MINOR PARTIES WIN THREE BALLOT ACCESS SUITS

During the last month, minor parties won three constitutional cases:

New York: on June 19, the New York Libertarian Party won its lawsuit against a state law that gives qualified parties better treatment than unqualified parties. The case is Credico v New York State Board of Elections, eastern district, 10cv-4555.

In New York, a qualified party is any party that polled at least 50,000 votes for Governor in the last election. Unqualified parties place nominees on the November ballot by petition, so they also participate in elections, but they aren’t treated equally on the ballot.

New York permits two parties to jointly nominate the same candidate. If two qualified parties nominate the same candidate, the candidate is listed twice on the ballot, and voters are free to vote for that candidate under whichever party label they wish.

But if two unqualified parties jointly nominate the same candidate, that candidate can be listed on the ballot only once. The candidate must choose which party column to appear in, and then the other party that nominated him or her must have a blank spot for that office in its party column. The decision says that such a policy violates the Equal Protection Clause of the Fourteenth Amendment.

The case arose in 2010, when both the Libertarian Party, and the Anti-Prohibition Party, successfully petitioned for their statewide nominees. Both parties had nominated Randy Credico for U.S. Senate. Even though both parties had their own line of candidates on the ballot, Credico was only allowed to appear in the Libertarian column, not the Anti-Prohibition Party column. And therefore voters who wanted to vote for him couldn’t do that on the Anti-Prohibition Party line.

The most important part of the ruling, which makes this a valuable precedent, is that the Libertarian Party won the case, even though the court said the burden on the party and its voters is not "severe." Any voter was still free to vote for Credico. But the party still won the case because the Court ruled that there are no state interests for the policy. It is very rare for an Equal Protection ballot access to be won when the court finds the burden created by the discriminatory law is not severe. This precedent will be helpful in the pending Arizona case, over the state’s policy of printing only the Democratic and Republican Parties on the voter registration form, even though Arizona has five ballot-qualified parties, all of which have their own primaries.

The Board of Elections will probably appeal. The decision is by a Magistrate Judge, so the first appeal would be to a U.S. District Court Judge.

Tennessee: on June 17, U.S. District Court Judge William J. Haynes ruled that the state’s petition requirement for newly-qualifying parties, 2.5% of the last gubernatorial vote, is unconstitutional. He also ruled that it is unconstitutional for the state to always guarantee that the old major parties always get the best spot on the ballot for their nominees. And he held that the petition deadline of 90 days before the election is too early, at least in the context of the burdensome number of signatures. For 2014, the requirement is 40,042 valid signatures. Green Party of Tennessee v Hargett, middle district, 3:11cv-692. The Constitution Party is also a plaintiff.

Judge Haynes had made a similar ruling on February 3, 2012, but then the state had appealed. The Sixth Circuit then remanded the case back to the U.S. District Court. The Sixth Circuit felt the part of the ruling about the order of candidates on the ballot needed more evidence.

In response, the political party plaintiffs provided copies of the ballots of all 95 counties, proving that all Tennessee counties now use office-group ballots. The state had argued that some counties use party column ballots, and that putting minor party columns first on the ballot wastes space. But with an office-group ballot, there is no wasted space problem. Office-group ballots arrange the ballot as a list of the various offices up. For each particular office, all the candidates for that office are listed; then the ballot goes on to the next office. The decision notes that arranging all the candidates in surname alphabetical order, under the heading of the office they are running for, would be constitutional.

The Sixth Circuit had also said the 2.5% petition requirement isn’t unconstitutional on its face. So the new U.S. District Court decision explains that the 2.5% is unconstitutional as applied, given that Tennessee only requires 25 signatures for independent candidates, so there can’t be a state interest in requiring over 40,000 signatures for new parties.

Virginia: on May 29, the Fourth Circuit ruled that the ban on out-of-state circulators is unconstitutional. Libertarian Party of Va. v Judd, 12-1996. The U.S. District Court had come to the same conclusion earlier. This is the first case in which any minor party has won a constitutional election lawsuit against Virginia.

The state might ask the U.S. Supreme Court to reverse the ruling. Other circuits that have struck down bans on out-of-state circulators are the Sixth, Seventh, Ninth, and Tenth Circuits. However, the Eighth Circuit upheld them in 2001.

Connecticut, New Jersey, New York, and Pennsylvania are the only states that still ban out-of-state circulators for minor party and independent candidate petitions and enforce that law.

On June 6, a conference committee of the Arizona legislature added a new provision to an election law bill (HB 2305) that had already passed both Houses. The new provision makes it far more difficult for members of qualified minor parties to get on primary ballots. The new provision passed the legislature on the evening of June 13, hours before the legislature adjourned. Governor Jan Brewer signed the bill on June 19.

Because the provision was added by a conference committee, there were no public hearings on the ballot access provision.

The new law raises the number of signatures for minor party members to get on the primary ballot for statewide office from one-half of 1% of that party’s registration, to one-sixth of 1% of all registered voters. For U.S. House and legislature, the requirement changes from 1% of a party’s members, to one-third of 1% of all the registered voters in that district. For Libertarians running for statewide office, the requirement rises from 120 signatures to 5,376. Yet the bill does not relax the requirements on who can sign. Both under the old law and the new law, only members of that party, and registered independents, can sign.

Worse, the law already provides that candidates can’t be nominated by write-ins in the primary unless they receive a number of write-ins equal to the number of signatures needed to get on the primary ballot. By raising the petition requirements, the new law automatically hugely increases the number of write-ins to be nominated in the primary.

This part of the bill is likely to be declared unconstitutional, because in 1980 a U.S. District Court struck down the old Arizona law that required members of newly-qualifying parties who wanted to be nominated by write-ins in their own party’s primary to receive write-ins equal to one-tenth of 1% of all voters.

The case was Socialist Workers Party of Arizona v Mofford, civ80-293. In that case, the Socialist Workers Party only had 106 registered members but it was entitled to its own primary. The old law required 283 write-ins for the party to nominate anyone in its own primary for statewide office.

Another part of HB 2305 makes it illegal for a political party or a non-profit group to deliver voted absentee ballots to the county elections office. And if anyone else delivers a voter’s voted absentee ballot, the voter must sign an affidavit giving the person permission.

Still another part of the bill says that initiative and recall petitions must strictly comply with the law. Also, the bill says that voters will be removed from the list of permanent absentee voters if they fail two elections in a row to return their absentee ballot. Because these parts of the bill are strongly opposed by the Democratic Party, and by organizations representing Hispanic voters, it is very likely that a referendum petition will be attempted, to suspend the new law until the voters have a chance to vote on it. The petition needs 86,405 valid signatures by September 11, 2013, and if the petition succeeds, then the voters would determine on November 4, 2013, whether to implement the law.

The motives for the ballot access restriction are openly partisan. Republicans, who control both houses of the state legislature, passed the bill on a party-line vote, and some legislators openly said they hope to prevent Libertarians from running for Congress in 2014.

State Representative Adam Kwasman plans to run for Congress as a Republican in 2014 in the First District. He said he needed this bill, because in 2012, a Democrat won that seat by a vote of 122,774 to 113,594 for the Republican. The Libertarian in the race received 15,227 votes.

The same pattern existed in 2012 in the Ninth District, when the Democrat received 121,881 votes, the Republican received 111,630, and the Libertarian got 16,620.

There is no social science evidence that voters who vote Libertarian would vote Republican if the Libertarian candidate were not on the ballot. But, Republican legislators believe it anyway. Republican interest in this bill also came from the National Republican Congressional Committee. Daniel Scarpinato, a communications director for that committee, made a phone call to persuade Republican State Senator Steve Pierce to vote for the bill. Pierce had voted against the bill at first, but a few minutes later another vote was held and this time Pierce voted for it and it passed.

During the debate on the bill, Representative J. D. Mesnard, a Republican, said, "People try to manipulate the outcome of elections by putting third party candidates on the ballot." Ironically, the only known instance when either major party ever did that in Arizona was in 2010, when Republicans found eleven apolitical individuals and persuaded them to file for federal and state office in the Green Party primary. The Green Party then filed a lawsuit to remove these candidates, because it was clear that they had no interest or connection to the Green Party. Although the Green Party lost the case, six of the eleven then voluntarily withdrew. In the remaining five elections, the "sham" candidates, as the press labeled them, did not receive enough votes to alter the outcome.

On June 20, the Oregon legislature passed SB 146, which makes it easier for a party to remain on the ballot. The old law said when a party polls 1% for any statewide race, it is automatically on the ballot for the next election. The bill says that when a party meets the vote test, it is then on the ballot for the next two elections. The Green Party had initiated this idea, and Secretary of State Kate Brown put that idea into her omnibus election law bill. The bill passed almost unanimously. Similar laws passed recently in Utah and Nebraska.

On May 30, the California Assembly surprisingly defeated ACA 9, which would have provided that a write-in candidate for Congress or partisan state office who places second in the June primary cannot advance to the November election, unless the candidate polls a substantial number of write-ins. The number would have been approximately 3,000 for State Senate; 2,300 for U.S. House; 1,500 for Assembly; 100,000 for statewide office.

The reason this was surprising is that the Assembly had approved the companion measure to ACA 9 on May 23 by a vote of 65-8. In order for the idea behind these bills to become law, the legislature needed to pass both a bill (AB 141) and a constitutional amendment (ACA 9). It had seemed obvious that if the Assembly overwhelmingly liked the bill, it would also have liked the constitutional amendment. Fortunately, between May 23 and May 30, enough Democrats changed their mind to defeat the measure. Only two Democrats had voted against AB 141, but on May 30, thirteen Democrats did so. The May 30 vote was 46 in favor to 19 opposed. Although that is still a big majority for the measure, it needed 54 votes to pass (two-thirds of the Assembly) and members who abstain have the same effect as a "no" vote.

The American Civil Liberties Union lobbyist worked to defeat the bill. If it had passed the legislature and been approved by the voters, it would have created many one-candidate elections in the general election. In 2012 there were eight congressional or legislative elections in which only one candidate filed to be on the primary ballot, but in six of those districts, write-in candidates filed. Obviously, since current law says the top two vote-getters advance, that made an opening for a write-in candidate in the primary to come in second and advance to November.

The only minor party candidates for office (besides President) in November 2012 were three Peace & Freedom Party candidates, all of whom had been write-ins in the primary. If this measure had been in effect, they would have been excluded and zero minor party candidates would have been on the ballot (other than President).

On June 17, the Hawaii Democratic Party filed a lawsuit to prevent non-members from voting in its primaries. Hawaii has never had registration by party, and on primary day, any voter is free to choose any party’s primary ballot, or to choose a ballot that lists independent candidates. If the lawsuit wins, the state will be required to change the voter registration forms, so that they ask voters to choose a party on voter registration forms, or choose independent status.

Then, only registered Democrats would be able to vote in Democratic primaries. The case is Democratic Party of Hawaii v Nago, cv13-301. It was assigned to U.S. District Court Judge J. Michael Seabright, an appointee of President George W. Bush.

This is the first time any state Democratic Party has ever gone to court to close its primary. The Republican Parties of Idaho, South Carolina, and Virginia have done that. The Idaho Republicans won their case, and the Virginia Republicans got a partial victory. The South Carolina case is still pending.

Hawaii currently has a very restrictive law for independent candidates (for office other than President) to get on the November ballot. They must run in the September primary, and they must poll 10% of the vote, or else must outpoll one of the party nominees, or they can’t be on the November ballot. If the Democratic Party lawsuit wins, the legislature will need to change the system for independent candidates.

Recently, Kansas Secretary of State Kris Kobach, a Republican, re-interpreted Kansas election law to make it far more difficult for minor parties to remain ballot-qualified.

Current law, passed in 1984, is not worded clearly. It says a party remains on the ballot until it fails to poll 1% of the vote for any officer "elected from the state as a whole."

Every twelve years, in Kansas as in every state, there is a presidential election year with no U.S. Senate seat up. Such years, for Kansas, were 1988, 2000, and 2012. Kansas had no minor parties on the ballot in 1988. In 2000, though, the Libertarian Party and the Reform Party were both on the ballot. Neither one got 1% for President, but then-Secretary of State Ron Thornburgh interpreted the law to keep them on the ballot. This is because President is not an officer elected by Kansas, but by the entire nation.

The law was written in 1984 with input from Kansas Libertarian leader Bill Earnest. Earnest knew that minor parties in Kansas and in the nation usually don’t get as much as 1% for President, although in Kansas at least, they get far better percentages for other statewide office. It was his idea to word the law that way, for the purpose of giving parties a "free ride" in years when President was the only statewide office on the ballot. Former Secretary Thornburgh had worked in the Secretary of State’s office in 1984, and he remembered the intent of the law and interpreted it that way in 2000. But the current Secretary of State, who perhaps wasn’t even aware of this history, interpreted it to include President. Attempts are being made to persuade him to change his mind.

The only minor parties that have polled as much as 1% for President in Kansas in the last 80 years are the Conservative Party 1968, the Libertarian Party in 1980 and 2012, and the Reform Party in 1996.

On May 17, the Seventh Circuit upheld a ballot access restriction on qualified parties that was passed in 2009. Before 2009, if a qualified party didn’t nominate anyone in its primary, the party could still nominate someone after the primary was over, by party meeting. But in 2008, after the Green Party (which was qualified for its own primary back then) used that procedure to nominate some candidates, the legislature made the post-primary nomination process more difficult.

The 2009 law said a qualified party couldn’t use the party meeting method unless its nominee then submitted a petition. The law required 3,000 signatures for statewide office, 1,000 for State Senate, and 500 for State Representative.

The Republican Party is weak in Chicago, and couldn’t recruit any legislative candidates in most Chicago districts. But in 2012 it did nominate seven legislative candidates after the primary was over. Its nominees were unable to obtain the necessary petitions, so they filed a federal lawsuit saying there is no state interest in requiring them to submit petitions. After all, they were nominated by a qualified party, and the Republican Party has a modicum of support and is one of the only two ballot-qualified parties in Illinois at the time, and currently.

The U.S. District Court had dismissed the case on the grounds that it had been filed too late, and did not reach the merits. But the Seventh Circuit upheld the law. The case is Navarro v Neal, 12-3572. The decision was written by Judge John Tinder, a Reagan appointee, and signed by Judge Joel Flaum, another Reagan appointee, and Judge Diane Sykes, a Bush Jr. appointee.

The decision is stunningly illogical. It said that without the petition requirement, the ballot might contain so many names that it would resemble a telephone book.

The decision said in California in 2003, there were 135 candidates for Governor on the recall ballot. It said that in Florida, ten presidential candidates on the November 2000 ballot caused voter confusion in Palm Beach County.

The panel failed to grasp the fact that the Illinois law only applies to qualified parties, so even without the petition, there would have been two candidates on the ballot in those legislative races instead of just a Democrat.

The decision’s mention of California is irrelevant, because in California in the 2003 recall election, parties didn’t have nominees, so any person who submitted 65 signatures and a filing fee was on the ballot. If the California 2003 gubernatorial election had been a partisan election, there could have been only one nominee from each party on the ballot, so there would have been only one Democrat, not fifty; there would have been only one Republican, not forty-two.

The decision’s reference to Florida is also misguided. The Palm Beach County voters were confused in 2000 because of poor ballot design, not because 10 candidates on a ballot for any particular office is intrinsically confusing. Palm Beach County is famous for its "butterfly ballot" that year, in which it was difficult to tell which punchcard hole was connected to which candidate.

It is possible the plaintiffs will ask for U.S. Supreme Court review.

On June 13, the Rhode Island legislature passed the National Popular Vote Plan bills, SB 346 and HB 5575. Governor Lincoln Chafee hasn’t signed them yet, but he already said he would do so.

On June 12, the New York Assembly passed the National Popular Vote Plan bill, A4422. However, the legislature adjourned before the Senate could vote on it, although it did pass the Senate last year.

As noted in the June 1 B.A.N., the Sixth Circuit ruled in May that Michigan’s sore loser law applies to presidential primaries, and therefore the Michigan Secretary was correct to keep Gary Johnson (Libertarian nominee) off the November ballot last year, because his name had appeared on the January 2012 Republican presidential primary. This was a shocking decision, because no state had ever before kept a minor party candidate off the November ballot because he or she had run in a major party presidential primary. The party had asked for reconsideration.

On May 30, the Sixth Circuit asked the state to respond to the request for rehearing. This is a sign that the Court is taking the reconsideration request seriously.

BOOK REVIEWS: RESURRECTING DEMOCRACY and THE CENTRIST MANIFESTO

Resurrecting Democracy, by Robert A. Levine, 343 pages, 2011.

The Centrist Manifesto, by Charles Wheelan, 158 pages, 2013.

Robert A. Levine is a Connecticut physician. Charles Wheelan teaches public policy at Dartmouth College and has written other books, Naked Economicsand Naked Statistics. Both argue that the United States needs a new political party that would propose solutions for problems that are not being solved.

The bulk of the content of both books deals with policy. Neither of them talks about alternative voting systems, such as ranked-choice voting, preference voting, or proportional representation, which would make it easier for a new party to gain power. The very existence of these books shows that the impulses which resulted in the formation of the Reform Party in 1995, and Unity08 in 2006, and Americans Elect in 2010, are still strong. This is not suprising, since public discontent with both major parties is very high and is rising.

STATE	REQUIREMENTS		SIGNATURES COLLECTED				DEADLINES
	FULL PARTY	CAND	LIB’T	GREEN	CONSTI	Amer Ele	Party	Indp.
Ala.	44,829	44,829	*0	*0	*0	0	in court	in court
Alaska	(reg) 8,925	#2,975	already on	*1,818	*115	0	June 1	Aug. 26
Ariz.	23,041	(est) #31,000	already on	*3,000	0	already on	Feb. 28	May 28
Ark.	10,000	10,000	0	0	0	0	April 12	May 1
Calif.	(reg) 103,004	65 + fee	already on	already on	*304	already on	Jan. 2	March 7
Colo.	(reg) 1,000	#1,000	already on	already on	already on	already on	Jan. 8	July 10
Conn.	no procedure	#7,500	can’t start	already on	0	can’t start	– – –	Aug. 13
Del.	(est.) (reg) 650	(est.) 6,500	already on	already on	*401	*17	Aug. 19	July 15
D.C.	no procedure	(est.) #3,900	already on	already on	can’t start	can’t start	– – –	Aug. 6
Florida	0	pay fee	already on	already on	already on	*0	Sep. 1	July 15
Georgia	50,334	#50,334	already on	can’t start	can’t start	0	July 8	July 8
Hawaii	706	25	*400	already on	0	0	Feb. 20	June 10
Idaho	13,102	1,000	already on	0	already on	0	Aug. 30	March 14
Illinois	no procedure	#25,000	can’t start	can’t start	can’t start	can’t start	– – –	June 23
Indiana	no procedure	#34,195	already on	0	0	0	– – –	June 30
Iowa	no procedure	#1,500	0	0	0	0	– – –	Aug. 15
Kansas	16,776	5,000	already on	0	0	*0	June 2	Aug. 4
Ky.	no procedure	#5,000	can’t start	can’t start	can’t start	can’t start	– – –	Aug. 12
La.	(reg) 1,000	#pay fee	already on	already on	*110	*729	May 15	Aug. 15
Maine	28,639	#4,000	0	already on	0	0	Dec 12, 11	June 2
Md.	10,000	(est.) 40,000	already on	already on	0	*0	Aug. 4	Aug. 4
Mass.	(est) (reg) 43,000	#10,000	13,336	6,507	102	0	Nov. 5, 11	July 29
Mich.	32,261	30,000	already on	already on	already on	0	July 16	July 16
Minn.	146,297	#2,000	0	0	0	0	May 1	June 17
Miss.	be organized	1,000	already on	already on	already on	*0	April 4	April 4
Mo.	10,000	10,000	already on	0	already on	0	July 28	July 28
Mont.	5,000	#11,823	already on	*15	0	0	March 13	*May 27
Nebr.	4,880	4,000	already on	0	0	0	Aug. 1	Aug. 25
Nev.	9,738	9,738	already on	0	already on	0	April 11	Feb. 7
N. Hamp.	20,779	#3,000	0	0	0	0	Aug. 6	Aug. 6
N.J.	no procedure	#800	0	0	0	0	– – –	June 3
N. M.	3,009	18,053	already on	already on	already on	already on	in court	June 24
N.Y.	no procedure	#15,000	can’t start	already on	can’t start	can’t start	– – –	Aug. 19
No. Car.	89,366	89,366	already on	0	0	0	in court	June 12
No. Dak.	7,000	1,000	*1,500	0	0	0	Apr. 11	Sep. 5
Ohio	show support	5,000	already on	already on	already on	*0	unsettled	May 5
Okla.	66,744	pay fee	*0	*0	0	0	*March 3	April 11
Oregon	17,700	18,279	already on	already on	already on	*0	Aug. 26	Aug. 26
Penn.	no procedure	(est.) 25,000	can’t start	can’t start	can’t start	can’t start	– – –	Aug. 1
R.I.	17,115	#1,000	0	0	0	0	June 2	July 17
So. Car.	10,000	10,000	already on	already on	already on	already on	May 4	July 15
So. Dak.	7,928	3,171	already on	0	already on	already on	Mar. 25	June 3
Tenn.	40,042	25	0	0	0	0	Aug. 6	April 3
Texas	49,729	49,729	already on	already on	can’t start	can’t start	May 20	April 27
Utah	2,000	#1,000	already on	0	already on	0	March 1	March 17
Vermont	be organized	#500	already on	0	0	*0	Jan. 1	*June 12
Virginia	no procedure	#10,000	can’t start	can’t start	can’t start	can’t start	– – –	June 10
Wash.	no procedure	#pay fee	can’t start	can’t start	can’t start	can’t start	– – –	May 17
West Va.	no procedure	#6,516	already on	already on	0	0	– – –	Aug. 1
Wisc.	10,000	#2,000	*can’t start	0	already on	*can’t start	May 1	June 3
Wyo.	4,833	4,833	already on	0	already on	0	June 1	Aug. 25
TOTAL STATES ON			30*	20	15	6*	“	`

#partisan label permitted (other than "independent").
"AMER ELE" = Americans Elect Party.
* means entry changed since the last time this chart appeared (in the December 1, 2012 issue).

On June 25, President Obama gave an outdoor speech at Georgetown University on climate change. Near the end of the speech, at the 52 minute mark, he said, "I am willing to work with anybody, Democrats, Republicans, independents, Greens, Libertarians, anybody." It is believed this is the first time he has ever mentioned any U.S. political party (other than the Democratic and Republican Parties) in a public speech or statement. This appears to be true not only for the years since he has been President, but also during his 2007-2008 campaign for President.

On May 23, the Maine Supreme Court ruled in Nader v Maine Democratic Party, was-12-499, that Ralph Nader is not entitled to a trial against the Democratic Party for its insincere challenges to his ballot placement in 2004 in Maine and many states. Nader had won on this point in the lower court, and he had previously won in the Maine Supreme Court on the same matter, so this was a surprise. He asked for reconsideration, but it was denied on June 14. The Court said the evidence that Nader presented was not complete enough to justify a trial.

Also, on June 24, the U.S. Supreme Court refused to hear Nader’s appeal that the people who challenged his Pennsylvania petitions in 2004 should not be permitted to seize tens of thousands of dollars from his Washington, D.C. bank account for court costs. Nader v Seroty, 12-1294.

Nader had argued that after the court costs matter had been adjudicated, new evidence had come to light: his challengers had used state government resources and state employees for their challenge. Although some of the persons associated with the challenge went to prison, neither the Pennsylvania courts, nor the D.C. courts, were willing to re-open the court order that Nader pay his challengers.

On June 21, Rosanne Koss, a Southfield Township Trustee, announced that she had left the Republican Party and joined the Libertarian Party. The office is a partisan office.

Massachusetts: the unofficial returns for U.S. Senate are: Edward Markey, Democrat, 640,461; Gabriel Gomez, Republican, 521,688; Richard Heos, Twelve Visons Party, 4,513. The election was on June 25.

Missouri: returns for the June 4 U.S. House election, 8^th district, are: Jason Smith, Republican, 42,141; Steve Hodges, Democrat, 17,207; Doug Enyart, Constitution, 2,265; Bill Slantz,, Libertarian, 968.

On May 30, Rhode Island Governor Lincoln Chafee revealed that he had changed his registration from "independent" to "Democrat." He had been elected in 2010 as an independent. He plans to run for re-election in 2014 as a Democrat.

On June 25, the New Jersey Socialist Party sued the state elections office to obtain the ability of voters to register ino the Socialist Party. The only ballot-qualified parties in New Jersey, since 1920, have been the Democratic and Republican Parties. In 2001 the State Appeals Court upheld the ability of voters to register into unqualified parties (if they are parties that regularly place nominees on the ballot). The state now lets the six minor parties that sued have registration rights, but won’t extend this to any other minor parties. So the Socialist Party has been forced to file its own lawsuit. The case is Noble v State, Mercer County.

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