On January 4, Buffalo, New York Mayor Byron Brown filed this brief in Meadors v Erie County Board of Elections, w.d., 1:21cv-982. This is the lawsuit against the May petition deadline for New York independent candidates, a deadline created in 2019. Before 2019 the deadline had always been in August, September or October of election years.

The Mayor filed an independent petition in 2021, the year he was running for re-election. Although his petition had enough valid signatures, it was rejected because it had been filed after the deadline. The Mayor won injunctive relief against the deadline in U.S. District Court in 2019, but then the Second Circuit reversed, without comment. So he did not get on the November 2021 ballot and had to spend over $1,000,000 on a write-in campaign. He did get re-elected on write-ins.