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Case No. 2020-1044

Supreme Court of the State of Ohio

STATE OF OHIO ex rel. KANYE WEST, et al.,

Relators,

v.

FRANK LAROSE, Ohio Secretary of State,

Respondent,

Original Action in Mandamus // Expedited Election-Related Matter

RELATORS’ MERIT BRIEF

Curt C. Hartman (0064242) THE LAW FIRM OF CURT C. HARTMAN 7394 Ridgepoint Drive, Suite 8 Cincinnati, Ohio 45230 (513) 379-2923 [email protected]

Counsel for Relators Kanye West and Michelle Tidball

David A. Yost (0056290) Ohio Attorney General Bridget C. Coontz (0072919) Halli Brownfield Watson (0082466) CONSTITUTIONAL OFFICES SECTION OFFICE OF THE OHIO ATTORNEY GENERAL 30 East Broad Street, 16th Floor Columbus, Ohio 43215-3431 (614) 728-2035 [email protected] [email protected] Counsel for Respondent Ohio Secretary of State Frank LaRose

Supreme Court of Ohio Clerk of Court - Filed August 31, 2020 - Case No. 2020-1044

i

TABLE OF CONTENTS

Table of Contents ...................................................................................................................... i

Table of Authorities .................................................................................................................. iii

I. INTRODUCTION .................................................................................................................... 1

II. STATEMENT OF FACTS ...................................................................................................... 1

III. LAW AND ARGUMENT ........................................................................................................ 2

PROPOSITION OF LAW No. 1: ........................................................................................... 4

The Ohio Supreme Court has original jurisdiction to issue a writ of

mandamus.


Mandamus is the proper procedure to remedy the failure of the

Secretary of State or a board of elections to accept a candidate’s

nomination petition or to certify the candidate’s name on the ballot

when the nominating petition contains a sufficient number of valid

signature and the petition is otherwise in conformity with law.


To be entitled to a writ of mandamus, a relator must establish (1) a clear

legal right to the requested relief, (2) a clear legal duty on the part of the

public official or public body; and (3) the lack of an adequate remedy in

the ordinary course of law.

A. Mandamus – Legal right and legal duty for issuance ............................................................ 5


To establish the requisite legal right and legal duty for issuance of a writ

of mandamus in the context of ballot access, a relator must demonstrate

that the Secretary of State or board of elections engaged in fraud,

corruption, abuse of discretion, or clear disregard of statutes or other

pertinent law.


Because the duty of election officials with respect to signatures on

election-related documents is to establish the authenticity of the elector

who signed the document, and not the validity or genuineness of the

signature itself, the Secretary of State or a board of elections abuses its

discretion and clearly disregards statutes or other pertinent law when it

rejects a petition premised upon the latter.

ii


When the signature of a person on an election-related document is

questioned or challenged as not being genuine or authentic, the

Secretary of State or a board of elections abuses its discretion and

clearly disregards statutes or other pertinent law when it continues to

reject the validity of such signature after that person tenders an

unrefuted sworn affidavit attesting that the signature at issue is, in fact,

his or her signature.


Substantial compliance, not strict compliance, is required with respect to

the forms of statements of candidacy and nominating petitions under

R.C. § 3513.261.


Pursuant to R.C. § 3513.261, only one originally-signed statement of

candidacy is required.


Variations between an original statement of candidacy and the copy of

the statement of candidacy accompanying a nominating petition are not

prohibited and do not invalidate the nominating petition so long as there

is no fraud or deception on the persons signing the nominating petition.

B. Mandamus – Adequate remedy in the ordinary course of law ............................................. 18

PROPOSITION OF LAW No. 10: ......................................................................................... 18

In a mandamus action arising from the denial of ballot access, the proximity of

a forthcoming election establishes the lack of an adequate remedy in the

ordinary course of law.

CONCLUSION .......................................................................................................................... 18

Certificate of Service.................................................................................................................. 20

APPENDIX ................................................................................................................................ 21

Rejection Letter dated August 21, 2020

R.C. § 3501.39

R.C. § 3505.01(A)

R.C. § 3513.257

R.C. § 3513.261

iii

TABLE OF AUTHORITIES

Case Citations

Georgetown v. Brown Cty. Bd. of Elections,

158 Ohio St.3d 4, 139 N.E.3d 852, 2019-Ohio-3915 .......................................................

10, 17

State ex rel. Allen v. Warren Cty. Bd. of Elections,

115 Ohio St.3d 186, 874 N.E.2d 507, 2007-Ohio-4752 ...................................................

5

State ex rel. Beck v. Casey,

51 Ohio St.3d 79, 554 N.E.2d 1284 (1990) ......................................................................

14-16

State ex rel. Bobovnyik v. Mahoning County Bd. of Elections,

__ Ohio St. 3d __, __N.E.3d__, 2020-Ohio-4003 ...........................................................

6

State ex rel. Brown v. Summit Cty. Bd. of Elections,

46 Ohio St.3d 166, 545 N.E.2d 1256 (1989) ....................................................................

5

State ex rel. Burroughs v. Summit Cty. Bd. of Elections,

145 Ohio St.3d 220, 48 N.E.3d 515, 2015-Ohio-4122 ....................................................

12

State ex rel. Crowl v. Delaware Cty. Bd. of Elections,

144 Ohio St.3d 346, 43 N.E.3d 406, 2015-Ohio-4097 .....................................................

10

State ex rel. Green v. Casey,

51 Ohio St.3d 83, 554 N.E.2d 1288 (1990) .....................................................................

17

State ex rel. Hawkins v. Cuyahoga Cty. Bd. of Elections,

28 Ohio St.2d 4, 274 N.E.2d 563 (1971) .........................................................................

8, 15

State ex rel. Husted v. Brunner,

123 Ohio St.3d 288, 915 N.E.2d 1215, 2009-Ohio-5327 .................................................

2

State ex rel. Leslie v. Duffy,

164 Ohio St. 178, 129 N.E.2d 632 (1955) ........................................................................

15

State ex rel. Martin v. Tuscarawas County Board of Elections,

2019-Ohio-4236 (5th Dist.) ..............................................................................................

12

State ex rel. Moss v. Franklin Cty. Bd. of Elections,

69 Ohio App.2d 115, 432 N.E.2d 210 (1980) ..................................................................

4

State ex rel. National City Bank v. Board of Ed. of the Cleveland City School Dist.,

52 Ohio St.2d 81, 369 N.E.2d 1200 (1977) .....................................................................

4

State ex rel. O’Donnell v. Cuvahoga Cty. Bd. of Elections,

136 Ohio App.3d 584, 587, 737 N.E.2d 541, 2000-Ohio-169 ..........................................

5

State ex rel. Ohio Liberty Council v. Brunner,

125 Ohio St.3d 315, 928 N.E.2d 410, 2010-Ohio-1845 ...................................................

18

State ex rel. Osborn v. Fairfield Cty. Bd. of Elections,

65 Ohio St.3d 194, 602 N.E.2d 636 (1992) .....................................................................

14

iv

State ex rel. Ohio Republican Party v. FitzGerald,

145 Ohio St.3d 92, 47 N.E.3d 124, 2015-Ohio-5056 .......................................................

11

State ex rel. Ruehlmann v. Luken,

65 Ohio St.3d 1, 598 N.E.2d 1149 (1992) .......................................................................

1, 17

State ex rel. Rust v. Lucas Cty. Bd. of Elections,

101 Ohio St.3d 63, 800 N.E.2d 1162, 2004-Ohio-9 (2004) ..............................................

6, 8

State ex rel. Saffold v. Timmins,

22 Ohio St.2d 63, 64, 258 N.E.2d 112 (1970) .................................................................

16, 17

State ex rel. Scott v. Franklin Cty. Bd. of Elections,

139 Ohio St.3d 171, 10 N.E.3d 697, 2014-Ohio-1685 .....................................................

10

State ex rel. Stern v. Cuyahoga Cty. Bd. of Elections,

14 Ohio St.2d 175, 237 N.E.2d 313 (1968) ......................................................................

17

State ex rel. Summit Cty. Republican Party Executive Commt. v. Brunner,

118 Ohio St.3d 515, 890 N.E.2d 888, 2008-Ohio-2824 ...................................................

12

State ex rel. Wilke v. Hamilton Cty. Bd. of Comm’rs,

90 Ohio St.3d 55, 734 N.E.2d 811, 2000-Ohio-13 ...........................................................

4

State ex rel. Yeager v. Richland Cty. Bd. of Elections,

136 Ohio St.3d 327, 995 N.E.2d 228, 2013-Ohio-3862 ...................................................

18

State Statutes

R.C. § 3501.01(I) ..................................................................................................................... v 15

R.C. § 3501.011(A) .................................................................................................................. v 9

R.C. § 3501.39 ......................................................................................................................... v 2

R.C. § 3501.39(A) .................................................................................................................... v 2

R.C. § 3505.01(A)(1) ............................................................................................................... v 6

R.C. § 3513.09 ......................................................................................................................... v 15, 16

R.C. § 3513.257 ....................................................................................................................... v 7

R.C. § 3513.257(A) .................................................................................................................. v 1

R.C. § 3513.261 ....................................................................................................................... v passim

1

I. INTRODUCTION

Over 6,000 validly-registered voters in the State of Ohio signed a petition to nominate

KANYE WEST and MICHELLE TIDBALL as candidates for President and Vice-President of

the United States at the forthcoming general election to be held on November 3, 2020. Verified

Complaint ¶21; Answer ¶21; Exhibit B to Hartman Affidavit. Notwithstanding the fact that Mr.

WEST and Ms. TIDBALL tendered a Nominating Petition containing a sufficient number of

valid signatures for the placement of their names on the ballot, see R.C. § 3513.257(A), the

Office of the Secretary of State rejected the Nominating Petition and, accordingly, Secretary of

State FRANK LAROSE refuses to certify their names as candidates on the ballot at the

forthcoming election. Verified Complaint ¶46; Answer ¶¶45 & 46.

Left unchecked by this Court, the arbitrary actions of Secretary of State LAROSE and his

clear disregard of legal provisions, premised solely upon subjective speculation, will deny those

who signed the nominating petition of Mr. WEST and Ms. TIDBALL, as well as all registered

voters in the State of Ohio, the opportunity for free and competitive elections in the forthcoming

election. Moreover, the arbitrariness and lack of any basis for the rejection of the Nominating

Petition become more apparent as Ms. TIDBALL has confirmed under oath that the two

signatures which formed the sole basis for the sua sponte rejection of the Nominating Petition

are, in fact, her signatures notwithstanding any perceived variation between the two. Verified

Complaint ¶¶30 – 32.

Failing to appreciate that the pertinent statute only requires substantial compliance and

that election statutes should be construed “to avoid unduly technical interpretations that impede

the public policy favoring free, competitive elections,” State ex rel. Ruehlmann v. Luken, 65

Ohio St.3d 1, 3, 598 N.E.2d 1149 (1992), Secretary LAROSE has abused his discretion and

2

clearly disregarded applicable legal provisions and standards. In light of the proximity of the

forthcoming election and because no other viable remedy is available to compel the placement of

their names on the ballot, Mr. WEST and Ms. TIDBALL commenced this mandamus action to

challenge the decision of Secretary LAROSE, wherein “the standard is whether [he] engaged in

fraud, corruption, or abuse of discretion, or acted in clear disregard of applicable legal

provisions.” State ex rel. Husted v. Brunner, 123 Ohio St.3d 288, 915 N.E.2d 1215, 2009-Ohio-

5327 ¶9 (quoting Whitman v. Hamilton Cty. Bd. of Elections, 97 Ohio St.3d 216, 778 N.E.2d 32,

2002-Ohio-5923 ¶11).

As developed below, based upon the undisputed sworn evidence before the Court and the

law itself, the decision to reject the Nominating Petition of Mr. WEST and Ms. TIDBALL and

the refusal to certify their names to the ballot constitute an abuse of discretion and a clear

disregard of statutes or other pertinent law. Accordingly, a writ of mandamus should issue to

compel Respondent FRANK LAROSE, the Ohio Secretary of State:

(i) to accept, pursuant to R.C. § 3501.39, the Statements of Candidacy and

Nominating Petition of KANYE WEST and MICHELLE TIDBALL as

candidates for President and Vice-President of the United States; and

(ii) to certify, pursuant to R.C. § 3505.01(A), for placement on the official ballot

for the forthcoming general election to be held on November 3, 2020, the

names of KANYE WEST and MICHELLE TIDBALL as candidates for

President and Vice-President of the United States.

II. STATEMENT OF FACTS

Seeking to be independent candidates for President and Vice-President of the United

States, KANYE WEST and MICHELLE TIDBALL caused to be filed with the Office of the

Secretary of State on August 5, 2020, Statements of Candidacy and a Nominating Petition, as

well as other required documents. Verified Complaint ¶¶16 – 19; Answer ¶¶16 – 19; Aumann

3

Affidavit ¶¶3 – 5. As the Nominating Petition consisted of approximately 1,400 part-petitions

with nearly 15,000 signatures from across the State, see Exhibit A to Aumann Affidavit, the

Office of the Secretary of State transmitted the part-petitions to the various boards of elections

for verification of the signatures thereon. Verified Complaint ¶20; Answer ¶20. By August 18,

2020, the Office of the Secretary of State had received confirmation from most of the boards of

election that KANYE WEST and MICHELLE TIDBALL had tendered over 6,000 valid

signatures on the Nominating Petition, see Exhibit B to Hartman Affidavit, clearly surpassing the

statutory requirement of 5,000 valid signatures. Verified Complaint ¶21; Answer ¶21.

The next day, i.e., August 19, 2020, a third party started a series of ex parte exchanges of

communications with the Office of the Secretary of State, arguing against the acceptance and the

Nominating Petition and the certification of Mr. WEST and Ms. TIDBALL to the ballot at the

forthcoming general election. See Exhibit A to Hartman Affidavit. Following and clearly

adopting the gist of the ex parte argument by this third party, Amanda M. Grandjean, the

Director of Elections and Deputy Assistant Secretary of State, issued a Rejection Letter to a

designated representative of Mr. WEST and Ms. TIDBALL on August 21, 2020, informing him

that the “nominating petition of Mr. WEST and Ms. TIDBALL is rejected.” Verified Complaint

¶¶22 – 24; Answer ¶¶22 – 24; Aumann Affidavit ¶¶8 – 9, and Exhibit B thereto. In contrast to

the ex parte exchange with a third party concerning the Statements of Candidacy and the

Nominating Petition, the Office of the Secretary of State did not make any inquiry or expression

of concern to the representative of Mr. WEST and Ms. TIDBALL concerning the validity or

genuineness any signatures or other aspects with respect to the Statements of Candidacy or the

Nominating Petitions until issuing the Rejection Letter. Aumann Affidavit ¶10.

4

In light of the rejection of the Statements of Candidacy and Nominating Petition,

Secretary of State LAROSE has acknowledged that KANYE WEST and MICHELLE TIDBALL

will not be certified to the forthcoming general election ballot as candidates for President and

Vice-President of the United States. Answer ¶¶45 & 46. Following the decision of Secretary of

State LAROSE to not accept the Nominating Petition and his refusal to certify their names to the

forthcoming general election ballot, KANYE WEST and MICHELLE TIDBALL commenced

the present mandamus action to compel Secretary of State LAROSE to comply with his legal

duties under Ohio’s election laws as KANYE WEST and MICHELLE TIDBALL have complied

with all of the legal requirements to be on the ballot this coming November.

III. LAW AND ARGUMENT

PROPOSITION OF LAW No. 1:

The Ohio Supreme Court has original jurisdiction to issue a writ of

mandamus.

“Original jurisdiction is conferred on this court in mandamus actions by Section 2(B)(1)(b)

of Article IV of the Constitution of Ohio.” State ex rel. National City Bank v. Board of Ed. of the

Cleveland City School Dist., 52 Ohio St.2d 81, 86, 369 N.E.2d 1200 (1977); accord State ex rel.

Wilke v. Hamilton Cty. Bd. of Comm’rs, 90 Ohio St.3d 55, 59, 734 N.E.2d 811, 2000-Ohio-13

(“[u]nder Section 2(B)(1)(b), Article IV of the Ohio Constitution, the Supreme Court of Ohio has

original jurisdiction in mandamus actions”).


Mandamus is the proper procedure to remedy the failure of the Secretary of

State or a board of elections to accept a candidate’s nomination petition or to

certify the candidate’s name on the ballot when the nominating petition

contains a sufficient number of valid signature and the petition is otherwise

in conformity with law.

5


To be entitled to a writ of mandamus, a relator must establish (1) a clear

legal right to the requested relief, (2) a clear legal duty on the part of the

public official or public body; and (3) the lack of an adequate remedy in the


When the Secretary of State or a board of elections refuses to accept a candidate’s

nominating petition or to certify the candidate’s name to the ballot, this Court and inferior courts

have repeatedly recognized that mandamus is the proper remedy. State ex rel. Brown v. Summit

Cty. Bd. of Elections, 46 Ohio St.3d 166, 167, 545 N.E.2d 1256 (1989); State ex rel. Moss v.

Franklin Cty. Bd. of Elections, 69 Ohio App.2d 115, 432 N.E.2d 210 (1980)(mandamus action to

challenge action of county board of elections in refusing to place petitioner’s name on ballot);

see also State ex rel. O’Donnell v. Cuvahoga Cty. Bd. of Elections, 136 Ohio App.3d 584, 587,

737 N.E.2d 541, 2000-Ohio-169 (mandamus was the appropriate remedy to address decision of

county’s board of elections to invalidate and decertify candidate’s declaration and petition for

candidacy). In order to be entitled to the requested writ of mandamus, Relators must establish a

clear legal right to certification of their candidacy on the November 3 general election ballot, a

corresponding clear legal duty on the part of the Secretary of State to certify their candidacy, and

the lack of an adequate remedy in the ordinary course of the law. State ex rel. Allen v. Warren

Cty. Bd. of Elections, 115 Ohio St.3d 186, 874 N.E.2d 507, 2007-Ohio-4752 ¶8 (quoting Rust v.

Lucas Cty. Bd. of Elections, 108 Ohio St.3d 139, 841 N.E.2d 766, 2005-Ohio-5795 ¶7).

A. Mandamus – Legal right and legal duty for issuance.


To establish the requisite legal right and legal duty for issuance of a writ of

mandamus in the context of ballot access, a relator must demonstrate that

the Secretary of State or board of elections engaged in fraud, corruption,

abuse of discretion, or clear disregard of statutes or other pertinent law.

6


Because the duty of election officials with respect to signatures on election-

related documents is to establish the authenticity of the elector who signed

the document, and not the validity or genuineness of the signature itself, the

Secretary of State or a board of elections abuses its discretion and clearly

disregards statutes or other pertinent law when it rejects a petition premised

upon the latter.


When the signature of a person on an election-related document is

questioned or challenged as not being genuine or authentic, the Secretary of

State or a board of elections abuses its discretion and clearly disregards

statutes or other pertinent law when it continues to reject the validity of such

signature after that person tenders an unrefuted sworn affidavit attesting

that the signature at issue is, in fact, his or her signature.

When the Secretary of State or a board of elections refuses to accept a candidate’s

nominating petition or to certify the candidate’s name to the ballot, “to establish the requisite

legal right and legal duty, relators ‘must prove that the [secretary of state] or board of elections

engaged in fraud, corruption, abuse of discretion, or clear disregard of statutes or other pertinent

law.’” Rust, 108 Ohio St.3d 139, 841 N.E.2d 766, 2005-Ohio-5795 ¶8; accord State ex rel.

Bobovnyik v. Mahoning County Bd. of Elections, __ Ohio St. 3d __, __N.E.3d __, 2020-Ohio-

4003 ¶11.

R.C. § 3501.39(A) imposes the mandatory duty upon the Secretary of State to “accept

any petition described in section 3501.38 of the Revised Code” (which includes nominating

petitions presented to or filed with the secretary of state for the purpose of becoming a candidate

for any office) unless a protest is filed or “[t]he candidate’s candidacy or the petition violates the

requirements of this chapter, Chapter 3513 of the Revised Code, or any other requirements

established by law.” And R.C. § 3505.01(A)(1) requires the Secretary of State to “certify to the

board of elections of each county the forms of the official ballots to be used at that general

7

election, together with the names of the candidates to be printed on those ballots whose

candidacy is to be submitted to the electors of the entire state….”

Once the various boards of elections confirmed that the Nominating Petition contained a

sufficient number of valid signatures to satisfy the requirements of R.C. § 3513.257 (“[i]f the

candidacy is to be voted on by electors throughout the entire state, the nominating petition…shall

be signed by no less than five thousand qualified electors”) and that a slate of presidential

electors sufficient in number to satisfy the requirement of the United States Constitution was

submitted with the Nominating Petition, see R.C. § 3513.257, Mr. WEST and Ms. TIDBALL

satisfied the statutory requirements for placement as candidates on the forthcoming general

election ballot. At that stage, the Secretary of State had the legal obligation to accept the petition

and to certify their names to the general election ballot.

However, almost immediately after the boards of elections collectively confirmed and

reported a sufficient number of valid signatures on the Nominating Petition, the Office of the

Secretary of State started to engage in ex parte communications with a third party arguing the

Nominating Petition contained fatal flaws. Instead of also seeking input on the issue from Mr.

WEST and Ms. TIDBALL, the Office of the Secretary of State engaged exclusively in an

exchange of e-mails with this third party on August 19, 2020, wherein the third party made ex

parte arguments concerning the Statements of Candidacy and the Nominating Petition.

Ultimately, on August 21, 2020, Amanda M. Grandjean, the Director of Elections and

Deputy Assistant Secretary of State, issued a Rejection Letter to a designated representative of

Mr. WEST and Ms. TIDBALL informing him that the “nominating petition of Mr. WEST and

Ms. TIDBALL is rejected.” Not surprisingly, not only did the gist of the contention within the

Rejection Letter track the ex parte argument made by a third party two days earlier, but the two

8

cases to which Ms. Grandjean cited for support in the Rejection Letter were the same two cases

the third party had cited to in his ex parte communication with the Office of the Secretary of

State concerning the Nominating Petition. In the end, Secretary LAROSE has acknowledged that

he will not certify the names of Mr. WEST and Ms. TIDBALL as candidates for President and

Vice-President on the forthcoming general election ballot. Answer ¶46.

At issue before this Court is the premise upon which the Nominating Petition was

rejected. The stated basis for the sua sponte rejection (after ex parte argument from a third

party) as set forth in the Rejection Letter is that:

Under Ohio law, a nominating petition must include at least one originally signed

statement of candidacy, which may be copied on the other petition papers for

circulation. The statement of candidacy that was designated as the original in

their filing does not match the petitions circulated. In fact, the signatures for

Michelle Tidball bear no resemblance, calling into question which is genuine.

Therefore, their nominating petition is rejected.

In a footnote, Ms. Grandjean cited to R.C. § 3513.261, as well as this Court’s decisions in State

ex rel. Hawkins v. Cuyahoga Cty. Bd. of Elections, 28 Ohio St.2d 4, 6, 274 N.E.2d 563 (1971),

and State ex rel. Rust v. Lucas Cty. Bd. of Elections, 101 Ohio St.3d 63, 800 N.E.2d 1162, 2004-

Ohio-9 (2004).1

With respect to a statement of candidacy, R.C. § 3513.261 simply requires a single

original statement of candidacy even if the nominating petition itself is tendered through multiple

part-partitions:

A nominating petition may consist of one or more separate petition papers, each

of which shall be substantially in the form prescribed in this section. If the

petition consists of more than one separate petition paper, the statement of

candidacy of the candidate or joint candidates named need be signed by the

candidate or joint candidates on only one of such separate petition papers, but the

1 It is more than coincidental that these are the two cases to which the third party cited

during his ex parte argument and exchange with the Office of the Secretary of State on August

19, 2020. See Exhibit A to Hartman Affidavit.

9

statement of candidacy so signed shall be copied on each other separate petition

paper before the signatures of electors are placed on it.

It must be noted that the entire basis for the rejection of the Nominating Petition as stated

in the Rejection Letter is that the Office of the Secretary of State simply “questioned” which of

two signatures purportedly that of Ms. TIDBALL was her genuine signature. In the subjective

opinion of Ms. Grandjean, the signature appearing on the original Statement of Candidacy

compared to the signature appearing on the copy of the statement of candidacy included with the

Nominating Petition bore what Ms. Grandjean described as “no resemblance”. Based solely

upon that subjective perception of Ms. Grandjean, the Nominating Petition was rejected.

But in “questioning” the “genuineness” of one signature over another, Ms. Grandjean or

Secretary LAROSE abused their discretion and clearly disregarded applicable law as such actions

go beyond the proper role and duty of election officials. R.C. § 3501.011(A) provides that:

as used in the sections of the Revised Code relating to elections…, whenever a

person is required …to sign or affix a signature on any other document that is

filed with or transmitted to a board of elections or the office of the secretary of

state, “sign” or “signature” means that person’s written, cursive-style legal mark

written in that person’s own hand.

And in a recent series of cases, this Court has clearly distinguished between an election official

undertaking and ascertaining whether a person’s legal mark on an election-related document is

the precise legal mark actually used by that person, i.e., determining whether the legal mark itself

is genuine or authentic, versus simply confirming that a signature on an election-related

document is, in fact, the signature of the particular person whose it is purported to be regardless

of the similarity vel non to other signatures of that person, i.e., determining whether the signature

is genuinely that of the person whose it is purported to be. While there is a nuance between the

two concepts, this Court has held that the former, which is essentially the actions of the Office of

10

the Secretary of State or Secretary LAROSE in rejecting the Nominating Petition, is not within the

scope of election officials’ duties and responsibilities.

In State ex rel. Scott v. Franklin Cty. Bd. of Elections, 139 Ohio St.3d 171, 10 N.E.3d

697, 2014-Ohio-1685, after a board of election rejected a candidate’s petition when the

candidate, “in the board’s judgment”, did not submit a sufficient number of signatures, this Court

issued a writ of mandamus to compel the placement of candidate’s name on the ballot. In Scott,

the petition circulator and the elector whose signature was at issue attested under oath that the

signature at issue was, in fact, the signature of the person it purported to be. Thus, this Court

found an abuse of discretion in rejecting that signature as not being genuine and issued a writ of

mandamus.

Then, in State ex rel. Crowl v. Delaware Cty. Bd. of Elections, 144 Ohio St.3d 346, 43

N.E.3d 406, 2015-Ohio-4097, this Court confronted an issue similar to that in Scott. In once

again issuing a writ of mandamus to place a candidate’s name on the ballot after affidavits

attested to the genuineness of signature on a petition, this Court clarified the role of election

officials when it comes to policing signatures on election-related documents, declaring that

boards of elections (or the Secretary of State) have the obligation:

to confirm the authenticity of signatures, but it does not impose on them the

responsibility to enforce R.C. 3501.011 by policing petition signatures for

nonconforming legal marks.

Id. ¶10.

Less any ambiguity remains as to the role of election official vis-à-vis signatures, in

Georgetown v. Brown Cty. Bd. of Elections, 158 Ohio St.3d 4, 139 N.E.3d 852, 2019-Ohio-3915,

this Court made clear that, when it came to signatures on election-related documents, elections

officials are not to ferret into or attempt to police (let alone, guess as the Office of the Secretary

11

of State did in the present case) the genuineness of a signature qua a signature, but, instead, are

simply to ensure the signature on the election-related document is that of the person whose it is

purported to be:

Although the caselaw speaks in terms of establishing whether a signature is

genuine, Crowl and Scott explain that the duty of the boards of elections is to

establish the authenticity of the elector, not the signature.

Id. ¶24.

In the present case, the signatures of Ms. TIDBALL on the Statement of Candidacy are

the basis by which the Nominating Petition was rejected and, accordingly, the names of Mr.

WEST and Ms. TIDBALL will not be certified to the general election ballot. Claiming in a press

release that “the information and a signature on the original nominating petition and statement of

candidacy submitted to the Secretary’s office do not match that of the nominating petition and

statement of candidacy that was used to circulate part-petitions,” the Office of the Secretary of

State published on its website (and as part of that press release) a Comparison of the Statements

of Candidacy of KANYE WEST and MICHELLE TIDBALL between what it characterizes as

the “Original” and “Circulated Version” of the Statements of Candidacy. Verified Complaint ¶25

& Exhibit B; Answer ¶25.2 Yet, through the Verified Complaint, Ms. TIDBALL has

acknowledged under oath that the two signatures on the Comparison, i.e., Exhibit B, purporting

to be her signatures on the original Statement of Candidacy and that copied onto statement

2 The referenced press release, which contains a link directly to the Comparison, is

available on the website of the Secretary of State at https://www.sos.state.oh.us/media-

center/press-releases/2020/2020-08-212/. To the extent relevant, this Court can take judicial

notice of the press release. See State ex rel. Ohio Republican Party v. FitzGerald, 145 Ohio

St.3d 92, 47 N.E.3d 124, 2015-Ohio-5056 ¶18.

https://www.sos.state.oh.us/media-center/press-releases/2020/2020-08-212/

https://www.sos.state.oh.us/media-center/press-releases/2020/2020-08-212/

12

included with the part-petitions are, in fact, her genuine signature notwithstanding any perceived

variation between the two. Verified Complaint ¶¶30 – 32.3

As noted above, in Scott and Crowl, this Court has issued writs of mandamus when a

person attests under oath to the genuineness of their signature on a petition or election-related

document. See also Burroughs, 145 Ohio St.3d 220, 48 N.E.3d 515, 2015-Ohio-4122 (upon

presentation of undisputed evidence validating the legitimacy of four signatures, “[o]n the

authority of [Crowl], we conclude that the board abused its discretion in rejecting the four

petition signatures and in denying relator a place on the ballot. Accordingly, we grant the writ”).

And various courts of appeals have similarly ordered the certification of candidates to the ballot

under similar circumstances. See, e.g., State ex rel. Martin v. Tuscarawas County Board of

Elections, 2019-Ohio-4236 ¶¶12 & 13 (5th Dist.)(“Ms. Martin submitted affidavits from Craig

Fahrney and Randall Stephens. Each affiant indicates he voluntarily signed Ms. Martin’s

Nominating Petition for Ms. Martin…and that each signed Ms. Martin’s Nominating Petition

with their genuine signature.… We find the affidavits of Craig Fahrney and Randall Stephens

establish they are the electors who signed Ms. Martin’s Nominating Petition…. The Board of

3 The fact that such evidence was not presented to the Secretary of State before the filing of

this action is of no moment. Firstly, the Secretary of State sua sponte (and based solely upon an

ex parte exchange with a third party) rejected the Nominating Petition without providing any

notice to either Mr. WEST or Ms. TIDBALL, thus precluding them the ability to present such

evidence in order to resolve whatever issue the Office of the Secretary of State might have with

respect to Ms. TIDBALL’s signature. Furthermore, the statutory process allowing for sua sponte

action does not envision the presentation of evidence at that stage; thus, presentation of evidence

as part of the mandamus action is appropriate. See State ex rel. Summit Cty. Republican Party

Executive Commt. v. Brunner, 118 Ohio St.3d 515, 890 N.E.2d 888, 2008-Ohio-2824 ¶68

(O’Donnell, J., concurring)(“R.C. 3501.07 does not provide any process for presentation of

evidence to the Secretary at the time of the appointment. Instead, the opportunity to present

evidence is through the mandamus action”). Finally, even in situations when a hearing was held

before a board of elections, this Court has granted a writ of mandamus upon consideration of

evidence, i.e., affidavits, presented for the first time as part of the mandamus action filed in this

Court. See State ex rel. Burroughs v. Summit Cty. Bd. of Elections, 145 Ohio St.3d 220, 48

N.E.3d 515, 2015-Ohio-4122.

13

Elections presented no evidence to refute this fact. Therefore, under the Crowl decision, we find

the Board of Elections abused its discretion when it found Fahrney’s and Stephens’ signatures to

be invalid.”).

Mr. WEST and Ms. TIDBALL have completed and satisfied all of the statutory

requirements to be placed on the general election ballot as candidates for President and Vice-

President of the United States. In light of the undisputed evidence that the two signatures of Ms.

TIDBALL on both the original Statement of Candidacy and on that copied onto the statement of

candidacy included with the part-petitions are, in fact, her genuine signature, the basis for the

rejection of the Nominating Petition by the Office of the Secretary of State or Secretary LAROSE

is clearly without merit. Furthermore, as the action of the Office of the Secretary of State or

Secretary LAROSE in rejecting the Nominating Petition improperly sought to determine whether

the legal mark of Ms. TIDBALL was genuine, as opposed to simply whether it was her

signature, and doing so based upon ex parte communications with a third party and not affording

any opportunity for Mr. WEST or Ms. TIDBALL, Secretary LAROSE has clearly abused his

discretion and clearly disregarded applicable legal provisions and standards in both rejecting the

Nominating Petition and in refusing to certify their names to the ballot at the forthcoming

general election.


Substantial compliance, not strict compliance, is required with respect to the

forms of statements of candidacy and nominating petitions under R.C. §

3513.261.


Pursuant to R.C. § 3513.261, only one originally-signed statement of

candidacy is required.

14


Variations between an original statement of candidacy and the copy of the

statement of candidacy accompanying a nominating petition are not

prohibited and do not invalidate the nominating petition so long as there is

no fraud or deception on the persons signing the nominating petition.

While the Rejection Letter clearly indicates the basis for the rejection of the Nominating

Petition was the “questionable” comparison of the signature of Ms. TIDBALL on the original

Statement of Candidacy versus her signature on the copy of the statements of candidacy included

with the Nominating Petition, to the extent the Secretary of State may now attempt to recast the

issue in broader terms, i.e., any variations between the original Statements of Candidacy and the

copy of the statements of candidacy with the Nominating Petition, variations between the two are

not verboten and do not invalidate a nominating petition.

R.C. § 3513.261 provides, in part:

A nominating petition may consist of one or more separate petition papers, each

of which shall be substantially in the form prescribed in this section. If the

petition consists of more than one separate petition paper, the statement of

candidacy of the candidate or joint candidates named need be signed by the

candidate or joint candidates on only one of such separate petition papers, but the

statement of candidacy so signed shall be copied on each other separate petition

paper before the signatures of electors are placed on it….

Additionally, only “substantial compliance” is required with respect to the requirements of R.C.

§ 3513.261, including, specifically, what is necessary when a statement of candidacy is copied

onto other part-petitions. State ex rel. Osborn v. Fairfield Cty. Bd. of Elections, 65 Ohio St.3d

194, 196-97, 602 N.E.2d 636 (1992); see also State ex rel. Beck v. Casey, 51 Ohio St.3d 79, 81,

554 N.E.2d 1284 (1990)(R.C. § 3513.07 governing the form for declarations of candidacy and

petitions “requires substantial compliance with such forms”).

Thus, as R.C. § 3513.261 clearly provides, and case law confirms, at least one originally

signed statement of candidacy is required in order for the Secretary of State or board of elections

15

to place a candidate’s name on the general election ballot. See Hawkins, 28 Ohio St.2d 4, 6, 274

N.E.2d 563 (1971)(without “at least one originally signed… statement of candidacy, as [R.C. §

3513.261] requires, [a board of elections] is not under a clear legal duty to place [a candidate’s]

name on the ballot”). With one originally signed statement of candidacy, the statement of

candidacy on other part-petitions does not need to be an original but can be copied.

But contrary to the implication of the Rejection Letter, the statement of candidacy copied

onto the other part-petitions does not need to be a precise photostatic copy of the original;

instead, non-material variations that do not mislead or deceive signors are permissible and are

not a proper basis to invalidate a nominating petition. In Beck, 51 Ohio St.3d 79, 554 N.E.2d

1284, this Court directly addressed the impact of variations between an original declaration of

candidacy and the copy included on other part-petitions.4 Beck held that, when multiple part-

4 With respect to the issues in the present case, there is not a material difference between

the requirements of the form concerning a declaration of candidacy for party nomination versus

the statement of candidacy. The difference between a declaration of candidacy (together with a

petition of candidate) versus a statement of statement of candidacy (together with a nominating

petition) is simply the manner by which one appears on the general election ballot.

Candidates appearing on the general election ballot appear through a nominating process.

But there are two distinct ways as to how one is nominated: (1) by a primary election; or (2) by

nominating petition. To seek the nomination of a party (via a primary election), a prospective

candidate utilizes a declaration of candidacy, together with a petition of candidate. See R.C. §

3513.07; see State ex rel. Leslie v. Duffy, 164 Ohio St. 178, 129 N.E.2d 632 (1955)(“[i]n the case

of the party candidate he makes a declaration of candidacy and those electors signing his petition

certify that he belongs to a certain party and that they believe he is qualified to perform the duties

of the office he seeks”).

On the other hand, independent candidates utilize a statement of candidacy, together with a

nominating petition, to effectuate the placement of their name on the ballot. See R.C. §

3501.01(I). Via this process, the independent candidate makes a statement of candidacy (as

opposed to the declaration of candidacy) and he or she is actually nominated via a sufficient

number of valid signatures of electors on the nominating petition.

The requirements as to the form of either the declaration of candidacy or the statement of

candidacy are materially the same. Compare, e.g., R.C. § 3513.09 (“[i]f the petition…to be filed

with a declaration of candidacy consists of more than one separate petition paper, the declaration

of candidacy of the candidate named need be signed by the candidate…on only one of such

separate petition papers, but the declaration of candidacy so signed shall be copied on each other

16

petitions are submitted, non-material variations between the original declaration of candidacy

and the declaration of candidacy on any other various part-petitions “do not destroy the unity of a

declaration of candidacy” and, thus, is not a basis to reject the accompanying petition. Id. at 80.

Relying upon the explicit language of R.C. § 3513.09, this Court recognized “[t]hat only one

declaration of candidacy ‘need be’ signed implies that others may be [signed].” Id. at 81; see

R.C. § 3513.261 (“the statement of candidacy of the candidate or joint candidates named need be

signed by the candidate or joint candidates on only one of such separate petition papers not

fatal”).

In fact, in Beck, the Secretary of State actually took the position that a declaration of

candidacy need not be precisely the same on all part-petitions (though that now appears to be the

premise of the Rejection Letter):

The board’s interpretation requires a candidate to either fill out all of the

necessary declarations to accompany the part-petitions on the same day or

requires him to copy his original declaration to attach to all part-petitions. The

copying of a declaration as provided in R.C. 3513.09 would become mandatory

rather than permissive. It would preclude a candidate from completing a separate

declaration on a different day if he ran out of copies or original declarations. If

the declaration is actually signed on a subsequent date from the original one, the

candidate would be forced to back-date the new one under the board’s

interpretation. This back-dating of declarations may subject the candidate to an

election falsification violation.

Id. at 81.

“The sole purpose of the declaration of candidacy [or statement of candidacy] is to

inform the signer that one is seeking to be a [] candidate for a certain public office to begin at a

certain time.” State ex rel. Saffold v. Timmins, 22 Ohio St.2d 63, 64, 258 N.E.2d 112 (1970).

separate petition paper”) with R.C. § 3513.261 (“[i]f the petition consists of more than one

separate petition paper, the statement of candidacy of the candidate or joint candidates named

need be signed by the candidate or joint candidates on only one of such separate petition papers,

but the statement of candidacy so signed shall be copied on each other separate petition paper”).

Thus, case law addressing either are equally applicable to both.

17

Thus, “the standard for reviewing technical defects in declaration of candidacy [or statements of

candidacy] and petition papers is whether the defect could cause a signer to be deceived or

misled.” State ex rel. Green v. Casey, 51 Ohio St.3d 83, 85, 554 N.E.2d 1288 (1990), implicitly

superseded on different issue by statutory enactment as recognized by Georgetown, 158 Ohio

St.3d 4, __ N.E.3d __, 2019-Ohio-3915 ¶¶19-20. This standard is premised upon the public

policy favoring free and competitive elections. As explained by this Court:

The public policy which favors free competitive elections, in which the electorate

has the opportunity to make a choice between candidates, outweighs the

arguments for absolute compliance with each technical requirement in the petition

form, where the statute requires only substantial compliance, where, in fact, the

only omission cannot possibly mislead any petition signer or elector, where there

is no claim of fraud or deception, and where there is sufficient substantial

compliance to permit the board of elections, based upon the prima facie evidence

appearing on the face of the jurat which is a part of the petition paper, to

determine the petition to be valid.

Saffold, 22 Ohio St.2d at 64, 258 N.E.2d 112 (quoting State ex rel. Stern v. Board of Elections,

14 Ohio St.2d 175, 237 N.E.2d 313 (1968)).

“Absolute compliance with every technicality should not be required in order to

constitute substantial compliance, unless such complete and absolute conformance to each

technical requirement of the printed form serves a public interest and a public purpose.” Stern

v., 14 Ohio St.2d 175, 180, 237 N.E.2d 313 (1968). Thus, courts and elections officials “must

avoid unduly technical interpretations that impede the public policy favoring free, competitive

elections.” Ruehlmann, 65 Ohio St.3d at 3. In rejecting the Statements of Candidacy and

Nominating Petition, the Secretary of State has failed to consider and follow the requirements of

the law and the public policy promoting free and competitive elections. Mr. WEST and Ms.

TIDBALL did all that the law required and, accordingly, the requested writ of mandamus should

issue.

18

B. Mandamus – Adequate remedy in the ordinary course of law.


In a mandamus action arising from the denial of ballot access, the proximity

of a forthcoming election establishes the lack of an adequate remedy in the


As for the final requirement to warrant the issuance of a writ of mandamus, i.e., the lack

of an adequate remedy in the ordinary course of law, this Court has repeatedly acknowledged

and held that an approaching deadline to finalize ballots, as well as the proximity of a

forthcoming election, sufficiently establish this element. E.g., State ex rel. Yeager v. Richland

Cty. Bd. of Elections, 136 Ohio St.3d 327, 995 N.E.2d 228, 2013-Ohio-3862 ¶16 (“[b]ecause of

the proximity of the November 5 election, and specifically the September 21, 2013 deadline for

finalizing ballots in accordance with [UOCAVA], Yeager has established that he lacks a remedy

in the ordinary course of the law”); see also State ex rel. Ohio Liberty Council v. Brunner, 125

Ohio St.3d 315, 928 N.E.2d 410, 2010-Ohio-1845 ¶27 (“[b]ecause of the proximity of the June

30 deadline to file the signed initiative petition with the secretary of state to have the proposed

amendment submitted to the electorate at the November 2, 2010 general election, relators lack an

adequate remedy in the ordinary course of law”).

IV. CONCLUSION

Mr. WEST and Ms. TIDBALL complied with the statutory requirements in order to be

placed on the forthcoming general election ballot as independent candidates for President and

Vice-President of the United States – they tendered original statements of candidacy, a

nominating petition (through 1,400 part-petitions with over 6,000 valid signatures of Ohio

electors), and a slate of presidential electors. In contrast, the Secretary of State has arbitrarily

19

and in derogation of the law rejected their Nominating Petition premised upon nothing more than

speculation and subjective opinion, all of which has been refuted by direct and uncontradicted

evidence before this Court.

With the standards for this extraordinary action having been satisfied, a writ of

mandamus should issue forthwith to compel FRANK LAROSE, as the Ohio Secretary of State:

(i) to accept the Statements of Candidacy and Nominating Petition of

KANYE WEST and MICHELLE TIDBALL as candidates for President

and Vice-President of the United States; and

(ii) to certify for placement on the official ballot for the forthcoming general

election to be held on November 3, 2020, the names of KANYE WEST

and MICHELLE TIDBALL as candidates for President and Vice-

President of the United States.

Respectfully submitted,

/s/ Curt C. Hartman

Curt C. Hartman (0064242)

The Law Firm of Curt C. Hartman

7394 Ridgepoint Drive, Suite 8

Cincinnati, OH 45230

(513) 752-8800

[email protected]

Attorney for

Relators Kanye West and Michelle Tidball

20

CERTIFICATE OF SERVICE

I certify that a copy of the foregoing will be served upon the following on this 31st day of

August 2020, via electronic mail:

Counsel for Respondent

Ohio Secretary of State Frank LaRose

Bridget C. Coontz

Halli Brownfield Watson

Senior Assistant Attorney General

30 East Broad Street, 16th Floor

Columbus, Ohio 43215-3431

[email protected]

[email protected]

Counsel for Proposed Intervenor-Respondent

Lewis Goldfarb

Donald J. McTigue

J. Corey Colombo

Derek S. Clinger

Ben F.C. Wallace

MCTIGUE & COLOMBO LLC

545 E. Town Street

Columbus, OH 43215

[email protected]

[email protected]

[email protected]

[email protected]

/s/ Curt C. Hartman

21

APPENDIX

Rejection Letter dated August 21, 2020

R.C. § 3501.39

R.C. § 3505.01(A)(1)

R.C. § 3513.257

R.C. § 3513.261

August 21, 2020

Matthew R. Aumann

Isaac Wiles

Two Miranova Place, Ste. 700

Columbus, OH 43215-5098

Re: Certification to the Ballot for Kanye West and Michelle Tidball

Dear Mr. Aumann:

I regret to inform you that Kanye West and Michelle Tidball will not appear on the

November 3, 2020 General Election Ballot as joint independent candidates for President and Vice

President of the United States. Under Ohio law, a nominating petition must include at least one

originally signed statement of candidacy, which may be copied on the other petition papers for

circulation.1 The statement of candidacy that was designated as the original in their filing does not

match the petitions circulated. In fact, the signatures for Michelle Tidball bear no resemblance,

calling into question which is genuine. Therefore, their nominating petition is rejected.

You may contact me if you have any questions.

Sincerely,

Amanda M. Grandjean

Director of Elections and Deputy Assistant Secretary of State

1 R.C. 3513.261; State ex rel. Hawkins v. Cuyahoga Cty. Bd. of Elections, 28 Ohio St.2d 4, 6, 274 N.E.2d 563

(1971); State ex rel. Rust v. Lucas Cty. Bd. of Elections, 101 Ohio St.3d 63, 2004-Ohio-9, 800 N.E.2d 1162 (2004).

Ohio Revised Code § 3501.39

Grounds for rejection of petition or declaration of candidacy.

(A) The secretary of state…shall accept any petition described in section 3501.38 of the Revised

Code unless one of the following occurs:

(1) A written protest against the petition or candidacy, naming specific objections, is filed, a

hearing is held, and a determination is made by the election officials with whom the protest is

filed that the petition is invalid, in accordance with any section of the Revised Code providing

a protest procedure.

(2) A written protest against the petition or candidacy, naming specific objections, is filed, a

hearing is held, and a determination is made by the election officials with whom the protest is

filed that the petition violates any requirement established by law.

(3) In the case of an initiative petition received by the board of elections, the petition falls

outside the scope of authority to enact via initiative or does not satisfy the statutory

prerequisites to place the issue on the ballot, as described in division (M) of section 3501.38

of the Revised Code. The petition shall be invalid if any portion of the petition is not within

the initiative power.

(4) The candidate's candidacy or the petition violates the requirements of this chapter, Chapter

3513. of the Revised Code, or any other requirements established by law.


Forms of official ballots.

(A)(1) …. on the seventieth day before the day of the next general election, the secretary of state

shall certify to the board of elections of each county the forms of the official ballots to be used at

that general election, together with the names of the candidates to be printed on those ballots whose

candidacy is to be submitted to the electors of the entire state.

but see H.B. 166, § 735.11 (133rd General Assembly)

Notwithstanding any provision of the Revised Code to the contrary, the major political parties shall

certify to the Secretary of State the names of the candidates for president and vice-president

nominated at their national conventions pursuant to section 3505.10 of the Revised Code not later

than the sixtieth day before the 2020 general election. Certification by the Secretary of State of

the forms of official ballots required by division (A) of section 3505.01 of the Revised Code shall

occur on or before the fiftieth day before the general election.


Independent candidates statements of candidacy and nominating petitions.

… Persons desiring to become independent joint candidates for the offices of president and vice-

president of the United States shall file, not later than four p.m. of the ninetieth day before the day

of the general election at which the president and vice-president are to be elected, one statement

of candidacy and one nominating petition for the two of them. The prospective independent joint

candidates’ statement of candidacy shall be filed with the nominating petition as one instrument.

The statement of candidacy and separate petition papers of each candidate or pair of joint

candidates shall be filed at the same time as one instrument.

The nominating petition shall contain signatures of qualified electors of the district, political

subdivision, or portion of a political subdivision in which the candidacy is to be voted on in an

amount to be determined as follows:

(A) If the candidacy is to be voted on by electors throughout the entire state, the nominating

petition…shall be signed by no less than five thousand qualified electors, provided that no petition

shall be accepted for filing if it purports to contain more than fifteen thousand signatures.

…

All nominating petitions of candidates for offices to be voted on by electors throughout the entire

state shall be filed in the office of the secretary of state. No nominating petition for the offices of

president and vice-president of the United States shall be accepted for filing unless there is

submitted to the secretary of state, at the time of filing the petition, a slate of presidential electors

sufficient in number to satisfy the requirement of the United States Constitution. …

…


Nominating petition form and fee.

A nominating petition may consist of one or more separate petition papers, each of which shall be

substantially in the form prescribed in this section. If the petition consists of more than one

separate petition paper, the statement of candidacy of the candidate or joint candidates named need

be signed by the candidate or joint candidates on only one of such separate petition papers, but the

statement of candidacy so signed shall be copied on each other separate petition paper before the

signatures of electors are placed on it.…

…

Each nominating petition shall contain a statement of candidacy that shall be signed by the

candidate or joint candidates named in it….

The form of the nominating petition and statement of candidacy shall be substantially as follows….

…

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