On May 29, Tyson Parker filed a notice of appeal in Parker v Duran, the lawsuit over the number of signatures needed for an independent candidate in New Mexico. Parker was an incumbent member of the Public Education Commission, a partisan elected office. He tried to run for re-election in 2014 but since he was an independent, he needed the signatures of 2,196 voters in his district. If he had been running as the nominee of one of New Mexico’s four ballot-qualified parties, he only would have needed 732 signatures. He submitted 1,379 signatures, not enough to meet the independent requirement.

He argued in court that the Constitution does not permit New Mexico to require three times as many signatures for an independent as for a minor party nominee, but the U.S. District Court upheld the law.