On January 10, the 6th circuit dismissed Ralph Nader’s Michigan ballot access case for procedure reasons. Nader v Land, 04-2428. In 2004, the Reform Party was on the ballot in Michigan. Even though the national convention of the Reform Party nominated Nader for president, one of the two factions of the Reform Party in Michigan told the Secretary of State that the state party desired to have no presidential nominee. Therefore, the Secretary of State didn’t list any Reform Party nominee in 2004, even though another faction of the state party wanted to list Nader.

Nader got on the ballot anyway in Michigan, as an independent. The 6th circuit said that since he got on the ballot anyway, he doesn’t have standing to complain about how the Secretary of State handled the Reform Party internal division.