Electionline Weekly November-21-2024

Ballot Measures, Legislation & Rulemaking

Georgia Rulemaking: The Georgia State Board of Elections, which made headlines before the election, met for the first time since November 5. According to the Georgia Recorder, the board voted to request state lawmakers pass legislation next year making voter lists readily available to the public before and after elections. Board members have decided to forward their recommendations to the state Legislature rather than launch their own rulemaking process, which has recently resulted in several of their initiatives successfully challenged in courts. Board members Janelle King, Janice Johnston and Rick Jeffares, asked state lawmakers to pass legislation which would require each county to make publicly available a list of all eligible voters during and after every election. Democratic Election Board member Sara Tindall Ghazal said that publishing supplemental lists of eligible voters during an election could impose an administrative burden on counties. She stressed the need for a better understanding of this burden before making legislative recommendations.

Maine: Rep. David Boyer, R-Poland, said he filed a bill for the next legislative session to not require a ranked-choice count in a two-person race if one candidate does not receive at least 50 percent of votes due to blank ballots. Boyer also said he thinks a runoff is not needed if the number of votes received by a declared write-in candidate is not enough to defeat the winner. Under state rules in place since Maine began using the ranked-choice method in 2018, voters can rank as many or as few candidates as they would like. Those who only rank a second choice have their votes initially recorded as blank. If the race goes to a ranked-choice count, those second choices are counted as first choices. Boyer said he is not sure that he wants to tweak the rules on blank ballots with no first choice and subsequent rankings. He thinks Merenda’s vote total is proof she would not have significantly changed Golden’s lead and that his solution balances practicality with letting write-in candidates “get their voices heard.” “It’s a bad use of tax dollars when it’s clearly a two-person race,” Boyer said.

North Carolina: Republican lawmakers plan to transfer authority over the state’s Board of Elections to the state auditor’s office, a move that will place administration and appointment of its members under GOP purview. Changes would make it harder for people who use absentee ballots to have their votes count. The plan, included in a bill that also funds further aid for Hurricane Helene relief, would further strip power from the governor’s office, which currently has appointment power and will remain in Democratic control under Governor-elect Josh Stein. The measure also grants Auditor-elect Dave Boliek, a Republican, new jurisdiction after he defeated Auditor Jessica Holmes and flipped control of an office held by Democrats since 2009. The board’s powers would remain independent of the auditor’s office, according to the bill, but its budgeting and appointments would fall under the direction of the auditor. The auditor’s ability to make appointments would start on May 1, 2025. Karen Brinson Bell, the board’s executive director, said in a statement that the plan’s administrative changes could “make it impossible” for county boards to properly count votes. “State Board staff were not consulted about this significant piece of legislation that transfers authority of the State Board of Elections and makes substantial administrative changes that may make it impossible for the county boards of elections to adequately ensure every eligible ballot cast is counted, especially in high turnout elections,” Brinson Bell said.

Ohio Ballot Measure: Ohio Secretary of State Frank LaRose and the state ballot board cleared supporters of a citizen-led initiative aimed at enshrining greater voting access in the state constitution to begin collecting signatures. The board voted unanimously that The Ohio Voters Bill of Rights contains only one proposed amendment. The proposed amendment would grant counties the ability to set up multiple early vote centers or ballot drop boxes, create a system to update voter registration automatically when someone visits the BMV, and allow for same day voter registration. While the proposal accomplishes several different changes, supporters argued because all them relate to voting, the proposal represents a single amendment. “The Ohio Supreme Court has stated time and again that the ballot board has a clear legal duty to liberally construe the right of initiative,” petitioners’ attorney Jyoti Jasrasaria argued. “As long as the citizen initiated proposed amendment, there’s some reasonable relationship to a single general object or purpose, the board must certify its approval of the amendment as written without dividing it into multiple petitions.” Organizers tried a similar amendment in 2020 only to see their efforts derailed by the COVID-19 pandemic. Although they’ve now cleared the initial administrative hurdles, organizers will need to collect hundreds of thousands of signatures from across Ohio to make it onto the ballot.

Utah: Utah lawmakers are planning significant electoral reforms in the upcoming legislative session according to The Deseret News. Among the reforms include the creation of a new executive agency to manage elections independent of the Lieutenant Governor’s Office, similar to the secretary of state model Utah had until the lieutenant governor position was created in 1976. Rep. Trevor Lee, R-Layton plans to introduce a bill that would change state code so that only registered voters who request a mail-in ballot will receive one — as opposed to all registered voters automatically receiving one. This shift would keep vote-by-mail as an option for everyone that wants it but would “clean up the voter rolls in one swoop,” Lee said, for voters who have moved or died. Under this bill, voters would be able to opt in to receive future mail-in ballots by marking a box on their mail-in ballot in the upcoming election cycle, Lee said.

Lawmakers declined to recommend a bill that would have prevented the counting of mail-in ballots that arrive after polls close on Election Day. The bill was brought forward during the Legislature’s interim meetings last month and was voted down during a meeting of the Government Operations Interim Committee this week. Utah law requires mailed ballots be postmarked no later than the day prior to the election in order to count. The proposal was meant to address a controversy that arose during the June Republican primary election for Utah’s 2nd Congressional District, in which several hundred ballots were postmarked late and not counted. Colby Jenkins narrowly lost the race to Rep. Celeste Maloy and contended that the U.S. Postal Service was to blame for some of the ballots being marked late. Had those votes been counted, he argued, they may have changed the results of the election.

Legal Updates

Arizona: For a second time since Election Day, the Navajo Nation Department of Justice filed a lawsuit against Apache County. The lawsuit was filed Nov. 12, after learning about delays in processing early ballots for the 2024 general election. “This is not the first time we’ve seen these kinds of issues in Apache County, and sadly, it’s been an ongoing pattern of disenfranchisement in previous elections,” said Speaker Crystalyne Curley. “The Navajo Nation will continue to fight for our voters, holding Apache County accountable until every Navajo voice is heard and every vote is counted.” The first lawsuit, filed on Election Day, sought to grant Navajo voters in Apache County an additional two hours to vote due to ballot printer failures at several polling sites. The second lawsuit aims to extend the deadline for voters to correct signature discrepancies on their early ballots. Voters initially had until 5pm on Sunday, Nov. 10, to resolve signature issues, but on Nov. 9, the Navajo Nation Department of Justice discovered that Apache County had halted early ballot processing from Nov. 6 to Nov. 8. Additionally, 143 Navajo ballots required signature verification, and as of 5:20 p.m. on Nov. 9, Apache County still had 900 unprocessed early ballots. With just 48 hours to notify affected voters and allow them to cure their ballots, many encountered barriers such as limited cell service, restricted internet access, and long travel distances to the Apache County Recorder’s Office in St. Johns. The compressed timeline made it challenging for voters to receive timely notice and take necessary action. In addition to these delays, many Navajo voters struggled to reach the Recorder’s Office during the election. By the afternoon of Nov. 9, the Arizona Secretary of State’s website still indicated that their ballots had not been received by Apache County, prompting numerous calls to confirm their votes were counted.

California: Orange County Superior Court Judge Nico Dourbetas rejected California’s lawsuit against the city of Huntington Beach over a local measure allowing officials to require voter identification at the polls. Dourbetas ruled that existing state law does not block the local measure, which was approved by voters earlier this year. The ruling could clear the way for the majority-Republican city to implement one of California’s only voter ID requirements at the polls in local elections. “It’s a massive black eye to the state of California,” City Attorney Michael Gates said of the ruling. “And what the state of California needs to know, if they haven’t found out already, is Huntington Beach is not going to be intimidated or deterred.” State Attorney General Rob Bonta’s office said in a statement to The Associated Press that the Friday decision “does not address the merits of the case.” “We continue to believe that Huntington Beach’s voter ID policy clearly conflicts with state law, and will respond appropriately in court,” the office added. Residents in Huntington Beach voted in March for a ballot measure that lets local officials require voter identification at the polls starting in 2026. It also allows the city to increase in-person voting sites and monitor ballot drop boxes in local elections. A month later, Bonta filed a lawsuit, saying the measure approved in the city of nearly 200,000 people conflicts with state law and could make it harder for poor, non-white, young, elderly and disabled voters to cast ballots.

Georgia: Nicholas Wimbish, 25, of Milledgeville has been formally indicted after allegedly mailing a bomb threat to a polling precinct, according to the U.S. Attorney’s Office for the Middle District of Georgia. Wimbish faces a maximum of 25 years in prison for mailing a bomb threat, conveying false information about a bomb threat, mailing a threatening letter, and making false statements to the FBI. Officials said that the indictment alleges Wimbish, who worked as a poll worker for the Jones County Elections Office, had a verbal altercation with a voter on Oct. 16. A day after early voting started for the 2024 election in Georgia. A news release stated he later looked up online what information about himself was publicly available. The next day, he allegedly mailed a letter that said it was from a Jones County voter to the Jones County Elections Superintendent. According to the Justice Department, the letter, written from a voter’s perspective, stated that Wimbish was “conspiring votes” and “distracting voters from concentrating.” Wimbish allegedly lied to the FBI, stating that he believed the voter he interacted with sent the letter, but law enforcement found the letter on his computer, officials stated.

Illinois: Republican Congressman Michael Bost asked the U.S. Supreme Court to revive his twice-dismissed legal challenge to state law that allows election officials to count timely postmarked or certified mail-in ballots for up to two weeks after an election. A federal district court and the 7th U.S. Circuit Court of Appeals previously concluded that Bost and his Republican co-plaintiffs lacked standing to sue since they failed to demonstrate any harm attributable to the state’s 14-day receipt deadline.In a cert petition filed this week, Bost asked the U.S. Supreme Court to hold that he and the other GOP plaintiffs have standing to sue as candidates for federal office and to allow their case to proceed on the merits in a federal district court. According to the petition, the 7th Circuit’s dismissal contained “serious legal errors” and uprooted precedent allowing federal candidates to challenge a state’s regulations on the time, place or manner of federal elections. The litigants have argued that Illinois’ 14-day mail-in ballot receipt deadline effectively “expands” Election Day in violation of the U.S. Constitution and federal law, which requires states to hold Election Day on the Tuesday after the first Monday in November. Bost’s lawsuit also alleged that the two-week deadline allows “illegal ballots” to “dilute the value of timely ballots cast and received on or before Election Day.” Tuesday’s cert petition — which solely focuses on the issue of standing — maintains that the challenged ballot receipt deadline imposes burdensome financial costs on candidates, who must monitor ballot receipt and counting for an additional two weeks to ensure an accurate tally of votes.

Louisiana: Judge Tonya M. Lurry ruled against the third-place Plaquemine mayoral candidate’s lawsuit requesting to enjoin or halt the Dec. 7 runoff election due to alleged improprieties. No evidence could be found to support Tonya Harmason’s allegations of gerrymandering and bias, Lurry concluded in the hearing at West Baton Rouge Parish Courthouse in Port Allen. Harmason came up 33 votes short for a runoff against frontrunner JB Barker, who will face Plaquemine Selectman/Mayor Pro Tem Timmy Martinez in the election to determine the successor for retiring three-term officeholder Edwin M. “Ed” Reeves Jr. In court, Harmason alleged irregularity and potential bias because Registrar of Voters Kirsha Deshotel Barker is JB Barker’s daughter-in-law. Lurry said she did not see adequate evidence to support allegations of bias or that active voters from two districts had been removed from the electoral logs at polling locations where they voted in past elections.

Michigan: Calhoun Circuit Judge John Hallacy denied a request to stop re-tabulating the votes in the race for Michigan’s 44th state House District. WMUK reported last week that the race between Republican Steve Frisbee and Democratic incumbent Jim Haadsma in the state House District that includes Battle Creek was still in question. On November 13, the Calhoun County Board of Canvassers was sued by the Frisbee campaign seeking to stop the count. The dispute involves re-tabulating absentee ballots from Battle Creek. A programming error on Election Day meant about half of the city’s mail-in ballots weren’t included in the unofficial results. Chris Trebilcock, an attorney who represents Haadsma, said the Calhoun County Board of Canvassers is doing exactly what the law requires it to do. “The process allows for correction. Correction by the board of canvassers. Correction through a recount that may flip votes here or there when you do a hand recount,” Trebilcock said. “Quite frankly, this type of frivolous election litigation needs to stop. Calhoun County deserves better.”

The State Supreme Court has denied a request to weigh in on whether the results of a recall election in Flint should determine who takes a vacant seat on the Flint City Council. Last week the court granted immediate consideration of the request but denied a leave to appeal in the case of Beverly Biggs Leavy, who finished as the top vote-getter in the Nov. 5 recall election. Biggs Leavy was one of five candidates on the ballot in the 3rd Ward election that sought to remove the late Quincy Murphy from office. But because Murphy died on Sept. 29, just days after absentee ballots had been printed and became available to voters, city, Genesee County and state election officials said the results of the election would be invalid because Murphy’s death meant he was no longer an officeholder and therefore not subject to recall. Biggs Leavy, who sponsored the recall, challenged the election officials’ interpretation, filing a lawsuit against them and seeking to preserve the election results. The state Court of Claims dismissed her complaint against Secretary of State Jocelyn Benson and state Elections Director Jonathan Brater and the state Court of Appeals denied an immediate appeal, leading to the request to the Supreme Court. Biggs Leavy’s complaint against county Clerk-Register Domonique Clemons and Flint Clerk Davina Donahue were filed simultaneously in Genesee County where the case is pending. Clemons said on Wednesday, Nov. 20, that county attorneys have filed a motion for the lawsuit to be dismissed.

Minnesota: Timothy Michael Scouton — who was head judge at a precinct in rural Badoura Township in Hubbard County– is facing felony charges for allegedly allowing 11 unregistered voters to cast ballots November 5. Officials began investigating after Hubbard County Auditor Kay Rave could not find any completed voter registration forms among the ballots and other materials returned by Scouton according to a criminal complaint filed Friday. Another election judge told an investigator from the county sheriff’s office that Scouton directed them not to use the registration forms, the complaint said, while another said Scouton told them that new voters needed only to sign the back of a book. The complaint said the investigator then met with Scouton at the sheriff’s office. He was advised of his rights but declined to make a statement, and was then put under arrest, the complaint said. The complaint did not give a potential motive. Scouton made his initial court appearance Friday and was released pending his next hearing Jan. 6. He did not immediately return a call seeking comment Saturday, and his attorney declined to comment on the case. The office of Minnesota Secretary of State Steve Simon called the allegations “extremely serious” and said they must be thoroughly investigated. “Election judges take an oath to administer elections in accordance with the law, a deliberate failure to do so is unlawful and a betrayal of the public trust,” the office said in a statement.

Mississippi: A group of Mississippians who were stripped of their voting rights is asking the U.S. Supreme Court to strike a provision of the state Constitution that allows denial of suffrage to people convicted of some felonies. The Mississippi residents, through attorneys with the Southern Poverty Law Center and private law firm Simpson Thacher and Bartlett, filed an appeal Friday with the nation’s highest court. They argue that the provision of the state Constitution that strips voting rights for life violates the U.S. Constitution’s Eighth Amendment protection against cruel and unusual punishment. Jonathan Youngwood, global co-chair of Simpson Thacher’s litigation department, told Mississippi Today in a statement that after filing the petition with the Court, he remains confident in the case, and the firm’s clients remain committed to ensuring their right to vote is restored. “The right to vote is an important cornerstone of democracy,” Youngwood said. “Denying broad groups of citizens, such as those who have completed their sentences for criminal convictions, who deserve the full right of participating in our representative government, is inconsistent with the United States Constitution.” Under the Mississippi Constitution, people convicted of a list of 10 felonies lose their voting rights for life. Opinions from the Mississippi Attorney General’s Office have since expanded the list of disenfranchising felonies to 24.

Jenifer Branning, who is in a runoff for a seat on the Mississippi Supreme Court, has filed a lawsuit against the Hinds County Election Commission. Under state law, the votes must be certified within 10 days of the general election. The Hinds County Election Commission said Friday evening shortly before 5 p.m. that the absentee and affidavit ballots had been counted and certified following the Nov. 5 general election. “There is concern that the Hinds County Election Commission may not finish counting all votes from the Nov. 5 general election, which would be a violation of state law requiring that it be done by (Friday),” said Branning’s attorney Spencer Ritchie. “We are asking the court to force the Election Commission to do their job by today’s deadline to ensure that voters in all 22 counties of the Supreme Court central district — no matter which candidate they intend to vote for — will be able to vote by absentee ballot starting (Saturday).” Around 6 p.m. Friday, Election Commissioners signed off on the November 5 election results, after a marathon day of counting affidavit ballots and responding to a lawsuit filed by a candidate running for Mississippi Supreme Court. District 1 Election Commissioner Kidada Brown said the certification should nullify the suit, and absentee balloting for the upcoming judicial runoffs should begin Saturday.

Montana: Third Judicial District Court Judge Ray Dayton issued a preliminary injunction that orders Deer Lodge County Clerk and Recorder Toni Hofland and her team of election workers to count Joshua Cypher’s ballot for the November 2024 election while the rest of the case plays out. Cypher had registered to vote absentee in this year’s election, but Hofland rejected his registration application on the basis he was committed to the Department of Corrections on a felony despite being housed at the state hospital in Warm Springs. Cypher and Disability Rights Montana then sued. In response to Cypher’s lawsuit, Attorney General Austin Knudsen in October issued a new legal opinion that found that no felon – no matter whether they are involuntarily committed to the state hospital – enjoys the right to vote while serving their sentence. But Dayton wrote that despite the new opinion, the Attorney General’s Office admitted at a hearing that the state hospital was not a penal institution and that a court had never found Cypher to be of “an unsound mind.” “In this case, if the Court does not enjoin further interference with Mr. Cypher’s right to vote, he will suffer complete disenfranchisement by operation of the AG’s Opinion in this election and in other elections that occur during the pendency of this case,” Dayton wrote. Dayton granted the preliminary injunction, saying that the government’s admissions and the fact that the election had not been certified as of last Friday would mean preventing Cypher from voting would disenfranchise him in violation of the constitution.

North Carolina: Appeals Court Judge Jefferson Griffin sued the North Carolina State Board of Elections over the vote counting process in the Supreme Court race in which he is the Republican nominee. Griffin’s suit claims the elections board isn’t providing data quickly enough for him to request a recount prior to the Tuesday, November 19 deadline for counties that have completed their canvass. Many, but not all of North Carolina’s 100 counties have completed the canvas process at the time of filing the lawsuit on Monday, though they are expected to finish by the end of the day. It’s one of the closest contests in the general election. Griffin held a narrow lead of less than 10,000 votes over incumbent Democratic Justice Allison Riggs on election night. Since then, Riggs has crept ahead with results from additional provisional and absentee ballots. The two candidates were separated by a margin of 24 votes at the time of filing the lawsuit, according to the document. The State Board of Elections website reported a margin of 70 votes in Riggs’ favor out of more than 5.5. million cast as of 4:00 pm. Monday. “Defendants’ failures have impeded Plaintiffs’ efforts to meaningfully examine the 2024 General Election processes and unlawfully interfered with Plaintiffs’ ability to evaluate the potential need to file any protests in relation to the 2024 General Election,” the document read.

Ohio: Fiona Allen, 40, of Cleveland, has been accused of illegally voting in five different elections since 2020, according to the Cuyahoga County Prosecutor’s Office. Allen is a legal resident of the United States, prosecutors say she is not an American citizen. According to an indictment, however, that didn’t stop her from improperly registering to vote in March of 2020 before voting in that year’s November election, with more ballots to follow in the primary and general elections in both 2022 and ’23. A grand jury charged Allen with five counts of illegal voting and one count of false voter registration. If convicted, she could face up to 11 1/2 years in prison. Allen’s alleged crimes stem from March 7, 2020, when authorities say she filled out a voter registration card and answered “no” when asked if she was a U.S. citizen. Per officials, the card “explicitly states in the instructions that if you answer ‘no’ to the U.S. citizenship question, you should not complete the registration card,” though prosecutors did not indicate how her registration was even approved if she confirmed she was not a citizen.

Pennsylvania: The Pennsylvania Supreme Court court has directed three counties not to include undated or misdated mail ballots in their November election results. Such ballots have been the subject of years of litigation in various courts, and became an issue again after Bucks, Montgomery, and Philadelphia counties moved to count them for the Nov. 5 election. These are the ballots where a voter has neglected to write the date on the return envelope or written something incorrect, like their birthday. There are roughly 1,500 or so ballots in play in the three counties, likely not enough to change the outcome of the U.S. Senate race that is spurring the litigation. Attorneys for the counties had argued that officials there had constitutional concerns about rejecting the improperly dated ballots. They pointed to Commonwealth Court, which has ruled multiple times this year that rejecting mail ballots solely for an improper date violates the state constitution’s free and equal elections clause. A 4-3 majority of the state Supreme Court told the three counties not to include undated and misdated ballots in their counts. It clarified that the Commonwealth Court rulings do not apply to the Nov. 5 election.

Utah: A legal settlement over Native American voter access in San Juan County expired with the 2024 elections. Now, the American Civil Liberties Union of Utah says it would like to see an extension. The Navajo Nation Human Rights Commission and ACLU sued San Juan County in 2016 over voter access in Utah’s largest geographic county. The lawsuit alleged that San Juan County’s shift to vote-by-mail also created some hurdles to ballot access. Navajo is a primarily unwritten language and there were limited in-person polling locations, leading to long drives to vote. “We have a Native American culture that has a completely different language and it’s not a language that you can learn easily because it’s not written any place,” said San Juan County Commissioner Bruce Adams. “To get the people that can interpret that language at the polling places is probably the most difficult thing that we face.” The county and the plaintiffs reached a settlement that stretched from 2018 to this election cycle in 2024. That settlement has benefited voters, said Tara Benally, a San Juan County resident who also works on voter registration for the group Stewardship Utah. Adams said he believes things have been working out well. “I think we’ve gone out of our way to get interpreters where they’re needed, to get ads on the Navajo radio to get everybody informed whether they’re on the reservation or off the reservation. I think we’ve done a great job in trying to make sure that everybody gets a chance to vote,” he said.

Virginia: Omer Masoud, 23 of Woodbridge, arrested for voter intimidation on Election Day outside a Fairfax City polling place, according to the City of Fairfax Police. Officers responded around 4:17 p.m. on Nov. 5 for the report of a man making hand gestures and verbally threatening people outside the polls at the Sherwood Center at 3740 Blenheim Blvd., according to police. The officers arrested the suspect Masoud. After taking Masoud to the Fairfax County Adult Detention Center, police charged him with one count of voter intimidation and two counts of reckless driving. Mousod was held without bond. Mousod has a hearing scheduled for 9:30 a.m. on Dec. 10 in Fairfax City General District Court on the voter intimidation and reckless driving charges, according to court records.

Washington: Michele Tomes of Centralia has been one count of casting another person’s ballot after elections officials determined she signed two ballots in the August primary. Lewis County prosecutors accused Tomes of signing her name to her ballot and her 34-year-old son’s ballot. Tomes said she made a mistake. “I just didn’t think about it,” she told KING 5 News Monday at her Centralia home. Tomes said her son made the selections on the ballot, but she signed it. “I sign for him all the time,” said Tomes, who said her son has autism. Tomes said she is her son’s legal guardian. ”It’s a pretty clear-cut statute,” said Lewis County senior deputy prosecuting attorney Paul Masiello. “If you cast another person’s ballot, you’ve broken the law.” The Lewis County Auditor’s Office has identified five ballots submitted in the November general election that will be investigated for potential signature forgeries.

Wisconsin: The Wisconsin Supreme Court heard oral arguments this week in a lawsuit over Wisconsin Elections Commission (WEC) Administrator Meagan Wolfe’s ability to remain in her post. Several times during the arguments, justices and attorneys described the situation as “absurd” and “bizarre” as the Court is being asked to deal with the ramifications of a divided state government that has frequently deadlocked over executive appointments to boards and commissions and the Republican-held Senate’s confirmation of those appointees. In the summer of 2023, Wolfe’s initial four-year term as WEC administrator expired and Senate Republicans said they would not confirm her to a second term. The three Democrats on the commission, in an effort to shield Wolfe from the Senate, abstained from a vote to reappoint her while the three Republicans on the commission voted to nominate her again. State law requires a majority of the six member body to vote in favor of an administrator’s nomination, however, meaning the nomination wasn’t officially advanced to the Senate for a vote. But the Senate acted anyway, voting against Wolfe’s appointment. Democratic Attorney General Josh Kaul immediately filed a lawsuit arguing that under the precedent Republicans set in the Prehn decision, Wolfe is able to remain in her position as a holdover. At the circuit court level, Republicans admitted that the Senate vote to remove Wolfe was “symbolic.” But after a Dane County judge ruled in Wolfe’s favor, the GOP leaders appealed the decision to the Supreme Court. Assistant Attorney General Charlotte Gibson, the Department of Justice lawyer arguing on behalf of Wolfe, said that the statute that gives the commission the authority to appoint administrators does not require it to act when the administrator’s term expires. The administrator, she said, becomes a holdover appointee and serves at the will of the commission, who can fire her at any time.










NYC Wins When Everyone Can Vote! Michael H. Drucker