Local Government
Complaint against Meza’s council appointment filed in Circuit Court
Acting on behalf of one of what is believed to be three other candidates than the one appointed to fill the vacated Front Royal Town Council seat of now Mayor Chris Holloway, attorney David Downes filed a Complaint for Declaratory Judgement Monday morning, January 11, in Warren County Circuit Court.
The Complaint and accompanying Petition for Injunctive Relief filed by Downes for Paul Lauritz Aldridge lists the Front Royal Town Council and Jacob Louis Meza as defendants, with service to Town Attorney Doug Napier at Town Hall and Meza at a private address. The grounds for the filing echo the points made by Downes in a response to Napier’s Town Press Release opinion Town Charter Section 47 (Chapter 6) did not prevent Meza’s appointment, published last week in the Royal Examiner along with an accompanying story exploring the legal points at issue.

The Warren County Courthouse may be the final arbiter in a decision on the legality of Jacob Meza’s appointment to an elected body he decided not to seek re-election to in November. Royal Examiner File Photos by Roger Bianchini
The complaint states, “This Plaintiff seeks to nullify the appointment of Meza, a former town councilman, as town councilman on January 4, 2021, as ultra virus (beyond the authority of) and unconstitutional, stay any and all (activities) in his official capacity as “councilman” by issuing a writ of mandamus to prohibit any appointments to him under the jurisdiction of the Town Council until after January 1, 2022.”
Asked about the legal weight of the Town Charter in the conduct of Town business earlier, Downes had equated it with the U.S. or State Constitutions that set the basis of legal codes at those levels of government.
Contacted by email Monday, Downes said he would pursue a judicial stay on Meza’s seating and participation in council business pending resolution of the case but was not sure such a court ruling could be achieved prior to tonight’s 7 p.m. town council meeting.
That meeting will be held at the Warren County Government Center under public seating and number restrictions due to the Phase 3 jump in COVID-19 Coronavirus pandemic cases and fatalities nationwide and in Warren County and the Lord Fairfax Health District. It will be broadcast live on the Town website.

In 2020 he decided the time to end his public service had come; however, 2021 brought a change of heart.
Perhaps if seated tonight Meza will have the opportunity to address what changed in his desire to continue serving on council between his fall decision not to run for re-election and the turn of the new year when time constraint and length of public service issues seem to have evaporated.
Also, on tonight’s council agenda is a move to reduce the number of town planning commission members from seven to five. Joseph McFadden’s election to council created a vacancy and recent work session discussion has indicated difficulty in achieving full participation of a seven-member commission. McFadden told Royal Examiner he had considered trying to serve on both town bodies to help fill the planning commission numbers, but had decided against it as stretching him to thin time-wise.
A full reading of the basis of the Complaint filed against Meza’s appointment is posted in the Royal Examiner OPINION section, other linked stories are listed below:
- The Question at Root of Legal Dispute over Meza Council Appointment
- Second attorney disagrees with town attorney interpretation of Town Charter on council appointments
- Meza appointment legality – it’s 2 to 2 as Town finds supporting opinion
- Attorney request Council’s consideration of memorandum regarding appointment of Jacob Meza
- Complaint Filed
