^ -. CLERK OF PO^^^T SUPREME COUR r OF O^^^ IN THE SUPREME COURT OF STATE ex rel. STEVEN LINNAI3ARY ) Case No.
|
|
- Winifred Carr
- 5 years ago
- Views:
Transcription
1 ^ -. IN THE SUPREME COURT OF STATE ex rel. STEVEN LINNAI3ARY Case No Relator, vs. JON HUSTED Respondent. Original Action in Mandamus Expedited Election Case Under S.Ct.Prac.R RELATOR'S MOTION FOR RECONSIDERATION Mark G. Kafantaris (# City Park Avenue Columbus, Ohio Tel: ( Fax: ( mark!cr^kafantaris.com Mark R. Brown (# East Broad Street Coluznbus, OFT Tel: ( Fax: ( mbrownnqlaw.capita1.edu Counsel for Relator Michael DeWine Attorney General of Ohio Eric E. Murphy (#83284 State Solicitor - Counsel of Record Stephen P. Carney (#63460 Deputy Solicitor Kristopher J. Armstrong (#77799 Assistant Attorney General 30 East Broad Street, 17th Floor Columbus, Ohio Tel: ( Fax: ( eric.nlurh'a.ohioattorneygeneral o_v Counselfor Respondent APR 13 " CLERK OF PO^^^T SUPREME COUR r OF O^^^
2 RELATOR'S MOTION FOR RECONSIDERATION Relator, Steven Linnabary, moves the Court for reconsideration of its decision of April 3, 2014 denying him a writ of mandamus pursuant to S.Ct.Prac.R, 12.08(B. Relator specifically requests that the Court reconsider the issue of Mr. Akers' standing. The Court found that it need not resolve this thorny question insofar as R.C (A allows Respondent to accept petitions unless "(3 the candidate's candidacy or the petition violates the requirements of this chapter, Chapter 3513 or the Revised Code, or any other requirements establislied by law." State ex r el. Linnabcziy v. Husted, Slip Opinion No Ohio-1417, ',118, 19. But Respondent had already fulfilled this obligation when he certified Relator's candidacy as the Libertarian candidate for the Office of Attorney General of Ohio. It was only in the context of a protest that Respondent reconsidered his earlier decision and removed Relator from the ballot on the grounds raised exclusively by Mr. Akers. This is because Respondent does not enforce the employment disclosure unless a protest is filed. Relator's Exhibit G at -9. This is so, remarkably, even when Respondent knows that R.C (E(1 has been clearly violated or is incomplete. Icl. It is no wonder Respondent has never had occasion to invalid part-petitions on this basis until this very protest. And this is consistent with the directives of Respondent's predecessors who specifically instructed boards of election not to invalided part-petitions because the employment disclosure was incomplete. See Ohio Secretary of State Directive (Instructions for Examining State Issue Petition Papers (Aug. 21, 2006, at page 3 of 5 ("Do not invalidate a. part-petition if the employer infornnation statemertt... is blank or incomplete, does not match or correspond with the information provided by 2
3 the circulator in the compensatioii statement, or is otherwise improperly filled out."; Directive (Sept. 10, 2007 (Instructions for Exarnining State Issue Petition Papers, at page 3 of 5 (same. i1^tr. Damschroder explained that Respondent has "taken a different approach as it relates to communicating instructions to the boards of elections." Relator's Exhibit G at 14. Instead of issuing different directives for the review of each petition that's filed, as was done byrespondent's predecessors (see e.g. Directives and only one directive is issued that goverrzs all of the petitions. Id. Mr. Damschroder could not recall the number of that directive but nonetheless testified that the instructions contained in Directives and were, in spirit, the same as in the omnibus directive he was referring to. Id. at 15. Thus, while Respondent's earlier directives may not have been in force, it's clear from Mr. Damschroder's testimony that the policy remained not to invalidate part-petitions that contained blank or incomplete employment disclosures. The only time R.C (E(1 has ever been enforced against a candidate, Mr. Damschroder acknowledged, is now with Gregory Felsoci's protest against Charlie Earl and Mr. Akers' protest against Relator. Consequently, identical candidates who use the same circulator, Mr. Damschroder admitted, will see disparate applications of R.C (E(1. Id. at 12. One wheis protested, like Relator, is removed from the ballot; the other who is not is allowed to compete in the election. Id.. Respondent's litigation-position before this Court, that it can and must enforce violations of R.C (F_,(1 even in the absence of a protestor with proper standing pursuant to R.C (A(3, also directly contradicts Mr. Damschroder's testimony that "the duty of the Secretary is to aggregate the results of the valid and 3
4 invalid signatures." Id. at 9. Pressed by Judge Watson about how Respondent could enforce a law in the context of protest that he did not enforce on his own, Mr. Damshroder reiterated: "... the duty of the secretary in statewide candidates and on statewide issue petitions is to aggregate the information from the boards of elections. We don't conduct any review, pro forma or otherwise, of the individual partpetition.s." Id. at 47. But Judge Watson was still perplexed and asked "so it's at the whim of somebody brining a protest to determine whether or not Ohio election law is enforced? Id. at Mr. Damshroder's response is even more telling: "I would say that it's up to a protestor to decide whether or not the protestor believes there would be enough invalid signatures to overturn the secretary's aggregation results froin the boards of elections." AZ Respondent's chief elections officer could not have been clearer: Respondent merely aggregates part-petitions and does not enforce the employment statute unless a protestor decides to bring the protest. To the extent R.C (A(3 allows Respondent to enforce the employment disclosure and invalidate the part-petitions on this basis alone, it appears that Respondent has delegated entirely this duty to protestors. The result is that a protest is the sine qua non of R.C (E(1'senforcement.. The procedural posture of this case, together with the fact that no other candidate has ever been disqualified on this basis until now, confirnis as much. Respondent's position, as adopted by the Court, that he could have enforced the employment statute himself after his earlier certificatioti of Relator's candidacy upon learning of the purported illegality alleged by Mr. Akers, regardless of standing, renders the party affiliation language in paragraph 13 of R.C meaningless. If anyone can alert Respondent to a deficiency that he himself overlooked, it makes 4
5 little sense for the legislature to have required that a "member of the same political party" bring the protest. After all, R.C and R.C have never allowed a protestor to challenge something that could not have been independently enforced by Respondent. They merely allow a protestor to allege deficiencies that are squarely the province of Respondent. At best, Respondent could have enforced R.C (E(1 himself but chose not to do so when he certified Relator's candidacy. Mr. Damshroder's testimony establishes that Respondent will only do so when faced with a protest, and this is the case even wlien Respondent knows that the employment disclosure has not been complied with. Relator's Exhibit G at 8-9. Relator will not rehash the ultimate issue of wl ether Mr. Akers has standing to protest his candidacy insofar as it has already been fully briefed by the parties. He incorporates his argument oty this point from his merit brief as if fully rewritten hereizi. 1V1-IEREFGRE, Relator prays that the Court reconsider its decision and issue a writ of mandamus compelling Respondent to restore him to the May 6, 2014 primary. 5 Respectfully submitted, A^ Mark G. Kafantaris (# City Park Avenue Columbus, Ohio 'Tel: ( Fax: ( mark^c^kafantaris.com Mark R. Brown (# East Broad Street Columbus, (J:H Tel: ( Fax: ( mbrownlajaw.cavital.edu Coun.sel for Relator
6 CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing will be served by electronic mail on the date of filing to Eric iviurphy, Counsel for Respondent, at eric.mujphv@ohioattorneyg^ eergov; and John Zeiger, Counsel for Amicus Curie Gregory Felsoci, at zeiger(a-litohio.com, pursuant to S.Ct.Prac.tt (C. Mark G. Kafantaris
Case: Document: 18-1 Filed: 09/11/2014 Page: 1
Case: 14-3877 Document: 18-1 Filed: 09/11/2014 Page: 1 Case No. 14-3877 IN THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT OHIO STATE CONFERENCE OF : THE NATIONAL ASSOCIATION : On Appeal from
More informationSLIP OPINION NO OHIO-224 THE STATE EX REL. FOCKLER ET AL.
[Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as State ex rel. Fockler v. Husted, Slip Opinion No. 2017-Ohio-224.] NOTICE This slip opinion is subject to formal
More informationCase: 2:13-cv MHW-TPK Doc #: 130 Filed: 07/08/14 Page: 1 of 9 PAGEID #: 2883
Case: 2:13-cv-00953-MHW-TPK Doc #: 130 Filed: 07/08/14 Page: 1 of 9 PAGEID #: 2883 LIBERTARIAN PARTY OF OHIO, et al., and ROBERT HART, et al., UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN
More informationSupreme Court of Ohio Clerk of Court - Filed September 12, Case No IN THE SUPREME COURT OF OHIO
Supreme Court of Ohio Clerk of Court - Filed September 12, 2015 - Case No. 2015-1422 IN THE SUPREME COURT OF OHIO STATE OF OHIO, ex rel. : CITY OF YOUNGSTOWN, : : Relator, : Case No. 2015-1422 : v. : Original
More informationSLIP OPINION NO OHIO-5794 THE STATE EX REL. COOVER ET AL.
[Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as State ex rel. Coover v. Husted, Slip Opinion No. 2016-Ohio-5794.] NOTICE This slip opinion is subject to formal
More informationSupreme Court of Ohio Clerk of Court - Filed August 08, Case No IN THE SUPREME COURT OF OHIO. CASE NO Plaintiff-Appellant
Supreme Court of Ohio Clerk of Court - Filed August 08, 2016 - Case No. 2013-1619 IN THE SUPREME COURT OF OHIO STATE OF OHIO CASE NO 2013-1619 Plaintiff-Appellant v. MATTHEW T. MOLE Defendant-Appellee
More informationUNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT : : : : : : : : : : : : : : : :
UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT LIBERTARIAN PARTY OF OHIO, KEVIN KNEDLER, AARON HARRIS, CHARLIE EARL, Plaintiffs-Appellants, -vs- JON HUSTED, Ohio Secretary of State, Defendant-Appellee,
More informationCase: 2:13-cv MHW-TPK Doc #: 271 Filed: 12/03/14 Page: 1 of 9 PAGEID #: 7318
Case 213-cv-00953-MHW-TPK Doc # 271 Filed 12/03/14 Page 1 of 9 PAGEID # 7318 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION LIBERTARIAN PARTY OF OHIO, et al., Plaintiffs, -vs-
More informationUNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT. v. No Appellee-Intervenor-Defendant.
UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT LIBERTARIAN PARTY OF OHIO, KEVIN KNEDLER, CHARLES EARL, AARON HARRIS, Appellants-Plaintiffs, v. No. 14-3230 JON HUSTED, in his Official Capacity as
More informationCase: 2:13-cv MHW-TPK Doc #: 91 Filed: 03/25/14 Page: 1 of 26 PAGEID #: 2237
Case 213-cv-00953-MHW-TPK Doc # 91 Filed 03/25/14 Page 1 of 26 PAGEID # 2237 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION LIBERTARIAN PARTY OF OHIO, et al, -vs- Plaintiffs, JON
More informationSeptember 10, 2007 TO: BOARDS OF ELECTIONS Members, Directors & Deputy Directors RE: Referendum Petition of Sub. S.B. No.
JENNIFER BRUNNER OHIO SECRETARY OF STATE 180 East Broad Street, 15th ;floor Columbus, Ohio 43215-3726 USA TeL: 1 614-466-2655 Fax: 1 614 644-0649 v-jww,sos.state,oh.us www.sos.state.oh.us DIRECTIVE 2007-14
More informationNO UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT LIBERTARIAN PARTY OF OHIO; KEVIN KNEDLER; AARON HARRIS; CHARLIE EARL,
NO. 14-3230 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT LIBERTARIAN PARTY OF OHIO; KEVIN KNEDLER; AARON HARRIS; CHARLIE EARL, Plaintiffs-Appellants, v. JON HUSTED, Secretary of State, Defendant-Appellee,
More informationIN THE COURT OF COMMON PLEAS HAMILTON COUNTY, OHIO : : : : : : : : : : : : : : : : : : : : : : : : : : : :
David R. Langdon (0067046) Thomas W. Kidd, Jr. (0066359) Bradley M. Peppo (0083847) Trial Attorneys for Plaintiffs IN THE COURT OF COMMON PLEAS HAMILTON COUNTY, OHIO LETOHIOVOTE.ORG 208 East State Street
More informationSupreme Court of Ohio Clerk of Court - Filed September 03, Case No IN THE SUPREME COURT OF OHIO
Supreme Court of Ohio Clerk of Court - Filed September 03, 2015 - Case No. 2015-1456 IN THE SUPREME COURT OF OHIO STATE OF OHIO ex. rel. KATHRYN WILEN 867 Stonewater Drive Kent, OH 44240 and WILLIAM WILEN
More informationF LDD NOV CLERK OF COURT SUPREME COURT OF OHIO. STATE OF OHIO, ex rel. DANA SKAGGS, et al.,
IN THE SUPREME COURT OF OHIO STATE OF OHIO, ex rel. DANA SKAGGS, et al., Relators, 8--22206 vs. Case No. JENNIFER L. BRUNNER ORIGINAL ACTION IN SECRETARY OF THE STATE OF MANDAMUS OHIO, et al., Respondents.
More informationUNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION
Case: 2:13-cv-00953-MHW-TPK Doc #: 3 Filed: 09/26/13 Page: 1 of 11 PAGEID #: 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION LIBERTARIAN PARTY OF OHIO, et al. Plaintiffs, Case
More informationPart Description 1 10 pages 2 Exhibit Consent Decree 3 Affidavit Knedler 4 Affidavit Harris 5 Affidavit Earl 6 Affidavit Redpath
Libertarian Party of Ohio et al v. Husted, Docket No. 2:13-cv-00953 (S.D. Ohio Sept 25, 2013), Court Docket Part Description 1 10 pages 2 Exhibit Consent Decree 3 Affidavit Knedler 4 Affidavit Harris 5
More informationCase: 2:13-cv MHW-TPK Doc #: 57-3 Filed: 03/07/14 Page: 1 of 18 PAGEID #: Before Ohio Secretary of State. Jon A.
Case: 2:13-cv-00953-MHW-TPK Doc #: 57-3 Filed: 03/07/14 Page: 1 of 18 PAGEID #: 1083 Before Ohio Secretary of State Jon A. Husted In Re: Protest of Carl Michael Akers Challenging ) Certification of Steven
More informationF^F JAN CLERK OF COURT ORIGINAL SUPREME COURT OF OHIO IN THE SUPREME COURT OF OHIO. CHARLES E. WILSON, et al., Relators, Original Action
ORIGINAL IN THE SUPREME COURT OF OHIO CHARLES E. WILSON, et al., V. Relators, Case No. 2012-0019 Original Action GOVERNOR JOHN KASICH, et al., Respondents. RESPONDENT SECRETARY OF STATE JON ITUSTED'S SUBMISSION
More informationCase: 1:12-cv SJD Doc #: 69 Filed: 02/28/14 Page: 1 of 11 PAGEID #: 697
Case 112-cv-00797-SJD Doc # 69 Filed 02/28/14 Page 1 of 11 PAGEID # 697 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OHIO WESTERN DIVISION FAIR ELECTIONS OHIO, et al., Plaintiffs, v. JON
More informationCase: 2:15-cv MHW-NMK Doc #: 20 Filed: 07/01/15 Page: 1 of 10 PAGEID #: 143
Case: 2:15-cv-01802-MHW-NMK Doc #: 20 Filed: 07/01/15 Page: 1 of 10 PAGEID #: 143 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION THE OHIO ORGANIZING : COLLABORATIVE,
More informationPRELIMINARY INJUNCTION and TRO REQUESTED /
Case: 2:18-cv-00966-EAS-EPD Doc #: 1 Filed: 08/28/18 Page: 1 of 20 PAGEID #: 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION WILLIAM SCHMITT, JR., CHAD THOMPSON, AND DEBBIE BLEWITT,
More information1N THE SUPREME COURT OF OHIO. CASE NO Cleveland, Ohio 44104, RELATORS' MOTION FOR Relator, ) RECONSIDERATION
1N THE SUPREME COURT OF OHIO STATE OF OHIO ex rel. TERRANCE McCLAIN, 11091 Reservoir Place Drive CASE NO. 2009-1413 Cleveland, Ohio 44104, RELATORS' MOTION FOR Relator, ) RECONSIDERATION vs. Expedited
More informationCase: Document: 20 Filed: 09/11/2014 Page: 1 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT. Filed: September 11, 2014
Case: 14-3877 Document: 20 Filed: 09/11/2014 Page: 1 Deborah S. Hunt Clerk UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT 100 EAST FIFTH STREET, ROOM 540 POTTER STEWART U.S. COURTHOUSE CINCINNATI,
More informationCase: 2:16-cv GCS-EPD Doc #: 15 Filed: 04/08/16 Page: 1 of 8 PAGEID #: 117
Case: 2:16-cv-00303-GCS-EPD Doc #: 15 Filed: 04/08/16 Page: 1 of 8 PAGEID #: 117 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO, EASTERN DIVISION OHIO A. PHILIP RANDOLPH INSTITUTE, et al.
More informationIN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION STATE ex rel. SKAGGS, et al. v. Relators, JENNIFER L. BRUNNER SECRETARY OF STATE OF OHIO, et al., Respondents. Case
More informationCase: 2:06-cv ALM-TPK Doc #: 346 Filed: 11/01/12 Page: 1 of 11 PAGEID #: 12588
Case: 2:06-cv-00896-ALM-TPK Doc #: 346 Filed: 11/01/12 Page: 1 of 11 PAGEID #: 12588 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION THE NORTHEAST OHIO COALITION
More informationCase: 2:13-cv MHW-TPK Doc #: 73 Filed: 03/16/14 Page: 1 of 13 PAGEID #: 2038
Case: 2:13-cv-00953-MHW-TPK Doc #: 73 Filed: 03/16/14 Page: 1 of 13 PAGEID #: 2038 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION LIBERTARIAN PARTY OF OHIO, et al., : : Case No.
More informationCase: 2:13-cv MHW-TPK Doc #: Filed: 08/18/14 Page: 1 of 18 PAGEID #: Before Ohio Secretary of State. Jon A.
Case: 2:13-cv-00953-MHW-TPK Doc #: 166-2 Filed: 08/18/14 Page: 1 of 18 PAGEID #: 3308 Before Ohio Secretary of State Jon A. Husted In Re: Protest of Carl Michael Akers Challenging ) Certification of Steven
More informationIN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO
IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO LIBERTARIAN PARTY OF OHIO, ) CASE NO.: 2586 Tiller Lane, Suite 2K ) Columbus, Ohio 43231-2265 ) ) JUDGE: Plaintiff, ) C O M P L A I N T ) (Claim of Unconstitutionality
More informationSupreme Court of Ohio Clerk of Court - Filed September 04, Case No IN THE SUPREME COURT OF OHIO
Supreme Court of Ohio Clerk of Court - Filed September 04, 2015 - Case No. 2015-1371 IN THE SUPREME COURT OF OHIO STATE OF OHIO ex rel. WALKER, et al., ) ) Relators, ) Case No. 2015-1371 ) v. ) ) Expedited
More informationSupreme Court of Ohio Clerk of Court - Filed March 18, Case No IN THE SUPREME COURT OF OHIO
Supreme Court of Ohio Clerk of Court - Filed March 18, 2015 - Case No. 2015-0303 IN THE SUPREME COURT OF OHIO R. LOTUS JUSTICE, et al., Relators, Case No. 2015-0303 v. UNITED STATES, et al., Respondents.
More informationSupreme Court of Ohio Clerk of Court - Filed August 19, Case No IN THE SUPREME COURT OF OHIO
Supreme Court of Ohio Clerk of Court - Filed August 19, 2015 - Case No. 2015-1371 IN THE SUPREME COURT OF OHIO State of Ohio, ex rel Renee Walker 2933 County Road 3 Swanton, OH 43558 and John P. Ragan
More informationUNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT. Appellants-Plaintiffs, V. CASE NO Appellee-Defendant, Appellee-Intervenor-Defendant.
UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT LIBERTARIAN PARTY OF OHIO, et al., Appellants-Plaintiffs, V. CASE NO. 15-4270 JON HUSTED, in his Official Capacity as Ohio Secretary of State, and THE
More information12PREM;^O ^, Q^0 APR CLERK OFCOURT IN THE SUPREME COURT OF OHIO
[State of Ohio ex rel.]david Fox, Relator, IN THE SUPREME COURT OF OHIO 2008 vs. Case No. 08-0626 Franklin County Common Pleas Court, Original Complaint in Mandamus Respondent. MOTION TO DISMISS OF RESPONDENT
More informationUNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT. Case No LIBERTARIAN PARTY OF OHIO; KEVIN KNEDLER; AARON HARRIS; CHARLIE EARL,
UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT Case No. 16-3537 LIBERTARIAN PARTY OF OHIO; KEVIN KNEDLER; AARON HARRIS; CHARLIE EARL, Plaintiffs-Appellants, V. JON HUSTED, Secretary of State, Defendant-Appellee,
More informationIMM FED 13 Z013 CLERK OF COURT SUPR^ME COURT F 0H1 IN THE SUPREME COURT OF OHIO. FRANCESCA STEINHART, et al., CASE NO
IN THE SUPREME COURT OF OHIO IMM FRANCESCA STEINHART, et al., Relators, vs. CASE NO. 2013-0102 Original Action in Mandamus THE OHIO DEPARTMENT OF JOB AND FAMILY SERVICES, et al. Respondents. RESPONDENT
More informationCase: 1:12-cv SJD Doc #: 54 Filed: 02/21/13 Page: 1 of 9 PAGEID #: 652
Case 112-cv-00797-SJD Doc # 54 Filed 02/21/13 Page 1 of 9 PAGEID # 652 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION Fair Elections Ohio, et al., Plaintiffs, Jon
More information3Jn trye 6Upreme Court of bid. Court of Appeals Case Defendants-Appellants. No. CA
3Jn trye 6Upreme Court of bid PIETRO CRISTINO, et al., Case No. 2007-0152 V. Plaintiffs-Appellees, ADMINISTRATOR, OHIO BUREAU OF WORKERS' COMPENSATION, et al., On Appeal from the Cuyahoga County Court
More informationIN THE SUPREME COURT OF OHIO
IN THE SUPREME COURT OF OHIO STATE ex rel. FOCKLER, et al., Relators, V. CASE NO. 2016-1863 HUSTED, Respondent. ORIGINAL ACTION IN MANDAMUS RELATORS' MERIT BRIEF Mark R. Brown Halli Watson Bar No. 81941
More informationIN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION : : : : : : : : : : : : :
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION THE STATE OF OHIO ex rel. DANA SKAGGS, et al., v. Plaintiff - Relator, JENNIFER L. BRUNNER SECRETARY OF THE STATE
More informationIN THE SUPERIOR COURT OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA ) ) ) ) ) ) ) ) ) ) ) )
1 2 3 4 Michael Kielsky, SBN #021864 4802 E. Ray Rd., #23-255 Phoenix, AZ 85044 TEL (602 903-5123 FAX (602 532-7777 Attorney for Plaintiff 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27
More informationIN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION REPUBLICAN PARTY OF OHIO : OF OHIO, et al., : : Plaintiffs, : : Case No. 2:08-cv--00913 v. : : JENNIFER BRUNNER :
More informationp L DD 0q^^/41, CLERK OF COURT SUPREME COURT OF OHIO IN THE SUPREME COURT OF OHIO State ex rel., McGRATH Case No
IN THE SUPREME COURT OF OHIO 0q^^/41, State ex rel., McGRATH V. Relato THE EIGHTH DISTRICT COURT OF APPEALS, Case No. 2010-1860 Original Action in Mandamus and Procedendo Respondent. MOTION TO DISMISS
More informationIN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION
IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION LIBERTARIAN PARTY OF OHIO, et al., Plaintiffs, and ROBERT M. HART, Individually and ROBERT FITRAKIS, on behalf of THE GREEN
More informationAlso Present: Carrie Kuruc, Senior Elections Counsel
BEFORE THE OHIO BALLOT BOARD Meeting of the Ohio : Ballot Board Pursuant : to R.C. 3505.062. : PROCEEDINGS before the Ohio Ballot Board, Grant Hearing Room, Ohio Statehouse, 1 Capitol Square, Columbus,
More informationIN THE SUPREME COURT OF OHIO
IN THE SUPREME COURT OF OHIO STATE OF OHIO, ex rel. MARC S. TRIPLETT, Supreme Court No. 332 South Main Street Bellefontaine, Ohio 43311, Relator, ORIGINAL ACTION IN PROHIBITION vs. JOHN L. ROSS, Judge,
More informationCase No IN THE SUPREME COURT OF OHIO STATE EX REL. SCIOTO DOWNS, INC., ET AL., JENNIFER L. BRUNNER, ET AL.,
Case No. 09-1294 IN THE SUPREME COURT OF OHIO STATE EX REL. SCIOTO DOWNS, INC., ET AL., V. Relators, JENNIFER L. BRUNNER, ET AL., Respondents. Original Action Under Section lg, Article II, of the Ohio
More informationIN THE COMMONWEALTH COURT OF PENNSYLVANIA
IN THE COMMONWEALTH COURT OF PENNSYLVANIA In Re The Nomination Petition of Rodney A. Bedow, Sr. for Member of the Republican State Committee from Venango County in the Primary Election of April 27, 2004
More informationDEFENDANT CITY OF LOVELAND S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION
DISTRICT COURT, LARIMER COUNTY, STATE OF COLORADO 201 La Porte Ave., Suite 100 Fort Collins, CO 80521 Tel: 970-494-3500 Plaintiff: LARRY SARNER, an individual, pro se v. Defendants: CITY OF LOVELAND; and
More informationIN THE SUPREME COURT OF OHIO 2013 RESPONDENT'S MOTION TO DISMISS RELATOR'S ACTION IN MANDAMUS
4 I ^^. IN THE SUPREME COURT OF OHIO 2013 Edward Jackson, Case No. 13-0086 -vs- Relator, ORIGINAL ACTION Ronald J. Obrien and Judge David Cain et. al., Respondents.. Court of Appeals Case No. 89AP-1015
More informationSupreme Court of the United States
No. 16-980 ================================================================ In The Supreme Court of the United States --------------------------------- --------------------------------- JON HUSTED, Ohio
More informationCase: 2:16-cv GCS-EPD Doc #: 84 Filed: 10/17/16 Page: 1 of 9 PAGEID #: 23383
Case: 2:16-cv-00303-GCS-EPD Doc #: 84 Filed: 10/17/16 Page: 1 of 9 PAGEID #: 23383 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION OHIO A. PHILIP RANDOLPH INSTITUTE, NORTHEAST
More informationIn the Supreme Court of Ohio
Supreme Court of Ohio Clerk of Court - Filed June 10, 2015 - Case No. 2014-1767 In the Supreme Court of Ohio LELAND EISENBARTH, et al., Plaintiffs-Appellants, v. DEAN REUSSER, et al., Defendants-Appellees.
More informationIN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION
IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION OBAMA FOR AMERICA, Plaintiff, CASE NO. 108CV00562 vs. JUDGE GAUGHAN CUYAHOGA COUNTY BOARD OF ELECTIONS, Defendant ANSWER OF
More information[Cite as State ex rel. Scioto Downs, Inc. v. Brunner, 123 Ohio St.3d 24, 2009-Ohio-3761.]
[Cite as State ex rel. Scioto Downs, Inc. v. Brunner, 123 Ohio St.3d 24, 2009-Ohio-3761.] THE STATE EX REL. SCIOTO DOWNS, INC. ET AL. v. BRUNNER, SECY. OF STATE, ET AL. [Cite as State ex rel. Scioto Downs,
More informationSLIP OPINION NO OHIO-5523 THE STATE EX REL. CITY OF CHILLICOTHE
[Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as State ex rel. Chillicothe v. Ross Cty. Bd. of Elections, Slip Opinion No. 2009-Ohio-5523.] NOTICE This slip opinion
More informationO1.tKK OF COURT ^EK COURT OF OHIO IN THE SUPREME COURT OF OHIO 2012 ^46. Case No STATE OF OHIO,
IN THE SUPREME COURT OF OHIO 2012 F,^ ^rv ^46 STATE OF OHIO, Case No. 11-1473 -vs- Plaintiff-Appellant EMMANUEL HAMPTON, On Appeal from the Franklin County Court of Appeals, Tenth Appellate District Court
More informationSUPREME COURT FOR THE STATE OF OHIO RELATOR S MEMORANDUM IN SUPPORT OF COMPLAINT FOR AN ORIGINAL WRIT OF MANDAMUS
SUPREME COURT FOR THE STATE OF OHIO State ex rel. Ohio Citizen Action ) 614 West Superior Avenue, Suite 1200 ) Cleveland, Ohio 44113 ) ) Case No. Relator, ) v. ) ) J. Kenneth Blackwell ) Ohio Secretary
More informationBEFORE THE BOARD OF ELECTIONS LUCAS COUNTY, OHIO
BEFORE THE BOARD OF ELECTIONS LUCAS COUNTY, OHIO IN RE: REQUEST TO SET DATE / FOR RECALL ELECTION OF / MAYOR CARLETON S. FINKBEINER / / / / Scott A. Ciolek (0082779) / CIOLEK & WICKLUND / 520 Madison Avenue,
More informationCase: 2:13-cv MHW-TPK Doc #: 42 Filed: 12/23/13 Page: 1 of 19 PAGEID #: 781
Case: 2:13-cv-00953-MHW-TPK Doc #: 42 Filed: 12/23/13 Page: 1 of 19 PAGEID #: 781 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION LIBERTARIAN PARTY OF OHIO, et al., ) ) ) Plaintiffs,
More informationSupreme Court of Ohio Clerk of Court - Filed February 10, Case No IN THE SUPREME COURT OF OHIO
Supreme Court of Ohio Clerk of Court - Filed February 10, 2015 - IN THE SUPREME COURT OF OHIO THE STATE OF OHIO ex rel. : PAULETTA HIGGINS, : : Relator, : : v. : Original Action in : Mandamus/Prohibition
More informationNo IN THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT : : : : : : : : : : : : :
No. 15-4270 IN THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT LIBERTARIAN PARTY OF OHIO, ET AL., v. Appellants-Plaintiffs, JON HUSTED, IN HIS OFFICIAL CAPACITY AS OHIO SECRETARY OF STATE, v.
More informationCase No IN THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT. NORTHEAST OHIO COALITION FOR THE HOMELESS, et al., Plaintiffs-Appellees
Case: 12-4354 Document: 63-1 Filed: 02/04/2014 Page: 1 Case No. 12-4354 IN THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT NORTHEAST OHIO COALITION FOR THE HOMELESS, et al., Plaintiffs-Appellees
More informationCase: 1:10-cv SJD Doc #: 35 Filed: 12/30/10 Page: 1 of 10 PAGEID #: 830 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION
Case 110-cv-00820-SJD Doc # 35 Filed 12/30/10 Page 1 of 10 PAGEID # 830 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION TRACIE HUNTER, et al., vs. Plaintiffs, HAMILTON COUNTY BOARD
More informationCase: 1:10-cv SJD Doc #: 35 Filed: 12/30/10 Page: 1 of 10 PAGEID #: 830 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION
Case 110-cv-00820-SJD Doc # 35 Filed 12/30/10 Page 1 of 10 PAGEID # 830 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION TRACIE HUNTER, et al., vs. Plaintiffs, HAMILTON COUNTY BOARD
More information1851 CENTER FOR CONSTITUTIONAL LAW
2015-09-18 Petition 1851 CENTER FOR CONSTITUTIONAL LAW HAND DELIVERED Hon. Mike DeWine Ohio Attorney General State Office Tower 30 E. Broad Street, 17th Floor Columbus, Ohio 43215 Attorney General De Wine:
More informationCounty Referendum Process
County Referendum Process Ventura County Elections Division MARK A. LUNN Clerk-Recorder, Registrar of Voters 800 South Victoria Avenue Ventura, CA 9009-00 (805) 654-664 venturavote.org Revised 0//7 Contents
More informationSupreme Court of Ohio Clerk of Court - Filed March 19, Case No IN THE SUPREME COURT OF OHIO
Supreme Court of Ohio Clerk of Court - Filed March 19, 2015 - Case No. 2015-0173 IN THE SUPREME COURT OF OHIO STATE OF OHIO EX REL. ) CASE NO. 2015-0173 AYMAN DAHMAN, MD, ET AL., ) ) Original Action in
More informationMARCI^G J. MENSEL, CLERK SUPREME COURT OE OHIO. Case. No.
IN THE SUPREME COURT OF OHIO State of Ohio ex rel. Jennifer Brady, -v- Relator, J. Kenneth Blackwell, Secretary of State of Ohio, et al., Case. No. J)6-@9^ 2065 On Direct Appeal From Cuyahoga County Court
More informationIN THE SUPREME COURT OF OHIO RESPONDENT OHIO STATE UNIVERSITY'S MOTION TO DISMISS
IN THE SUPREME COURT OF OHIO CHARLES DAVID FOOCE, Petitioner, CASE NO. 2008-1810 V. THE OHIO STATE UNIVERSITY, Respondent. Original Action in Mandamus RESPONDENT OHIO STATE UNIVERSITY'S MOTION TO DISMISS
More informationOHIO PUBLIC EMPLOYEES RETIREMENT SYSTEM 277 EAST TOWN STREET, COLUMBUS, OH PERS (7377)
OHIO PUBLIC EMPLOYEES RETIREMENT SYSTEM 277 EAST TOWN STREET, COLUMBUS, OH 43215-4642 1-800-222-PERS (7377) www.opers.org MEMORANDUM DATE: August 4, 2006 TO: FROM: OPERS Retirement Board Members Karen
More informationSLIP OPINION NO OHIO-3758 THE STATE EX REL. RESPONSIBLEOHIO ET AL.
[Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as State ex rel. ResponsibleOhio v. Ohio Ballot Bd., Slip Opinion No. 2015-Ohio-3758.] NOTICE This slip opinion
More informationIN THE SUPREME COURT OF OHIO
IN THE SUPREME COURT OF OHIO STATE OF OHIO, ex rel. MARC S. TRIPLETT, Supreme Court No. 332 South Main Street Bellefontaine, Ohio 43311, Relator, ORIGINAL ACTION IN PROHIBITION vs. JOHN L. ROSS, Judge,
More informationNovember 3, 2015 General Election. Candidacy Requirements for General Assembly Offices
1100 Bank Street, 1 st Floor Richmond, VA 23219-3642 12/12/14 November 3, 2015 General Election Candidacy Requirements for General Assembly Offices VOICE: 804-864-8901 TTY TOLL-FREE: 800-260-3466 VOICE
More informationIN THE SUPREME COURT OF OHIO
!r 0r^ IN THE SUPREME COURT OF OHIO STATE EX REL. RICIIARD L. CURLEY, Relator, V. Case No. 2013-1896 Original Action in Replevin NINTH DISTRICT COURT OF APPEALS, Respondent. 1VIOT`ION TO DISMISS OF RESPONDENT
More informationMERIT BRIEF OF APPELLEE, STATE OF OHIO EX REL. KEVIN B. TODD
IN THE SUPREME COURT OF OHIO STATE OF OHIO, EX REL. KEVIN B. TODD ) S.C. CASE NO. 2007-1002 -vs-. Appellee ON APPEAL FROM THE SEVENTH DISTRICT COURT OF APPEALS SHERRY FELGER MAYOR, VILLAGE OF NEW WATERFORD,
More informationIN THE SUPREME COURT OF OHIO
00900 ^k%e IN THE SUPREME COURT OF OHIO NICHOLAS J. KINSTLE ) CASE NO: 13-0735 Relator, VS. ORIGINAL ACTION IN MADAMUS JUERGEN A. WALDICK Prosecuting Attorney ) MOTION TO DISMISS and ) MANDAMUS PETITION
More informationMEETING OF THE OHIO BALLOT BOARD
MEETING OF THE OHIO BALLOT BOARD 1 - - - MEETING of the Ohio Ballot Board, at the Ohio Statehouse, Finan Finance Hearing Room, 1 Capitol Square, Columbus, Ohio, called at 3:00 p.m. on Tuesday, December
More informationCase: 2:13-cv MHW-TPK Doc #: 311 Filed: 07/17/15 Page: 1 of 14 PAGEID #: 7977
Case: 2:13-cv-00953-MHW-TPK Doc #: 311 Filed: 07/17/15 Page: 1 of 14 PAGEID #: 7977 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION LIBERTARIAN PARTY OF OHIO, et al. : : Plaintiffs,
More informationSTATE OF MICHIGAN COURT OF APPEALS
STATE OF MICHIGAN COURT OF APPEALS FAMILIES AGAINST INCINERATOR RISK, WILLIAM RINEY and PAUL FORTIER, UNPUBLISHED July 29, 2004 Plaintiff-Appellants, v No. 245319 Washtenaw Circuit Court PEGGY HAINES,
More informationNo. D-1-GN
No. D-1-GN-10-001924 TEXAS DEMOCRATIC PARTY; BOYD L. RICHIE, IN HIS CAPACITY AS CHAIRMAN OF THE TEXAS DEMOCRATIC PARTY; AND JOHN WARREN, IN HIS CAPACITY AS DEMOCRATIC NOMINEE FOR DALLAS COUNTY CLERK, vs.
More informationIN THE SUPREME COURT OF OHIO
ORIGINAL IN THE SUPREME COURT OF OHIO STATE OF OHIO ex rel. RICHARD F. : Case No. 2013-0295 DAVET P.O. Box 10092 : Original Action in Prohibition and Cleveland, Ohio 44110 : Mandamus Arising From Cuyahoga
More informationIN THE SUPREME COURT OF OHIO RESPONDENT ETNA TOWNSHIP'S ANSWER TO RELATORS' COMPLAINT FOR WRIT OF MANDAMUS
Ls! IN THE SUPREME COURT OF OHIO /n, w" State of Ohio, ex rel. Ascena Retail group, Inc., et al., Relators, Case No.: 14-1013 V. Original action in mandamus City of Reynoldsburg, et al., Respondents. RESPONDENT
More informationIN THE COURT OF COMMON PLEAS OF LUCAS COUNTY, OHIO. Plaintiff v. VERIFIED COMPLAINT FOR STATUTORY DAMAGES. and. Defendants
IN THE COURT OF COMMON PLEAS OF LUCAS COUNTY, OHIO Meghan Gallagher Chairman, Lucas County Republican Party Central Committee 10.S. Superior Toledo, OH 43604 Case No. LUCAS COUNTY BOARD OF ELECTIONS One
More informationIN THE SUPREME COURT OF OHIO. Relators, Respondent.
^ IN THE SUPREME COURT OF OHIO STATE OF OHIO, et rel. CASE NO. MORRIS KINAST, M.D. AND NEUROCARE CENTER, INC. 4105 Holiday St., N.W. P.O. Box 35006 Canton, OH 44375 1 3 O i 5 9 vs. Relators, THE HONORABLE
More informationSTATE OF MICHIGAN COURT OF APPEALS
STATE OF MICHIGAN COURT OF APPEALS D. ETTA WILCOXON, Plaintiff-Appellee, FOR PUBLICATION July 11, 2013 9:10 a.m. V No. 317012 Wayne Circuit Court CITY OF DETROIT ELECTION COMMISSION LC No. 13-007366-AS
More informationrnterv nor-plaintiffs'
Case: 2:13-cv-00953-MHW-TPK Doc #: 170-3 Filed: 08/19/14 Page: 1 of 5 PAGEID #: 3426 LIBERTARIAN PARTY OF OHIO, et al., UNTTtrD STATT]S DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION Ptaintiffs,
More informationAUG CLERK OF COURT SUPREME COURT OF OHIO. COUNSEL FOR RESPONDENTS University of Cincinnati and The Ohio State University
IN THE SUPREME COURT OF OHIO YVETTE BARBARA BALDWIN, Relator, CASE NO. 08-1372 vs. CASE WESTERN RESERVE UNIVERSITY, et al., Respondents. Original Action in Mandamus RESPONDENT UNIVERSITY OF CINCINNATI
More informationIN THE SUPREME COURT OF OHIO. This is a death penalty case.
^^ ^^^^f^^^. IN THE SUPREME COURT OF OHIO STATE OF OHIO, Plaintiff-Appellee, vs. MELVIN BONNELL, Defendant-Appellant. Case No. 2011-2164 On Appeal from the Court of Appeals, Eighth Appellate District,
More informationIn The United States District Court For The Southern District of Ohio Eastern Division
In The United States District Court For The Southern District of Ohio Eastern Division Libertarian Party of Ohio, Plaintiff, vs. Jennifer Brunner, Case No. 2:08-cv-555 Judge Sargus Defendant. I. Introduction
More informationSTATE EX REL. ROBERT HARSH, Respondent. IN TI-IE SUPREME COURT OF OHIO. Relator, Case No Original Action in Mandamus
^':3 ;E :;3;
More informationNO IN THE SUPREME COURT OF THE STATE OF OHIO STATE OF OHIO EXRELATIONE MITCHELL W. ALLEN, Relator,
CASE NO. 07 1291 IN THE SUPREME COURT OF THE STATE OF OHIO STATE OF OHIO EXRELATIONE MITCHELL W. ALLEN, Relator, V. WARREN COUNTY BOARD OF ELECTIONS, ET AL.,, Respondents. ORIGINAL ACTION FOR MANDAMUS
More informationBEFORE THE CHIEF JUSTICE OF THE SUPREME COURT OF OHIO
,r^", BEFORE THE CHIEF JUSTICE OF THE SUPREME COURT OF OHIO JOSHUA O'FARRELL, Contestor, V. AL LANDIS, and Contestee, Case No. 2012-2151 Election Contest Subject to R. C. 3515.08, R. C. 3515.14 and Section
More informationIn the Supreme Court of the United States
No. 14A336 In the Supreme Court of the United States MICHAEL DEWINE, IN HIS OFFICIAL CAPACITY AS OHIO ATTORNEY GENERAL, AND JON HUSTED, IN HIS OFFICIAL CAPACITY AS OHIO SECRETARY OF STATE, v. OHIO STATE
More informationCity Referendum Process
City Referendum Process Ventura County Elections Division MARK A. LUNN Clerk-Recorder, Registrar of Voters 800 South Victoria Avenue Ventura, CA 93009-00 (805) 654-664 venturavote.org Revised 9/5/7 Contents
More informationJAN 2 4 2Q0H. CLHHK OF GouRr SI1PHfMECO URT pf OHIO IN THE SUPREME COURT OF OHIO
STATE OF OHIO EX REL. PHILLIP GROUNDS 14420 Union Road Laurelville, Ohio 43135 Relator, IN THE SUPREME COURT OF OHIO Case No.: Original Action In Mandamus 08-- 188 -v- HOCKING COUNTY BOARD OF ELECTIONS
More informationRECALL ELECTIONS. Summary. Procedures
RECALL ELECTIONS Summary Wisconsin law permits voters to recall elected officials under certain circumstances. Recall is an opportunity for voters to require elected officials to stand for election before
More informationMEMORANDUM. FROM: Pat Wolfe, Director of Elections Michael Sciortino, President of Ohio Association of Elections Officials (OAEO)
Ohio Secretary of State J. Kenneth Blackwell Elections Division - 180 E. Broad St., 15 th Floor, Columbus, OH 43215 Tel. (614) 466-2585 Fax (614) 752-4360 e-mail: election@sos.state.oh.us MEMORANDUM TO:
More informationIN THE COURT OF COMMON PLEAS 1L CUYAHOGA COUNTY, OHIO
97422066 CITY OF CLEVELAND Plaintiff STATE OF OHIO Defendant 97422066 IN THE COURT OF COMMON PLEAS 1L CUYAHOGA COUNTY, OHIO Judge: MICHAEL J RUSSD'AHOGA COUNTY JOURNAL ENTRY 96 DISP.OTHER - FINAL 01/30/2017:
More information