Case: Tomasik v. Goins

3:13-cv-01118 | U.S. District Court for the Middle District of Tennessee

Filed Date: Oct. 9, 2013

Closed Date: Jan. 27, 2014

Clearinghouse coding complete

Case Summary

This is a case about the legality of certain state election laws as applied to the Chairman of the Libertarian Party of Tennessee for the 2013 Tennessee Special General Election for State House District 91 to be held on November 21, 2013 and all subsequent Special General Elections in the State of Tennessee.   On October 9, 2013, the Chairman of the Libertarian Party of Tennessee and a candidate for the office of Tennessee State Representative in State House District 91 for the Special General …

This is a case about the legality of certain state election laws as applied to the Chairman of the Libertarian Party of Tennessee for the 2013 Tennessee Special General Election for State House District 91 to be held on November 21, 2013 and all subsequent Special General Elections in the State of Tennessee.  

On October 9, 2013, the Chairman of the Libertarian Party of Tennessee and a candidate for the office of Tennessee State Representative in State House District 91 for the Special General Election to be held on November 21, 2013, a member of the Libertarian Party of Tennessee who desired to vote for the Chairman of the Libertarian Party of Tennessee, and the Libertarian Party of Tennessee (collectively, “Plaintiffs”) filed this lawsuit in the U.S. District for the Middle District of Tennessee before Judge William J. Haynes, Jr.  Plaintiffs sued the State of Tennessee (“defendant”) under the First and Fourteenth Amendments to the United States Constitution and Title 42, United States Code, § 1983.  Represented by private counsel, Plaintiffs sought a judgment declaring that T.C.A., §§ 2-1-104(a)(14), 2-1-104(a)(24), 2-1 104(a)(31), 2-5-208(d)(1, 2-13-107(a)(2), 2-13-201(a), and 2-14-202 (collectively, “the Statutes”) as applied to Plaintiffs for the 2013 Tennessee Special General Election for State House District 91 and all subsequent Special General Elections in the State of Tennessee were unconstitutional, and a temporary and permanent injunction against defendant from following and enforcing the provisions of the Statutes.  Plaintiffs claimed that without court intervention they would not be able to obtain ballot access with their candidate listed as the Libertarian candidate rather than the Independent candidate for State House District 91 in the Special General Election to be held on November 13, 2012 or subsequent Special General Elections.  In relevant part, the complaint asserted: “T.C.A., § 2-1-104(a)(14) defines a political party as an organization which nominates candidates for public office, T.C.A., § 2-1-104(a)(24), and taken in conjunction with T.C.A., §§ 2-1-104(a)(31), 2-5-208(d)(1), 2-13-107(a)(2), 2-13-201(a), and 2-14-202, a new statewide political party or minor political party to be recognized to run candidates in a special general election ballot in the State of Tennessee must petition successfully by presenting a petition with at least 2.5 percent  of the total number of votes cast for all gubernatorial candidates in the most recent gubernatorial election as shown by petitions to establish a political party filed with the Coordinator of Elections and signed by Tennessee registered voters so that it would find it virtually impossible to meet the petition deadline for minor political parties of 90 days before the general election, pursuant to T.C.A., § 2-13-107(a)(2), before the special general election when the special general election will  be set according to law (viz.: T.C.A., §2-14-202) between 100 and 107 days from the date of the writs for a special general election to fill the vacancy.”  

On October 15, 2013, Plaintiffs filed a motion for preliminary injunction to enjoin the enforcement of the Statutes as applied to plaintiffs for Special General Election for State House District 91 to be held on November 21, 2012, and specifically requested that defendant be ordered to place the Chairman of the Libertarian Party of Tennessee on the ballot as a Libertarian candidate rather than an Independent candidate.  Plaintiffs argued that the Chairman of the Libertarian Party of Tennessee “was unable to petition to obtain ballot status as a representative of the Libertarian minor party because it is virtually impossible under the petition signature requirement, petitioning time, and petitioning deadline of 90 days before a general election for a minor party to get recognized because of the time constraints involved in special general elections.”

On October 24, 2013, Plaintiffs filed an amended complaint naming the Shelby County Election Commission as an additional defendant in the lawsuit.  The allegations and relief sought remained the same.

On October 31, 2023, defendants filed a response to the motion for preliminary injunction stating that the Statutes required placement of the Chairman of the Libertarian Party of Tennessee’s name on the ballot as an Independent candidate and requesting that the motion for preliminary injunction be denied because defendants did not have the authority to consent to a change in the format of the ballot.

On October 31, 2023, the court heard Plaintiffs’ motion for preliminary injunction and granted the motion.  (This was a consolidated hearing on the motion for preliminary relief and the merits of the case.)  As reflected in the Judgment which was entered on November 25, 2013, the court ruled that the Statutes as applied to Plaintiffs for the Special General Election for State House District 91 to be held on November 21, 2013 were unconstitutional “for the reasons set forth on the record in open Court during the hearing”.  In an order filed on January 27, 2014, Plaintiffs’ counsel were awarded attorneys’ fees and expenses in the amount of $26,091.00.  The case is now closed.

Summary Authors

Melina Kountouris (10/24/2023)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/5038219/parties/tomasik-v-goins/


Judge(s)

Haynes, William Joseph (Tennessee)

Documents in the Clearinghouse

Documents in this case
1

3:13-cv-01118

Complaint

Oct. 9, 2013

Oct. 9, 2013

Complaint
10

3:13-cv-01118

Plaintiffs' Motion for Preliminary Injunction

Oct. 15, 2013

Oct. 15, 2013

Pleading / Motion / Brief
11

3:13-cv-01118

Plaintiffs' Motion for Preliminary Injunction

Oct. 15, 2013

Oct. 15, 2013

Pleading / Motion / Brief
12

3:13-cv-01118

Plaintiffs' Memorandum Brief in Support of their Complaint and Motion for Preliminary Injunction

Oct. 15, 2013

Oct. 15, 2013

Pleading / Motion / Brief
15

3:13-cv-01118

Order

Oct. 24, 2013

Oct. 24, 2013

Order/Opinion
17

3:13-cv-01118

Amended Complaint

Oct. 24, 2013

Oct. 24, 2013

Complaint
23

3:13-cv-01118

State Defendants' Response to Motion for Preliminary Injunction

Oct. 30, 2013

Oct. 30, 2013

Pleading / Motion / Brief
25

3:13-cv-01118

Response of Shelby County Election Commission to Motion for Preliminary Injunction

Oct. 31, 2013

Oct. 31, 2013

Pleading / Motion / Brief
30

3:13-cv-01118

Order

Nov. 5, 2013

Nov. 5, 2013

Order/Opinion
33

3:13-cv-01118

Judgment

Nov. 25, 2013

Nov. 25, 2013

Order/Opinion

Docket

See docket on RECAP: https://www.courtlistener.com/docket/5038219/tomasik-v-goins/

Last updated April 16, 2026, 4:57 a.m.

ECF Number Date Description Link
1 Oct. 9, 2013

COMPLAINT against Mark Goins and Tre Hargett (Filing fee $400, paid), filed by Libertarian Party of Tennessee, James Tomasik and J. Daniel Tomasik. (Attachments: # 1 Summons Issued, # 2 Civil Cover Sheet)(dt) (Entered: 10/09/2013)

1 Summons Issued

View on PACER

2 Civil Cover Sheet

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RECAP
2 Oct. 9, 2013

MOTION for attorney(s) James C. Linger to Appear Pro Hac Vice (Fee paid) by Libertarian Party of Tennessee, J. Daniel Tomasik and James Tomasik. (Attachments: # 1 Attachment - Proposed Order)(dt) (Entered: 10/09/2013)

RECAP
3 Oct. 9, 2013

CERTIFICATE OF GOOD STANDING of Attorney James Carter Linger from the United States District Court for the Northern of Oklahoma filed by Libertarian Party of Tennessee, J. Daniel Tomasik and James Tomasik. (dt) (Entered: 10/09/2013)

RECAP
4 Oct. 9, 2013

AFFIDAVIT of James C. Linger in support of 2 MOTION for attorney(s) James C. Linger to Appear Pro Hac Vice by Libertarian Party of Tennessee, J. Daniel Tomasik and James Tomasik. (dt) (Entered: 10/09/2013)

RECAP
5 Oct. 9, 2013

NOTICE of Initial Case Management Conference set for 11/25/2013 at 11:00 AM before Magistrate Judge Juliet E. Griffin. (dt) (Entered: 10/09/2013)

RECAP
6 Oct. 9, 2013

RECEIPT #34675028659, 34675028660 in the amount of $400.00 and $75.00 posted by James C. Linger, attorney for Libertarian Party of Tennessee, J. Daniel Tomasik and James Tomasik, re 2 Motion to Appear Pro Hac Vice and 1 Complaint. (dt) (Entered: 10/09/2013)

RECAP
Oct. 9, 2013

Bar status for attorneys W. Gary Blackburn of TN and James C. Linger of OK verified as active this date. (dt)

7 Oct. 10, 2013

SUMMONS returned executed by Libertarian Party of Tennessee, James Tomasik, J. Daniel Tomasik. Mark Goins served on 10/10/2013. (Blackburn, William) (Entered: 10/10/2013)

RECAP
8 Oct. 10, 2013

SUMMONS returned executed by Libertarian Party of Tennessee, James Tomasik, J. Daniel Tomasik. Tre Hargett served on 10/10/2013. (Blackburn, William) (Entered: 10/10/2013)

RECAP
9 Oct. 10, 2013

MOTION transfer case by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik. (Linger, James) (Entered: 10/10/2013)

RECAP
10 Oct. 15, 2013

MOTION for Preliminary Injunction by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik. (Attachments: # 1 Exhibit Exhibit 1, # 2 Attachment Cover Page for Exhibit 1)(Linger, James) (Entered: 10/15/2013)

1 Exhibit Exhibit 1

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2 Attachment Cover Page for Exhibit 1

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RECAP
11 Oct. 15, 2013

MOTION for Preliminary Injunction Corrected by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik. (Attachments: # 1 Attachment Cover Page, # 2 Exhibit 1)(Linger, James) (Entered: 10/15/2013)

1 Attachment Cover Page

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2 Exhibit 1

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RECAP
12 Oct. 15, 2013

BRIEF filed by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik re 11 Motion for Preliminary Injunction, 1 Complaint. (Linger, James) (Entered: 10/15/2013)

RECAP
13 Oct. 22, 2013

ORDER REASSIGNING CASE. Case reassigned to Chief Judge William J. Haynes, Jr for all further proceedings. Senior Judge John T. Nixon no longer assigned to case. Signed by Senior Judge John T. Nixon on 10/21/13. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(tmw) (Entered: 10/23/2013)

RECAP
14 Oct. 23, 2013

MOTION to Ascertain Status of Case re 11, 1, 12 by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik. (Linger, James) (Entered: 10/23/2013)

RECAP
15 Oct. 24, 2013

ORDER: By order entered October 22, 2013 13 , this case was reassigned to the Honorable William J. Haynes, Jr., Chief Judge. Inasmuch as Chief Judge Haynes normally conducts his own case management, the initial case management conference scheduled , by notice issued contemporaneously with the filing of the complaint, on 11/25/2013, is CANCELLED, to be rescheduled as appropriate by further order. Unless otherwise directed by the Court, there will be no further proceedings before the Magistrate Judge in this case. Judge Magistrate Judge Juliet E. Griffin no longer assigned to case. Signed by Magistrate Judge Juliet E. Griffin on 10/24/13. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(dt)

RECAP
16 Oct. 24, 2013

ORDER: Upon review after reassignment, this Motion for Preliminary Injunction 11 is set for a hearing on 10/31/2013 at 3:30 PM. Signed by Chief Judge William J. Haynes, Jr on 10/24/13. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(dt) (Entered: 10/24/2013)

RECAP
17 Oct. 24, 2013

AMENDED COMPLAINT against All Plaintiffs, filed by Libertarian Party of Tennessee, James Tomasik, J. Daniel Tomasik.(Linger, James) (Entered: 10/24/2013)

RECAP
18 Oct. 25, 2013

ORDER: This Motion to Ascertain Status of Case 41 is Denied as moot. Signed by Chief Judge William J. Haynes, Jr on 10/25/13. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(dt)

RECAP
19 Oct. 28, 2013

MOTION for Leave to Appear Telephonically (Proposed Order attached) by Shelby County Election Commission, John L. Ryder. (Attachments: # 1 Proposed Order re Motion to Appear Telephonically)(Ryder, John) (Entered: 10/28/2013)

RECAP
20 Oct. 29, 2013

NOTICE of Appearance by John L. Ryder on behalf of Shelby County Election Commission (Ryder, John) (Entered: 10/29/2013)

RECAP
21 Oct. 29, 2013

Amended MOTION for Leave to Appear Telephonically (Proposed Order attached) by Shelby County Election Commission. (Attachments: # 1 Proposed Order re Motion to Appear Telephonically)(Ryder, John) (Entered: 10/29/2013)

RECAP
22 Oct. 29, 2013

ORDER granting 19 Motion for Leave to Appear Telephonically. The court will initiate the telephone call. Signed by Chief Judge William J. Haynes, Jr on 10/29/2013. (eh) (Entered: 10/29/2013)

RECAP
23 Oct. 30, 2013

RESPONSE to Motion re 11 MOTION for Preliminary Injunction Corrected filed by Mark Goins, Tre Hargett. (Kleinfelter, Janet) (Entered: 10/30/2013)

RECAP
24 Oct. 30, 2013

NOTICE of Appearance by Janet M. Kleinfelter on behalf of Mark Goins, Tre Hargett (Kleinfelter, Janet) (Entered: 10/30/2013)

RECAP
Oct. 30, 2013

Bar status for attorney John L. Ryder of TN verified as active this date. (dt)

Oct. 30, 2013

Note to Filer, John L. Ryder, re DE# 20: Pursuant to Local Rule 5.01, Certificates of Service shall identify by name the person served, what was served, the method of service, and date of service. Please FILE a conformed Certificate of Service for this document. (dt)

25 Oct. 31, 2013

RESPONSE to Motion re 11 MOTION for Preliminary Injunction Corrected, 10 MOTION for Preliminary Injunction filed by Shelby County Election Commission. (Attachments: # 1 Exhibit A to Response to Motion for Preliminary Injunction)(Ryder, John) (Entered: 10/31/2013)

1 Exhibit A to Response to Motion for Preliminary Injunction

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RECAP
Oct. 31, 2013

Bar status for attorney Janet M. Kleinfelter of TN verified as active this date. (dt)

Oct. 31, 2013

Minute Entry for proceedings held before Chief Judge William J. Haynes, Jr: Motion Hearing held on 10/31/2013 re 11 MOTION for Preliminary Injunction Corrected filed by J. Daniel Tomasik, James Tomasik, Libertarian Party of Tennessee, 10 MOTION for Preliminary Injunction filed by J. Daniel Tomasik, James Tomasik, Libertarian Party of Tennessee. Hearing held on Plaintiffs' motion for preliminary injunction. (Court Reporter Peggy Turner.) (Wiley, Zachary)

26 Nov. 1, 2013

Transcript filed for dates of 10/31/13 before Judge William J. Haynes Jr.. Court Reporter/Transcriber: Peggy Turner, 615-726-4893, peggy_turner@tnmd.uscourts.gov. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. IT IS THE RESPONSIBILITY OF COUNSEL TO REVIEW THE TRANSCRIPT AND REQUEST REDACTION OF CONTENT CLASSIFIED AS PRIVATE UNDER THE NOTICE TO MEMBERS OF THE BAR, ELECTRONIC AVAILABILITY OF TRANSCRIPTS OF COURT PROCEEDINGS, EFFECTIVE MAY 5, 2008, AVAILABLE ON THE COURT'S WEBSITE UNDER THE CM-ECF LINK at: http://www.tnmd.uscourts.gov/files/20091201Notice_to_the_Bar_Transcripts.pdf. Intent to Request Transcript Redaction due 11/8/2013. Redaction Request due 11/22/2013. Redacted Transcript Deadline set for 12/2/2013. Release of Transcript Restriction set for 1/30/2014. (pt) (Entered: 11/01/2013)

RECAP
27 Nov. 1, 2013

WITNESS/EXHIBIT LIST prepared by Deputy Clerk. (eh) (Entered: 11/01/2013)

RECAP
28 Nov. 5, 2013

ORDER: This 21 Motion was granted. Signed by Chief Judge William J. Haynes, Jr on 1/4/2013. (eh) (Entered: 11/05/2013)

RECAP
29 Nov. 5, 2013

ORDER granting 2 Motion for James C. Linger to Appear Pro Hac Vice. Signed by Chief Judge William J. Haynes, Jr on 11/4/2013. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(eh) (Entered: 11/05/2013)

RECAP
30 Nov. 5, 2013

ORDER: Before the Court is Plaintiffs' motion for preliminary injunction (Docket Entry No. 11 ). For the reasons set forth on the record in open court during the hearing held on Plaintiffs' motion, at which counsel for all parties were present, Plaintiffs' motion is GRANTED, and the Shelby County Election Commission is ORDERED to place Plaintiff James "Jim" Tomasik on the ballot as a Libertarian Party candidate in the November 21, 2013 special election for State House District 91. It is so ORDERED. Signed by Chief Judge William J. Haynes, Jr on 11/5/2013. (eh) (Entered: 11/05/2013)

RECAP
31 Nov. 22, 2013

MOTION to Ascertain Status of Case and for Entry of Agreed Judgment re 17, 30 by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik. (Attachments: # 1 Attachment Cover to Exhibit 1, # 2 Exhibit Proposed Agreed Judgment)(Linger, James) (Entered: 11/22/2013)

RECAP
32 Nov. 25, 2013

ORDER granting 31 Motion to Ascertain Status of Case and for Entry of Agreed Judgment. Signed by Chief Judge William J. Haynes, Jr on 11/26/2013. (eh) (Entered: 11/25/2013)

RECAP
33 Nov. 25, 2013

JUDGMENT: IT IS ORDERED AND ADJUDGED that judgment be entered in favor of the Plaintiffs and against the Defendants. Signed by Chief Judge William J. Haynes, Jr on 11/26/2013. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(eh) (Entered: 11/25/2013)

RECAP
34 Nov. 25, 2013

ENTRY OF JUDGMENT re 33 Judgment, (eh) (Entered: 11/25/2013)

RECAP
35 Dec. 2, 2013

BILL OF COSTS with Attachment Ex "1" by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik. (Linger, James) (Entered: 12/02/2013)

RECAP
36 Dec. 2, 2013

MEMORANDUM in Support of 34 ENTRY OF JUDGMENT - DOCKET CLERK, 35 Bill of Costs filed by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik . (Attachments: # 1 Attachment Cover to Exhibit A, # 2 Attachment Exhibit A)(Linger, James) (Entered: 12/02/2013)

RECAP
37 Dec. 3, 2013

MEMORANDUM in Support of 34 ENTRY OF JUDGMENT - DOCKET CLERK, 33 Judgment, 36 Memorandum in Support, 35 Bill of Costs filed by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik . (Attachments: # 1 Attachment Cover page to Exhibit A, # 2 Exhibit A - Bill of Costs w Ex 1)(Linger, James) (Entered: 12/03/2013)

RECAP
38 Dec. 13, 2013

Costs Taxed in amount of $ 475.00 against Defendants. (dt) (Entered: 12/13/2013)

RECAP
39 Dec. 19, 2013

MOTION for Attorney Fees by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik. (Linger, James) (Entered: 12/19/2013)

RECAP
40 Dec. 19, 2013

MEMORANDUM BRIEF in support of 39 MOTION for Attorney Fees by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik. (Attachments: # 1 Attachment Exhibit A, # 2 Attachment Exhibit B, # 3 Attachment Exhibit C, # 4 Attachment Exhibit D, # 5 Attachment Exhibit E)(Linger, James) Modified texton 12/23/2013 (dt). (Entered: 12/19/2013)

RECAP
41 Dec. 23, 2013

NOTICE of Filing by Libertarian Party of Tennessee, J. Daniel Tomasik, James Tomasik re 39 MOTION for Attorney Fees, Docket Annotation, (Attachments: # 1 Exhibit A - Affidavit of W. Gary Blackburn, # 2 Exhibit B - Time Sheet Blackburn, # 3 Exhibit C - Affidavit of James C. Linger, # 4 Exhibit D - Time Sheet James C. Linger, # 5 Exhibit E - Non Taxable Costs and Expenses of James C. Linger)(Linger, James) (Entered: 12/23/2013)

RECAP
Dec. 23, 2013

Docket Annotation: At DE 40, counsel failed to include the mandatory description of the attached exhibits. The exhibits shall be RESUBMITTED by filing a Notice of Filing and attaching the exhibits with the mandatory brief description. (EXAMPLE: Attachments: # 1 Exhibit 1 Police Report dated 1/1/06, # 2 Exhibit 2 Unreported Case Smith v. Jones). (dt)

42 Jan. 27, 2014

ORDER granting 39 Motion for Attorney Fees. Signed by Chief Judge William J. Haynes, Jr on 1/27/14. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(la)

RECAP
June 5, 2014

Pursuant to LR 79.01(c), exhibits destroyed this date. (dt)

Case Details

State / Territory:

Tennessee

Case Type(s):

Election/Voting Rights

Special Collection(s):

Law Firm Antiracism Alliance (LFAA) project

Key Dates

Filing Date: Oct. 9, 2013

Closing Date: Jan. 27, 2014

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Libertarian Party of Tennessee

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

County

Shelby County Election Commission

State

State of Tennessee

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Equal Protection

Freedom of speech/association

Other Dockets:

Middle District of Tennessee 3:13-cv-01118

Available Documents:

Any published opinion

Complaint (any)

Injunctive (or Injunctive-like) Relief

Trial Court Docket

Outcome

Prevailing Party: Plaintiff OR Mixed

Relief Granted:

Attorneys fees

Injunction / Injunctive-like Settlement

Preliminary injunction / Temp. restraining order

Source of Relief:

Litigation

Content of Injunction:

Preliminary relief granted

State Statute Struck Down

Amount Defendant Pays: $26,091.00

Order Duration: 2013 - 2013

Issues

Voting:

Candidate qualifications

Election administration

Vote dilution

Voting: General & Misc.

Recommended Citation