In 2016, independent U.S. Senate candidate Paul Merritt sued the California Secretary of State for censoring his paid statement in the California Voters’ Handbook. The case, Merritt v Padilla, c.d., 8:16cv-606, is still in U.S. District Court. On January 10, the U.S. District Court called for a status conference on April 9, which seems to indicate that the Judge is not now ready to rule, and want further proceedings.
Merritt was an independent candidate and he said so in his statement, but the Secretary of State deleted his reference to being an independent candidate from the heading of his statement, and did not even tell him. The candidate only learned what had happened when his county election officials notified him. Still pending is the issue of whether his due process rights were violated.