NEW POLITICAL PARTIES REGAIN THE RIGHT TO RECEIVE UNLIMITED DONATIONS FROM INDIVIDUALS

On March 2, the U.S. Court of Appeals, D.C. circuit, ruled that a new political party can accept unlimited donations from individuals, as least as long as it doesn’t have a presidential nominee. Unity08 v Federal Election Commission, 08-5526. The decision is 15 pages long and was written by Judge Stephen Williams, a Reagan appointee. It was also signed by Douglas Ginsburg, another Reagan appointee, and Karen Henderson, a Bush Sr. appointee.

This is the first time the U.S. Court of Appeals, D.C., has ever ruled for a minor party or an independent candidate on any issue. It is also the first U.S. Court of Appeals victory for a minor party or an independent candidate, from any circuit, since 2008. In 2008, the 9^th and the 6^th circuits ruled in favor of Ralph Nader on petition circulator residency.

The Reform Party was founded by Ross Perot in September 1995. Perot spent lavishly on the new party. At the time there was no federal law controlling how much money any individual could donate to any political party. But in 2002, Congress passed the McCain-Feingold law, which set restrictions on how much money an individual could contribute to a political party. That limit was $25,000 per year, an amount indexed to inflation. But the McCain-Feingold law only controlled how much money an individual could contribute to an already-established party. It still didn’t restrict donations to a political party that wasn’t a "National Committee" as defined by the Federal Elections Commission.

The Federal Election Commission makes a case-by-case determination on whether a political party qualifies as a "National Committee." Ever since the FEC has had this authority, in 1976, it has only given "national committee" status to eight parties.

The eight parties, in order in which they received their status, are the Democratic, Republican, Libertarian, Socialist, Natural Law, Constitution, Reform, and Green Parties.

In 2006, the FEC ruled that new parties are subject to even more stringent limits than old parties. The FEC told Unity08, a new political party, that it could only receive $5,000 from any individual per year. The FEC decided that because Unity08 wasn’t a "National Committee", it must fit into some category. So the FEC said Unity08 must be a "Political Committee." The trouble with that is that a Political Committee is something that has been formed to work for a specific candidate for federal office, and Unity08 had no specific candidate in mind. It is because Unity08 never had any candidate that the D.C. Circuit ruled against the FEC.

The 2006 FEC ruling caused Unity08 to suspend its work of trying to qualify for the ballot. At the time, it had only qualified in two states, Mississippi and Florida. Although Unity08 did almost no more political work, it remained in existence, and continued to fight the FEC ruling. The U.S. District Court in D.C. upheld the FEC ruling on October 16, 2008, but that ruling has now been reversed.

It is possible that the ruling will be appealed, either to the entire U.S. Court of Appeals, D.C. circuit, or to the U.S. Supreme Court. The U.S. Solicitor General will decide. Any appeal to the full D.C. Circuit must be made by April 17. An appeal to the U.S. Supreme Court would be due by May 31.

Anyone reading this article might wonder if any existing "National Committtee" might be motivated to give up its status as a National Committee, to escape the McCain-Feingold limits on parties.

It is likely that the FEC would not permit an existing National Committee to opt out, if the FEC felt that the motivation for the request was to escape the donation limits. However, there is a precedent that a National Committee may retract its status. The Libertarian Party gave up its National Committee status in the mid-1980’s, but regained it a few years later. The advantage of being a National Committee is that a National Committee can give bigger donations to its candidates, relative to what other groups may give.

On March 26, two other important campaign finance decisions were handed down from federal courts.

Limits on Donations to Non-Party Groups: The U.S. Court of Appeals, D.C. Circuit, invalidated federal campaign laws that limit contributions to committees that make independent expenditures about candidates for federal office. SpeechNow.org v FEC, 08-5223. The decision was in front of all nine full-time judges of the circuit, and was unanimous. The Court upheld disclosure requirements for such groups. The law that was invalidated limited individual contributions to such groups at $5,000.

Limits on Donations to Political Parties: the U.S. District Court in Washington, D.C., upheld federal laws that restrict donations to political parties that are recognized as national committees by the FEC. Republican National Committee v FEC, 08-1953. The decision says that because the U.S. Supreme Court already upheld these laws in 2003, only that Court can strike these limits. This case will probably go to the U.S. Supreme Court.

On March 19, the U.S. Supreme Court asked Mississippi to file a response in Moore v Hosemann, 09-982. This is the first time the U.S. Supreme Court has asked a state government to respond to a ballot access cert petition filed by a minor party or independent candidate, since May 2004. Mississippi’s response is due April 19.

The case concerns whether Mississippi should have kept Brian Moore, the Socialist Party presidential candidate in 2008, off its ballot. He filed his presidential elector paperwork ten minutes too late.

If the U.S. Supreme Court asks the defendant to respond, the odds rise to 40% that the Court will then accept the case for review. The last time a ballot access cert petition filed by a minor party or independent candidate got this much interest from the Court was Zulick v Wise, 03-1300. That was a ballot access case from Pennsylvania. However, in that case, after Pennsylvania filed a response, the Court declined to hear the case (note: there have also been instances when the Court asked a state to respond to requests for injunctive relief).

The Supreme Court hasn’t agreed to hear a ballot access case involving a minor party or independent candidate since 1991, when it agreed to hear Norman v Reed, a case from Illinois.

The issues before the Supreme Court in Brian Moore’s case are procedural and do not involve the merits of the dispute itself. However, if the Court hears the case, that will send a signal that the Court does care about voting rights for minor party candidates.

One of the procedural issues is whether the state should have reimbursed Moore for the costs of hiring a process server. The other procedural issue is whether, when the 5^th circuit ruled that the case is not moot but that it belongs in state court, should the 5^th circuit have filed the case in state court for Moore, instead of telling Moore to file it himself.

On March 1, a 3-judge U.S. District Court ruled that South Carolina cannot enforce a new ballot access restriction because the state didn’t ask the Voting Rights Section of the U.S. Justice Department for permission. South Carolina is one of the states that must pre-clear all its election law changes. Gray v South Carolina Election Commission, 3:09-2126.

The particular restriction says that a candidate who wants to seek the nomination of more than one political party must file a separate declaration of candidacy for each party. The old rule just required one declaration of candidacy, so a candidate had the flexibility later to decide which nominations to seek.

No one would even have noticed that South Carolina changed its rules and then failed to pre-clear the change, except that in 2008 when a Green Party nominee tried to get the nomination of the Democratic Party as well, the state said he couldn’t do that because he had only filed one Declaration of Candidacy. That candidate, Eugene Platt, has a separate case pending in the 4^th circuit over whether he should have been allowed to be on the November ballot. That case will be argued on May 11.

The recent decision in the Gray case does not guarantee that Platt will win his case, but the Gray decision helps. Platt was kept off the November ballot, even though he was the Green Party nominee and the Green Party is a qualified party, because of another law: if someone gets one party nomination, and then tries and fails to get another party’s nomination, the first nomination is void. Because Platt lost the Democratic primary, he also couldn’t run as a Green.

In Doe v Reed, the case that the U.S. Supreme Court will hear on April 28 on the issue of whether petition signatures should be private, 47 organizations have filed amici briefs on the side of privacy. Amici briefs in favor of public exposure aren’t due yet.

On March 22, the 11^th circuit upheld Georgia’s petition requirement for independent and minor party candidates for U.S. House. Coffield v Handel, 09-13277. The decision is only three paragraphs long, and is not signed.

The decision says, "Coffield claims that Georgia’s 5% rule is too burdensome; she alleges no independent candidate for the House of Representatives in Georgia has met the requirement since 1964 and that no minor party candidate has ever met it. But she does not allege how many candidates have tried."

The implication is that if she had presented evidence that many candidates had tried and failed, perhaps the decision would have been different. However, the U.S. Supreme Court did not instruct lower courts to consider how many petitions failed. The Court said in 1974 in Storer v Brown, "Could a reasonably diligent independent candidate be expected to satisfy the signature requirement, or will it be only rarely that the unaffiliated candidate will succeed in getting on the ballot? Past experience will be a helpful, if not always unerring, guide: it will be one thing if independent candidates have qualified with some regularity and quite a different matter if they have not."

The 11^th circuit decision does not mention Storer v Brown. The Storer test has been cited by the U.S. Supreme Court as recently as 2008.

Coffield presented evidence showing that no petitioning candidate for U.S. House anywhere in the nation has ever overcome a petition requirement greater than 12,919 signatures. The decision does not mention that evidence. The Georgia requirement for Coffield’s district in 2008 was over 15,000 valid signatures.

Coffield will ask for a rehearing before all the full-time judges of the 11^th circuit.

In 2008, in Coffield’s district, only one candidate appeared on the November ballot.

During March, courts in California and Washington made decisions involving "top-two" election systems. "Top-two" systems provide that all candidates run on a single primary ballot, and all voters use that ballot. Then, only the top two vote-getters can be on the November ballot.

Washington: this state started using a "top-two" system in 2008. A lawsuit is currently pending in U.S. District Court over whether the system violates the associational rights of political parties as applied, and also whether the system violates the U.S. Supreme Court’s ballot access precedents, and finally whether the system violates the trademark of political parties that have trademarked their names. The case is Washington State Republican Party v Washington State and Washington State Grange.

On March 9, Judge John C. Coughenour rejected an attempt by the state and the Grange to eliminate the ballot access and trademark issues from the case. The Judge wrote, "Because of the parties’ continued ability to appeal those claims at least once, the Court would not under any circumstances require deletion of those claims from pleadings."

California: this state does not use a "top-two" system, but on June 8, voters will decide whether to use that system. On March 16, the California Court of Appeals re-wrote the ballot language, so that the ballot will say, "Proposition 14. Elections. Increases Right to Participate in Primary Elections. Changes the primary election process for congressional, statewide, and legislative races. Allows all voters to choose any candidate regardless of the candidate’s or voter’s political party preference. Ensures that the two candidates receiving the greatest number of votes will appear on the general election ballot regardless of party preference."

Opponents of Proposition 14 had tried and failed to persuade the Court that the ballot tell voters that the measure ends the right of political parties to appear on the November ballot.

Opponents wanted this language: "Elections. Primaries. Changes the primary election process for congressional, statewide and legislative races. Allows all voters to choose any candidate regardless of the candidate’s or voter’s political party preference. A candidate may choose to have his or her party preference, or lack thereof, indicated on the ballot. Provides that the two candidates receiving the greatest number of votes will appear on the general election ballot regardless of party preference. Eliminates the existing constitutional right of a political party that participated in the primary election to participate in the general election."

The California Constitution now contains a provision that says a political party that participates in the primary has a right to have the candidate who got the most votes in that party’s primary appear on the November ballot. It is unfortunate that voters will not be told that this provision will vanish if Proposition 14 passes. The provision guaranteeing parties the right to place their nominee on the November ballot was passed by the voters in 2004 with a 67.5% "yes" vote.

Alabama: the Coalition for Free & Open Elections held its annual meeting on February 28, and voted to spend $2,000 for a cert petition to the U.S. Supreme Court in Shugart v Chapman. Law professor Mark Brown will write the brief pro bono. COFOE thanks its donors. The issue in the Shugart case is whether a state may require more signatures for an independent candidate for U.S. House, than for an independent candidate for President. Alabama has six U.S. House districts, and yet requires more signatures for an office in just one-sixth of the state, than it does for a statewide office.

Arizona: on March 4, a Superior Court ruled that the state has the authority to tell Tucson that it must switch its city elections from partisan elections, to non-partisan elections. The city is appealing. The case is City of Tucson v State.

California: on March 11, a Superior Court in Sacramento ruled that the part of the state Constitution that requires a candidate to have lived in the district for one year before running for the legislature violates the U.S. Constitution. The case is Fuller v Bowen, 34-2010-80000452. The lawsuit was filed by Heidi Fuller, a candidate for State Senate in the Republican primary. One of her opponents is an Assemblyman who admits that he did not live in the district until December 30, 2009. Fuller had filed the lawsuit to remove that opponent from the ballot. She will appeal.

Colorado: the lawsuit against the state law that requires independent candidates to have not been registered in a party for an entire year is moving quickly. All briefs are due on April 2, and the oral argument will be in late April. The case is Riddle v Secretary of State, 09-cv-2680.

Colorado (2): on March 15, a federal lawsuit was filed against a state law that does not permit out-of-state residents to circulate initiative petitions. Independence Institute v Buescher, 10-cv-609.

Delaware: the Constitution, Green, and Working Families expect to file a lawsuit against the new law that doubles the number of registered voters needed for a party to be recognized. The lawsuit will not argue against the new requirement itself, but will argue that the state violates due process by making the new requirement go into effect immediately, instead of waiting until 2011.

Louisiana: on March 15, the 5^th circuit refused to rehear Libertarian Party v Dardenne, the case over whether the state should have printed the Libertarian, Socialist, and Reform Party presidential candidates on the 2008 ballot. The case will be appealed to the U.S. Supreme Court.

Massachusetts: on February 26, the U.S. Supreme Court asked the state to file a response in Simmons v Galvin, the case over whether the Voting Rights Act applies to laws that prevent felons from voting. The First Circuit had ruled 2-1 that the Act does not apply to this issue.

Michigan: on March 9, a State Court of Appeals ruled 2-1 that the list of which voters voted a Democratic presidential primary ballot in 2008, and which voters chose a Republican presidential primary ballot, is public information. The case is Practical Political Consulting v Land, 291176.

Montana: the lawsuit against the state’s March petition deadline for non-presidential independent is now in the 9^th circuit. Kelly v McCulloch, 10-35174. The lower court had said the plaintiffs lack standing.

Nevada: a Superior Court will hear Fasano v Ashjian on April 14. The issue is whether the Tea Party candidate for U.S. Senate should remain on the ballot. The Secretary of State put him on the ballot, but the Independent American Party sued to remove him, on the grounds that he didn’t change his registration from "Republican" to "Tea Party" until March 2, and the law required him to have done that by March 1.

New Hampshire: the Libertarian Party case on whether unqualified parties may use a stand-in presidential candidate on a petition is now in the First Circuit. The March 1 B.A.N. was in error when it said the Magistrate’s unfavorable February 17 could be appealed to a District Court Judge. New Hampshire federal court rules differ from most other districts. The case is Libertarian Party of N.H. v Gardiner, 10-1360. The First Circuit now has two cases on this subject; the other is from Massachusetts.

New Jersey: on March 16, a Superior Court ruled that the U.S. Constitution does not necessarily prevent states from providing for recall of members of Congress. The Court ordered the state to furnish petition blanks to a committee that wants to recall U.S. Senator Robert Menendez. Committee to Recall v Wells, Mercer Co., A-2254-09T1.

Oregon: on March 24, a U.S. District court upheld a law that requires paid initiative circulators to attend a class, before working. The court also upheld a law banning people who have ever been convicted of fraud from working. Walker v State, 08-06135.

North Carolina: on February 11, a third constitutional ballot access case was filed in this state. Mark Brody is attacking the petition requirement that independents for the legislature submit a petition of 4% of the number of registered voters. His case is Brody v State Board of Elections, state court, Mecklenberg Co., 10cvs-3216. Brody completed this petition as an independent candidate for the State House in 2008, and he polled 30%. He is running again in 2010, and he argues that he has already shown he has a modicum of voter support, so why should he be required to submit another petition?

Ohio: on March 25, the State Supreme Court restored a Libertarian Party candidate for the legislature to the Libertarian primary ballot. The Board of Election had removed him because his petitions forgot to fill in the blank asking for the date of the election. State ex rel Eshleman v Fornshell, 2010-0438.

Pennsylvania: on March 22, a Republican candidate for U.S. House, 1^st district, was removed from the primary ballot because some of her circulators don’t live in her district. However, in 2002, a U.S. District Court in Pennsylvania struck down a state law regulating residence of circulators for independent candidates. The Republican candidate, Pia Varna, expects to file a federal lawsuit against the residency requirement for primary ballot access circulators very soon.

On March 18, the Connecticut Joint Government Administration and Election Committee approved HB 5021, which deletes the parts of the public funding program that discriminate against independent candidates and against most minor party candidates. The bill eliminates the parts of the old law that require massive petitions before independent candidates can participate in the public funding program. Governor Jodi Rell is strongly backing this bill.

On March 3, the Colorado House passed HB 1271 by a vote of 58-7. Existing law says no one may be an independent candidate (except for President) if the candidate has been registered into a qualified party for even one day, during the year before filing. The bill eases that time period to approximately five months. The bill has a hearing in the Senate State, Veterans and Military Affairs Committee on March 29, and it is expected to pass.

The seven "no" votes on the House floor were cast by one Democrat, Edward Vigil, and six Republicans: Brian Del Grosso, James Kerr, Glenn Vaad, Kevin Priola, Mike May, and Larry Liston.

If the bill passes, California will be the only state that disqualifies independent candidates based on how they were registered during the year before the election.

During March, the legislatures of Minnesota and Vermont passed laws to move primaries from September to August. The bills take effect immediately. They both move the independent candidate deadlines to an earlier date. The Vermont bill, S.117, moves the petition deadlines from September to June, although that bill hasn’t been signed yet by the Governor. The Minnesota bill, SF 2251, moves petition deadlines for office other than president from July to June, and was signed March 3.

On March 2, the voters of Burlington, Vermont, repealed Instant Runoff Voting, by a vote of 3,972 to 3,669. The last Mayoral election had been won by the Progressive Party, and that outcome seems to have turned the Burlington Democratic Party against IRV.

STATE	REQUIREMENTS		SIGNATURES COLLECTED				DEADLINES
	FULL PARTY	CAND	LIB'T	GREEN	CONSTI	WK FAM	Party	Indp.
Ala.	37,513	37,513	100	0	0	0	June 1	June 1
Alaska	(reg) 9,786	#3,128	already on	*2,516	0	0	June 1	Aug. 24
Ariz.	20,449	(est) #25,500	already on	*finished	*1,700	0	Mar. 11	May 25
Ark.	10,000	10,000	*500	*1,000	0	0	June 30	May 3
Calif.	(reg) 88,991	173,041	already on	already on	in court	0	Jan. 6	Aug. 6
Colo.	(reg) 1,000	1,000	already on	already on	already on	0	June 1	June 15
Conn.	no procedure	#7,500	already on	already on	0	0	- - -	Aug. 11
Del.	(est) (reg) 300	(est) 6,200	already on	*571	*320	*550	Aug. 10	July 15
D.C.	no procedure	#3,000	can’t start	already on	can’t start	can’t start	- - -	Aug. 25
Florida	be organized	pay fee	already on	already on	already on	0	Apr. 30	Apr. 30
Georgia	57,582	#44,089	already on	0	0	0	July 13	July 13
Hawaii	692	25	already on	*finished	*too late	0	Apr. 1	July 19
Idaho	13,102	1,000	already on	0	already on	0	Aug. 27	March 19
Illinois	no procedure	#25,000	can’t start	already on	*200	*0	- - -	June 21
Indiana	no procedure	#32,742	already on	0	0	0	- - -	June 30
Iowa	no procedure	#1,500	0	0	0	0	- - -	Aug. 13
Kansas	16,994	5,000	already on	0	0	0	June 1	Aug. 2
Ky.	no procedure	#5,000	0	0	0	0	- - -	Aug. 10
La.	(reg) 1,000	pay $500	already on	already on	500	0	May 20	Aug. 20
Maine	27,544	#4,000	0	already on	0	0	Dec 11, 09	May 27
Md.	10,000	(est) 35,000	already on	already on	already on	0	Aug. 2	Aug. 2
Mass.	(est) (reg) 40,000	#10,000	already on	*1,000	80	20	Feb. 1	July 27
Mich.	38,024	30,000	already on	already on	already on	0	July 15	July 17
Minn.	145,519	#2,000	0	0	0	0	*Jun 1	*Jun 1
Miss.	be organized	800	already on	already on	already on	0	April 9	April 9
Mo.	10,000	10,000	already on	*1,400	already on	0	July 26	July 26
Mont.	5,000	#15,359	already on	*too late	already on	*too late	Mar. 18	Mar. 18
Nebr.	5,921	4,000	0	0	0	0	Aug. 2	Aug. 24
Nev.	9,083	9,083	already on	already on	already on	0	June 11	Mar. 12
N. Hamp.	20,394	#3,000	*250	0	0	0	Aug. 4	Aug. 4
N.J.	no procedure	#1,300	*200	*100	*70	0	- - -	June 2
N. M.	4,151	16,764	*finished	*in court	already on	0	Apr. 1	June 3
N.Y.	no procedure	#15,000	can’t start	can’t start	can’t start	already on	- - -	Aug. 17
No. Car.	85,379	85,379	already on	0	0	0	May 14	June 10
No. Dak.	7,000	#4,000	*finished	0	0	0	Apr. 9	Sep. 3
Ohio	* be organized	5,000	already on	already on	already on	*too late	*Feb. 3	May 3
Okla.	73,134	pay fee	0	0	0	0	May 1	June 9
Oregon	20,640	(est) 19,000	already on	already on	already on	already on	Aug. 26	Aug. 26
Penn.	no procedure	#19,056	*0	*600	*0	*0	- - -	Aug. 2
R.I.	23,589	#1,000	0	0	0	0	May 28	July 22
So. Car.	10,000	10,000	already on	already on	already on	already on	May 2	July 15
So. Dak.	8,389	3,356	0	0	already on	0	Mar. 30	June 8
Tenn.	in court	25	*in court	*in court	*in court	0	unsettled	April 1
Texas	43,991	43,991	already on	*500	*0	*0	May 24	May 10
Utah	2,000	#1,000	already on	0	already on	0	Feb. 15	March 15
Vermont	be organized	#500	already on	0	already on	already on	Jan. 1	*Jun 17
Virginia	no procedure	#11,000	*800	0	0	0	- - -	June 8
Wash.	no procedure	pay fee	0	0	0	0	- - -	May 15
West Va.	no procedure	#7,250	0	already on	*400	0	- - -	May 10
Wisc.	10,000	#2,000	already on	already on	can’t start	can’t start	June 1	July 13
Wyo.	4,988	4,988	already on	0	*4,400	0	June 1	Aug. 23
TOTAL STATES ON			29	17	16	4	``	`

#partisan label is permitted on the ballot (other than "independent").
*change from the Jan. 1 2010 chart.
Mississippi, New Jersey, Virginia, and West Virginia have no statewide race in 2010, so the entry is for a full slate for U.S. House.

The British Labour Party government announced on March 12 that it will introduce a bill to provide for an elected House of Lords, of 300 members. Elections for the House of Lords would use Proportional Representation. One-third of the Lords would be elected at each House of Commons election. Great Britain has been the only populous country in western or central Europe that has never used Proportional Representation for its national elections. If the bill is enacted, this event would be the biggest gain for Proportional Representation in many years.

On March 26, a Superior Court in Solano County, California, ruled that the lawsuit to settle the question of the identity of the true state officers of the American Independent Party may proceed. The case was filed on March 16, 2009, by the faction of the party loyal to the national Constitution Party, against the officers recognized by the Secretary of State. Those officers had declared Alan Keyes to be the party’s presidential candidate last year, so Keyes was on the California ballot instead of Chuck Baldwin.

The case has been stalled for a year because the defendants avoided being served. However, the judge ruled that the defendants were properly served last year. The case is King v Robinson, 033119. It was filed in Solano County because that is the home county of Markham Robinson, state chair of the Keyes faction.

To a certain extent, control of the party will also be influenced by the results of the June 8, 2010 primary for the AIP. The party’s partisan nominees are automatically on the state central committee, and the nominees may also appoint other members of that committee. Twenty-one individuals are running for partisan public office in the party’s primary, and the U.S. Senate, gubernatorial, and Controller primaries are contested.

The New York Libertarian Party has never been ballot-qualified, and it nominates by convention. This year, there is a vigorous contest between Warren Redlich, an attorney who is also running in the Republican primary, and Kristin Davis, who has the backing of Roger Stone, a long-time political consultant who was once a Republican but who no longer feels loyalty to the Republican Party. Each candidate believes that he or she is capable of polling 50,000 votes in the November election. A group whose gubernatorial nominee polls 50,000 attains (or retains) qualified party status. There is no other way to get that status. The convention is on Saturday, April 24, in Albany.

On March 17, Louisiana State Senator Troy Hebert changed his registration from "Democrat" to "independent." He is the first Louisiana State Senator to be a member of neither major party since 1916, when there were 5 Progressive Party State Senators in the Louisiana Senate. All Louisiana legislators are up for election in 2011.

New York: Jay Schneiderman has been a member of the Suffolk County legislature since 2003. He is considering whether to run for U.S. House, First District. If he runs, he would not try to obtain the nomination of either major party. He is very popular and was re-elected in 2008 with the nomination of all five ballot-qualified parties. He is doing polling to determine whether he could win as a non-major party candidate. The incumbent, Timothy Bishop, is a Democrat.

Rhode Island: Lincoln Chafee, independent for Governor, is leading in a Rasmussen Poll conducted in early March. He has 37% in a four-person general election.

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