Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 1 of 12

IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI

SONYA WILLIAMS-BARNES PETITIONER

VERSUS CIVIL ACTION NO. ____,('-tt~'...:.._/_7_~::._.__---

JEFFREY HULUM, III RESPONDENT

PETITION FOR JUDICIAL REVIEW

(EXPEDITED AND EMERGENCY REVIEW REQUESTED)

Petitioner, Sonya Williams-Barnes, through undersigned counsel, files this her

Petition for Judicial Review pursuant to Miss. Code. Ann.§ 23-15-961 as follows:

I. PROCEDURAL HISTORY

On March 7, 2019, Williams-Barnes filed her Petition Opposing and

Challenging the Certification of Jeffrey Hulum, III as a Candidate for House

District 119 with the Mississippi Democratic Party Executive Committee

(hereinafter "Executive Committee"). Petitioner's original Petition to the Executive

Committee is attached hereto as Exhibit "N'.

On or about March 13, 2019, the Executive Committee notified Petitioner of the

time and place of the hearing whereupon the Executive Committee would consider

the Petition.

On March 16, 2019 at 11:00 a.m., the Elections Committee of the Mississippi

Democratic Party (hereinafter "Elections Committee") convened a hearing and

allowed the parties to be heard and present evidence. Both parties were present.

Following the presentation of evidence by the parties, the parties were dismissed

and the Elections Committee went into executive session to deliberate. Upon

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 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 2 of 12

information and belief, the Elections Committee voted 4-3 to deny Williams-

Barnes's Petition.

On March 16, 2019 at 4:00p.m., the Elections Committee presented its findings

to the full Executive Committee and the Executive Committee affirmed the ruling

of the Elections Committee.

On March 16, 2019, a representative of the Executive Committee notified the

parties of the Executive Committee's decision.

II. REQUEST FOR JUDICIAL REVIEW

Petitioner is aggrieved by the action of the Executive Committee and asks the

Circuit Clerk to notify the Chief Justice of the Supreme Court pursuant to Miss.

Code. Ann.§ 23-15-961(5) so that a trial may be convened at the "earliest possible

date" and a trial judge may "determine whether [Respondent] is legally qualified to

have his name placed upon the ballot in question."

As shown in Petitioner's original filing with the Executive Committee and

demonstrated at the March 16 hearing, Respondent does not meet the legal

qualifications to serve in the Mississippi House of Representatives as proscribed in

the Mississippi Constitution. Specifically, Respondent does not meet the residency

requirements found in Miss. Const. Ann. Art. 4, § 41.

WHEREFORE, premises considered, Petitioner respectfully requests judicial

review of the March 16, 2019 decision of the Mississippi Democratic Party

Executive Committee, and upon hearing this action, to provide the following relief:

1. Enter an Order establishing that Respondent does not meet the legal

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 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 3 of 12

qualifications to serve in the Mississippi House of Representatives and that

his name should not be included on the August 6, 2019 Primary Ballot;

2. Costs of the proceedings pursuant to Miss. Code Ann.§ 23-15-961(5); and

3. Such other and further relief as may be appropriate under the premises.

Respectfully submitted, this 19th day of March 2019,

Petitioner, Sonya Williams-Barnes

By:-1--~~--~~~~~~~
Brandon C. Jones

Brandon C. Jones, MS Bar No. 101911

Baria-Jones, PLLC
308 East Pearl Street, Suite 302
Jackson, MS 39211
Ph. (601) 948-6016; Fx. (601) 948-0306
Email: bjones@barialaw .com

3
 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 4 of 12

BEFORE THE MISSISSIPPI DEMOCRATIC PARTY

IN THE MATTER OF THE ELECTION

OF THE HOUSE OF REPRESENTATIVES, DISTRICT 119

JEFFREY HULUM, Ill

RESPONDENT

PETITION OPPOSING AND CHALLENGING THE CERTIFICATION OF JEFFREY

HULUM, Ill AS A CANDIDATE FOR HOUSE DISTRICT 119

COMES NOW, SONYA WILLIAMS BARNES ("Petitioner"), and files this Petition
Opposing and Challenging the Certification of Jeffrey Hulum, Ill as a Candidate for
the 2019 Primary for House District 119 and in support of his Petition, would
respectfully show unto the Court the following,· to-wit:

Petitioner, Sonya Williams Barnes is an adult resident Harrison County, House of

Representatives District 119 of the State of Mississippi and a candidate for House
District 119.

Respondent, Jeffrey Hulum, Ill is an adult resident of the State of Texas whose
place of residence is 6012 Bridgewood Drive, Killeen, Texas.

On or around January 15, 2019, Jeffrey Hulum, Ill qualified with the Mississippi
Democratic Party as a candidate for the 2019 Primary for House District 119.

Exhibit "A"
 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 5 of 12

The Mississippi State Constitution provides the requirements for Mississippi

House of Representatives. In order to seek the office of House of Representatives
you must be a qualified elector and resident citizen of the state for four years, at
least 21 years old, and a resident of the district represented for two years before
the election. Miss. Const. of 1890, Art. IV, 8 41.

The Respondent has been a resident of the State of Texas for a least ten (10)
years prior qualifying as a candidate. Jeffrey Hulum, Ill has filed and claimed
homestead in Bell County, Texas since 2008. See Bell County, Texas Tax Records
as Exhibit "A" and is incorporated herein by reference.

The Mississippi Supreme Court has held that the general rule in this state is that
there is a rebuttable presumption that one's domicile and residence are where his
homestead exemption is filed. See Hinds County Election Comm'n v. Brinston, 671
So.2d 667 (Miss.1996}. Young v. Stevens, 698 So. 2d 1260 (Miss., 2007}.

It is clear that the Respondent does not meet the requirement as set out by the
Constitution.

In addition, upon a hearing of this matter more evidence will be submitted to

support the fact that the Respondent is not a resident of the State of Mississippi
and/or House District 119.

WHERERFORE, PREMISESES CONSIDERED, Petitioner prays that Respondent,

Jeffrey Hulum, Ill be disqualified as a candidate for House District 119.
 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 6 of 12

RESPECTFULLY SUBMITIED, this the rj}.J.. day of March 2019

SONYA WILLIAMS BARNES, Petitioner

2317 Searle Avenue

Gulfport, Mississippi 39507

 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 7 of 12

STATE OF MISSISSIPPI
COUNTY OF HINDS

PERSONALLY APPEARED BEFORE ME, the undersigned authority in and for the jurisdiction
aforesaid, the within named SONYA WILLIAMS BARNES who, after being by me first duly sworn, did state
on her oath that the matters and facts contained in the above and foregoing Petition are true and
t as therein stated.

GIVEN under my hand and official seal, this the·jib day of March, 2019.

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 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 8 of 12

Propl:'!rty SHarch > 383764 HLJllJM, JEffHEY Ill for Yt-'!ar 2015 r.l~ Y<?dr: 2015

Aeeount··
Property 10: 383764 Legal Description: BRIDGEWOOD ADDITION PHASE II, BLOCK 008, LOT
0050
Geographic ID: 0664002541 Zoning:
Type: Real Agent Code:
Property Use Code:
Property Use Description:

Protest
Protest Status:
Informal Date:
Formal Date:

Location
Address: . ;~ltl Mapsco:
·;:~~-~-.,. . . . . . . .
Neighborhood: "~~-~-.,._JD: 28C08
Neighborhood CD: BRDGEBRIC

Owner
Name: Owner 10: 621494
·:~~:·····;~
Mailing Address:

V11lues

(+)Improvement Hom·esite Value: + $131,800

(+)Improvement Non-Homesite Value: + $0
(+)Land Homesite Value: + $17,250
(+)land Non-Homesite Value: + $0 Ag I Timber Use Value
(+)Agricultural Market Valuation: + $0 $0
(+)Timber Market Valuation: + $0 $0

(=)Market Value: = $149,050

(-) Ag or Timber Use Value Reduction: - $0

(==)Appraised Value: = $149,050

(-)HSCap: $0

(=)Assessed Value: :::: $149,050

raxiii;~ Jurisdiction
Owner: HULUM, JEFFREY Ill
%Ownership: 100.000000()()0()9(,
Total Value: $149,050
https://propaccess.trueautomation.com/clientdb/Property.aspx EXHIBIT A 1/5
 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 9 of 12
Bell Ct\D

Property

· ·Aeeount-
Property ID: 383764 legal Description: BRIOGEWOOD ADDITION PHASE II, BLOCK 008, LOT
0050
Geographic ID: 0664002541 Zoning:
Type: Real Agent Code:
Property Use Code:
Property Use Description:

Protest
Protest Status:
Informal Date:

.
Formal Date:

Location
Address: -~~ -· Mapsco:

....
Neighborhood: BRIOGEWOOD 1-3 BRICK VENEER Map ID: 28C08
Neighborhood CD: BROGE BRIC

Owner
Name: ,_··~··· ;
Mailing Address: ~···-/ . ''jjjQ"'( fliliilil--:»:e:·

Values

(+)Improvement Homesite Value: + $137,275

(+) Improvement Non-Homesite Value: + $0
(+)land Homesite Value: + $17,250
(+}Land Non-Homesite Value: + $0 Ag I Timber Use Value
(+) Agricultural Market Valuation: + $0 $0
(+)Timber Market Valuation: + $0 $0

(=) Market Value: = $154,525

(-) Ag or Timber Use Value Reduction: $0

(=)Appraised Value: = $154,525

H HSCap: $0

(=) Assessed Value: = $154,525

Taxing Jurisdiction
Owner: HUlUM, JEFFREY Ill
%Ownership: 100.0000000000%
Total Value: $154,525

https://propaccess.trueautomation.com/cfientdb/Property.aspx
EXHIBIT A 1/5
 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 10 of 12

PropNty

·Aeeeunt- -- ··- · ··
Property ID: 383764 legal Description: BRIDGEWOOD ADDITION PHASE II, BLOCK 008, LOT
0050
Geographic ID: 0664002541 Zoning:
Type: Real Agent Code:
Property Use Code:
Property Use Description:

Protest
Protest Status:
Informal Date:
Formal Date:

Location
Address: Mapsco:

Neighborhood: BRIDGEWOOD 1-3 BRICK VENEER Map ID: 28C08

Neighborhood CD: BRDGE BRIC

Owner
Name:
Mailing Address:
~~,­
··{·~·~:~. ·••r ,._:cL•}
~'

Values

(+) Improvement Homesite Value: + $147,041

(+)Improvement Non-Homesite Value: + $0
(+)land Homesite Value: + $17,250
(+) Land Non-Homesite Value: + $0 Ag I Timber Use Value
(+)Agricultural Market Valuation: + $0 $0
(+)Timber Market Valuation: + $0 $0

(=} Market Value: = $164,291

(-) Ag or Timber Use Value Reduction: - $0

(=) Appraised Value: $164,291

(-)HSCap: $0

(=) Assessed Value: = $164,291

Taxing Jurisdiction
Owner: HULUM, JEFFREY Ill
% Ownership: 100.0000000000%
Total Value: $164,291
https:l/propaccess.trueautomaHon.com/clientdb/Property.aspx EXHIBIT A 1/5
 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 11 of 12
Bell f:J\0

Propctty

. AG&etiAt-
Property ID: 383764 Legal Description: BRIDGEWOOD ADDITION PHASE II, BLOCK 008, lOT
0050
Geographic ID: 0664002541 Zoning:
Type: Real Agent Code:
Property Use Code:
Property Use Description:

Protest
.Protest Status:
Informal Date:
Formal Date:
location
i........ Mapsco:

Neighborhood: BRIOGEWOOD 1-3 BRICK VENEER Map ID: 28C08

Neighborhood CD: BROGE BRIC
Owner
·-··- -- ·.-~-·... . ~--·

~--· Owner 10: 621494

Mailing Address: ~g... ".<'·}5ff •o· (-,..

Values

(+)Improvement Homesite Value: + $149,948

(+)Improvement Non-Homesite Value: + $0
(+)land Homesite Value: + $17,250
(+)Land Non-Homesite Value: + $0 Ag I Timber Use Value
(+)Agricultural Market Valuation: + $0 $0
(+)Timber Market Valuation: + $0 $0

(=) Market Value: = $167,198

(-) Ag or Timber Use Value Reduction: - $0

(=)Appraised Value: = $167,198

(-) HS Cap: $0

(=)Assessed Value: = $167,198

faxing Jurisdiction
Owner: HULUM, JEFFREY Ill
%Ownership: 100.()()()()0{)()()
Total Value: $167,198
https://propaccess.trueautomation.com/cllentdbiProperty.aspx EXHIBIT A 1/5
 Case: 25CI1:19-cv-00176-LER Document #: 3 Filed: 03/19/2019 Page 12 of 12

Property Searcit nesults >'3fJ~1fi4·;HOJ.UM, J£ffRf.V tn for Yeart,lxYNI fal¢9

20Hl

Account
Property ID: 383764 legal Description: BRIDGEWOOD ADDmON PHASE II, BLOCK 008, LOT
0050
Geographic 10: 0664002541 Zoning:
Type: Real Agent Code:
Property Use Code:
Property Use Description:

Protest
Protest Status:
Informal Date:
Formal Date:

location
Address: -. ~·-·
Mapsco:
.~. ··-~;;,:'
Neighborhood: BRIOGEWOOD 1-3 BRICK VENEER Map ID: 28C08
Neighborhood CD: BROGEBRIC

OWner
Name: ~fD;.>·'

Mailing Address: .;~;wp!: ..

Val lies

(+)Improvement Homesite Value: + N/A

(+)Improvement Non-Homesite Value: +
(+) land Homesite Value:
(+)land Non-Homesite Value:
(+)Agricultural Market Valuation:
(+)Timber Market Valuation:
N/A
+ N/A
+ N/A Ag I Timber Use Value
+ N/A N/A
+ N/A N/A

(=) Market Value: = N/A

(-) Ag or Timber Use Value Reduction: - N/A

(=)Appraised Value: ::: N/A

H HSCap: N/A

(=)Assessed Value: = N/A

Taxing Jurisdiclivn
Owner: HULUM, JEFFREY Ill
% Ownership: 100.0(){)()()()()()(
https://propaccess.trueautomatlon.com/clientdbiProperty.aspx?prop_ld=383764&year=2019
EXHIBIT A 1/5