting rulings on the parties’ dispute by various organs of the national

party. The national party’s Judicial Committee ruled that the LNC was required

to recognize the leadership of the defendants, while political organs of the party

have supported plaintiffs. But the fact that plaintiffs have been able to convince

some people within an organization to support their cause has no bearing on

whether the First Amendment barred the circuit court from wading into the

dispute or whether the answer to that question was established through the

doctrine of issue preclusion. Moreover, and perhaps most importantly, the

LNC’s view of this dispute is irrelevant. The highest body of the LPO is its

State Committee, not the Libertarian National Committee (“LNC”). The LPO

is affiliated with the LNC, but the LPO and the LNC are independent

organizations. See Dkt 99, Ex 26 at 1 (Wagner Decl). The LNC has no power

to decide who leads the LPO or what bylaws of the LPO are effective. Id.

9

Accordingly, if any governing body were to receive deference in resolving this

matter, it would be the LPO State Committee that adopted the 2011 Bylaws.

B. Plaintiffs’ claims were barred by issue preclusion.

Perhaps the most frustrating part of this litigation for defendants is that

when the tables were turned in 2006, the LPO under Plaintiff Burke’s

management obtained the dismissal of a writ of mandamus proceeding on the

ground that the First Amendment, as interpreted by the U.S. Supreme Court in

Eu, barred courts from enforcing the bylaws of a political party. Setting aside

frustration with such tactics, the point is that the final judgment in the 2006

Washington County case established issue preclusion on the subject of judicial

enforcement of political party bylaws, such that plaintiffs could not have an

objectively reasonable basis for asserting a claim seeking to enforce the LPO’s

bylaws.

Plaintiffs have two primary arguments on issue preclusion: (1) plaintiffs

were not a party or in privity with a party to the 2006 Washington County case;

and (2) the issues in this case and the 2006 Washington County case are not

identical. Pl’s Comb. Reply and Ans. Br. at 24-28. Plaintiffs are incorrect on

both counts.

Plaintiffs attempt to avoid the effects of issue preclusion by claiming that

they were not parties to the 2006 Washington County case and therefore did not

have a full and fair opportunity to be heard. Pl’s Comb. Reply and Ans. Br. at

10

27. Plaintiffs’ argument is unavailing. It is undisputed that the LPO was a

party to the 2006 Washington County case. As for the present case, according

to their own caption, Plaintiffs Reeves, Saub, Pealer, and Burnett bring claims

“on behalf of the LPO.” It is therefore inescapable that those plaintiffs claim to

act on behalf of a party to the 2006 Washington County case. Furthermore,

according to Plaintiffs’ caption, Plaintiffs Carling and Burke bring claims as

LPO members. Accordingly, their claims derive from the LPO, and as such,

they are in privity with the LPO. State Farm Fire & Cas. Co. v. Reuter, 299 Or

155, 160-61, 700 P2d 236 (1985) (“A person may be bound by a previous

adjudication either by reason of being a party in the case, or by reason of

participation which is substantially equivalent to having been a party, or from

having a legal relationship that is derived from one who was a party.”). Indeed,

Plaintiff Burke controlled the LPO’s defense in the Washington County case.

Dkt 99, Ex 35 at 4-6 (Wagner Decl) (billing statements showing LPO’s contacts

with its attorney). Given that each of the plaintiffs, by their own caption, are

acting in their purported capacities as either members of the LPO or as officers

bringing claims on behalf of the LPO itself, it is not, as plaintiffs argue,

“fundamentally unfair” to apply issue preclusion to them. Pl’s Comb. Reply

and Ans. Br. at 28.

Plaintiffs argue that issue preclusion does not apply because, according to

plaintiffs, the issues in this case and the 2006 Washington County case are not

11

identical. Plaintiffs are incorrect. The court in the 2006 Washington County

case stated the central issue of that case accordingly: “I understand [that] what

is being requested is for this court to force the Libertarian Party to comply with

its internal rules.” Dkt 99, Ex 33 at 20 (Wagner Decl) (hearing transcript). In

this regard, the LPO, led by Plaintiff Burke, argued that “noncompliance with

bylaws is not something that is subject to a legal remedy. It is subject to a

political remedy.” Id. at 14. The issue in this case is identical, and the trial

court in this case reached the same conclusion as the court in the 2006

Washington County case: a court lacks the authority to force a political party to

comply with its internal rules.

Plaintiffs also argue that the issues in this case and the 2006 Washington

County case are not identical for the additional reason that the relator in the

2006 Washington County case (Defendant Wagner) sought a writ of mandamus,

while plaintiffs in this case seek a declaratory judgment. Pl’s Comb. Reply and

Ans. Br. at 25. This argument also is incorrect. In numerous instances, Oregon

courts have concluded that decisions have preclusive effect in different type of

proceedings. See, e.g., Chavez v. Boise Cascade Corp., 307 Or 632, 634, 772

P2d 409 (1989) (administrative determinations may have preclusive effect in

later civil proceeding); Shuler v. Distribution Trucking Co., 164 Or App 615,

627, 994 P2d 167 (1999) rev den, 330 Or 375 (2000) (arbitration decision may

have preclusive effect in later civil proceeding). A judgment in a writ of

12

mandamus proceeding has the preclusive effect of a judgment in any other type

of civil proceeding.

Finally, plaintiffs argue that the court in the 2006 Washington County

case ruled that claims seeking to force a political party to comply with its

internal rules may be brought in a declaratory judgment action rather than in a

writ of mandamus action. Pl’s Comb. Reply and Ans. Br. at at 21. The

plaintiffs support this mischaracterization of the 2006 Washington County case

by quoting from a colloquy between the court and counsel for the defendants

regarding the question of whether the relator had an adequate remedy at law

other than a writ of mandamus. Id.; Dkt 99, Ex 33 at 14 (Wagner Decl)

(hearing transcript). A reading of the transcript demonstrates that Judge

Hernandez referred to declaratory actions in his attempt to articulate the

Libertarian Party of Oregon’s position, but offers no opinion on whether such

an action would be appropriate. Judge Hernandez explained that the court

might have concluded that the plaintiff needed to exhaust other remedies such

as a declaratory judgment action before seeking a writ of mandamus, but the

constitutional prohibition trumped that inquiry. Dkt 99, Ex 33 at 20-21

(Wagner Decl) (hearing transcript).

III. CONCLUSION

Plaintiffs asserted three claims against defendants, each founded on the

idea that the circuit court would resolve an intraparty dispute over the

13

governing documents and leadership of the LPO. Well-established

constitutional principles prohibit judicial involvement in such a dispute. At

least one plaintiff knew that was the case when plaintiffs commenced this

litigation: Plaintiff Burke controlled the LPO’s defense when it obtained a

ruling to that effect in the 2006 Washington County case. That ruling created

issue preclusion that established a second, independently sufficient barrier to

the relief plaintiffs sought. Lacking any legal or factual support, plaintiffs’

claims did not have an objectively reasonable basis. See Williams v. Salem

Women’s Clinic, 245 Or App 476, 482, 263 P3d 1072 (2011) (A claim lacks an

objectively reasonable basis for purposes of ORS 20.105(1) if it is “entirely

devoid of legal or factual support.”). Defendants therefore were entitled to

findings pursuant to ORS 20.105(1) establishing their right to recover their

reasonable attorney fees. Defendants respectfully request that this court reverse

the circuit court’s ruling on their rights under ORS 20.105(1) and award them

their reasonable attorney fees at trial and on appeal.

Respectfully submitted this 11th day of May, 2015

HARRANG LONG GARY RUDNICK P.C.

By: s/ C. Robert SteringerC. Robert Steringer, OSB No. [email protected] Applegate, OSB No. [email protected] Attorneys for Respondent / Cross-Appellant Libertarian Party of Oregon

CERTIFICATE OF COMPLIANCE WITH ORAP 5.05(2)(d)

CERTIFICATE OF COMPLIANCE WITH ORAP 5.05(2)(d)

I certify that (1) this brief complies with te word-count limitation in

ORAP 5.05(2)(b), and (2) the word count of this brief (as described in

ORAP 5.05(2)(a)) is 3,166 words.

I certify that the size of the type in this brief is not smaller than 14 point

for both the text of the brief and footnotes as required by ORAP 5.05(4)(f).



CERTIFICATE OF FILING AND SERVICE


I certify that on May 11, 2015, I filed the foregoing RESPONDENT /

CROSS-APPELLANT LIBERTARIAN PARTY OF OREGON’S REPLY

BRIEF ON CROSS-APPEAL with the Appellate Court Administrator by

using the eFiling system.

The following participants in this case are registered eFilers and will be

served via the electronic mail function of the eFiling system.

Tyler Smith, OSB No. [email protected] SMITH & ASSOCIATES, P.C.181 N Grant St., Suite 212Canby, OR 97013503.266.5590

Of Attorney for Plaintiffs-Appellants, Cross-Respondents

James Leuenberger, OSB No. [email protected] E. LEUENBERGER, P.C.P.O. Box 1684Lake Oswego, OR 97035503.542.7433

Of Attorney for Respondent / Cross-Appellant Wes Wagner


Colin Andries, OSB No. [email protected] LAW OFFICES

1001 SW 5th Avenue, Suite 1100Portland, OR 97204503.206.6002

Of Attorney for Respondents /Cross-Appellants Harry Joe Tabor,Mark Vetanen, Bruce Knight, JeffWeston, Jim Karlock and RichardSkyba

James L. BuchalMurphy & Buchal LLP3425 SE Yamhill Street, Suite 100Portland, OR 97214

Of Attorney for Amicus Curiae OregonRepublican Party



P0521280.v2P0521280.v2

libertarian party of oregon's reply brief on cross appeal (00712860x9e67

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