On August 16, Michigan’s Secretary of State filed this brief in Graveline v Johnson, e.d., 2:18cv-12354. This is the case in which Chris Graveline, an independent candidate for Attorney General, challenges the number of signatures and the petition deadline. No one has completed the Michigan statewide independent petition since it was created in 1988, except for two independent candidates for president, Ross Perot in 1992 and Ralph Nader in 2004.