Tuesday, February 10, 2026
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C.A. Reverses Judgment Without Deciding That It Was Erroneous, Blocking Preclusive Effect
Justices Say Dispute Related to 2024 Election Is Moot but Proper Remedy Is to Order Remand and Direct Dismissal by the Superior Court
By a MetNews Staff Writer
Div. Three of the Fourth District Court of Appeal has taken the unusual action of reversing a judgment without determining whether it was correct or erroneous, telling the trial court, on remand, to dismiss the election-related petition as moot.
To do otherwise, Justice Thomas A. Delaney said in Friday’s unpublished opinion, would risk the prospect of an undisturbed trial court ruling, which might have been wrongly decided, being given preclusive effect in possible future litigation.
The decision stems from a contest in 2024 over the validity of a ballot designation. On Aug. 19 of that year, community activist Victor Valladares, a candidate for the City of Huntington Beach City Council, petitioned the Orange Superior Court to block the description of a competitor for the seat, Chad Williams, as a “Navy SEAL Speaker.”
“SEAL” is the acronym for the Navy’s “SEa, Air, and Land” special operations force.
Williams had been a member of that force for about five years, ending in 2010. He argued that his preferred designation was an accurate description of his occupation because he earned his livelihood giving speeches “on Navy SEAL leadership principles.”
Trial Judge’s Ruling
Judge Craig L. Griffin on Aug. 29, 2024, ruled that the designation was “misleading,” in violation of Elections Code §17107, because it created the impression that Williams was presently a SEAL member, who speaks. He decreed:
“The Court strikes ‘Navy Seal’ from the ballot designation and allows ‘Speaker’ to remain on the ballot designation.”
Williams appealed the following day, and Div. Three a month later, when it realized that the appeal affected an election, ordered expedited briefing. It soon learned, however, that Orange County Registrar of Voters Bob Page had determined that the appeal stayed Griffin’s order and, on Aug. 30, finalized the format of the ballot, with Williams’s chosen designation appearing on it.
On Sept. 30, Div. Three ordered that the “appeal shall proceed according to normal deadlines and processes.”
In the Nov. 5, 2024, general election, Williams won. The appellate process lumbered along.
Delaney’s Opinion
Delaney wrote:
“For procedural reasons having nothing to do with the merits of the petition or the appeal, we reverse the challenged order and direct the trial court to dismiss the petition.”
He said that the dispute does not present one of the rare instances where the appeals court should render a decision despite mootness because “[t]he issues are fact-specific,” standing “in stark contrast to election matters that courts have considered to be of broad, general public interest so as to support discretionary review notwithstanding technical mootness.”
Procedural History
Explaining why the appeal was not dismissed, he alluded to the procedural history.
On Sept. 23, 2024—at which point it appeared that effective relief could not be provided because the election process was too far along—Div. Three solicited letter briefs from Valladares, Williams, and the city as to whether there should be a dismissal based on mootness. Williams said in a Sept. 26 response:
“From Williams’s perspective, he must pursue this appeal to avoid preclusion issues if he wants to use the Navy SEAL Speaker designation in a future election, especially one for Huntington Beach City Council….Williams’ future use of the Navy SEAL Speaker designation is uncertain, but it is enough of a possibility that he wants to exhaust his appellate remedies in order to preserve that option.”
Delaney, in Friday’s opinion, accepted that reasoning, notwithstanding Williams’s concession in a footnote to his letter brief, saying:
“If Williams wins the election, it seems likely that he would choose the designation ‘City Councilmember’ (or some derivative thereof) if/when he runs for reelection in 2028, as most incumbents do.”
‘Alternative Disposition’
The justice wrote:
“[W]ithout deciding whether the underlying order would have res judicata effect if we were to simply dismiss the appeal as moot…, we find an alternative disposition proper to avoid the possibility of it having such an effect in subsequent litigation.”
He noted that the California Supreme Court took just such an approach in its 1964 decision in Paul v. Milk Depots, Inc.
The case decided on Friday is Valladares v. Page (Williams), G064611.
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