What is the test for determining whether an appointee holds his position de jure?

The early case of People ex rel. Hodgkinson v. Stevens, 5 Hill, 616, has sometimes been referred to as an authority, deciding that the appointee of an officer de facto holds his position de jure. That was a proceeding under a writ of mandamus to compel the delivery of books and papers relating to the office of clerk of the city of Brooklyn. The election of the clerk depended upon the validity of the election of an alderman whose vote figured in the election of the clerk. All that was actually decided in that case was that the title to the office of alderman could not be tried in a collateral proceeding to compel the delivery of books and papers.