U.S. SUPREME COURT HELPS INITIATIVE PROCESS FOR FIRST TIME SINCE 2015

On April 22, the U.S. Supreme Court ended its stay in Brown v Yost, 24A970, and thereby helped initiative proponents in Ohio.  This is the first action the U.S. Supreme Court has taken to help an initiative get on the ballot, or to take effect, since 2015.

The case involved Ohio procedures for initiative proponents to get permission to circulate their petitions.  Proponents write their own description of what their initiative does.  This goes on the petition form.

In Ohio, uniquely, proponents must get the Attorney General’s approval of their description.  A group that wanted to circulate a petition concerning wrongful criminal convictions submitted its description seven times, and each time the Attorney General rejected it, sometimes for the most picayune reason.  Once he rejected it because of a missing space between two words.  Many times, he only submitted one objection, and then when they tried again, he chose another “flaw” that had been in the earlier versions.  In other words, he wouldn’t combine all his objections.

Every time the proponents try again for approval, they must first collect 1,000 signatures.

The U.S. District Court ruled that the Attorney General’s behavior and the Ohio law that authorizes it violates the First Amendment.

But, it stayed its own injunction.  Then, on April 9, the Sixth Circuit lifted the stay by a 2-1 vote.  Judges Karen Nelson Moore (a Clinton appointee) and Andre Mathis (Biden) were in the majority.  Judge John K. Bush (Trump) dissented.

But on April 10, the U.S. Supreme Court reimposed the stay.  However, twelve days later, the U.S. Supreme Court lifted the stay, allowing the proponents to start circulating their petition.  They need approximately 400,000 valid signatures by July 2 if they want their initiative on the November 2025 ballot.  They are now hard at work on their petition.

The vote in the U.S. Supreme Court on April 22 was 6-3.  Justices who dissented are Clarence Thomas, Samuel Alito, and Brett Kavanaugh.

The core issue in the case is whether the description of the initiative is speech of the proponents of the initiative or government speech.  It seems intuitive that any group that intends to sponsor an initiative, and which must describe what the initiative says, is the speaker.

Not only had the Court not been helpful until this month; it had done great harm, especially in 2018-2021, in five separate cases, concerning the ability to get initiatives on the ballot.

During the covid health emergency in 2020, lower courts sometimes eased petitioning restrictions, such as allowing electronic signatures or extending petition deadlines.  But in Idaho, Ohio, and Oregon, after lower courts imposed relief, the U.S. Supreme Court countermanded that relief.  The cases were Clarno v People Not Politicians, 20A21 (Oregon); Little v Reclaim Idaho, 20A18  (Idaho); and Thompson v DeWine, 21-1120  (Ohio).  Courts in many states had extended similar relief to minor party and independent candidates, so the outcome for initiatives seemed unjust.

During the years 2019-2022, the Supreme Court also refused to hear cases on the issue of whether governments can prevent initiatives from circulating based on the content of the initiative.  Those cases were Save Tacoma Water v Port of Tacoma, 18-1518 (2019); and Schmitt v LaRose, 19-974 (2020).  The Tacoma case concerned a proposed initiative that would have limited new businesses that were expected to consume a great deal of the public water supply.  The Schmitt case involved local initiatives that would have concerned marijuana enforcement.

The last time the U.S. Supreme Court helped initiative proponents was in 2015 in Arizona State Legislature v Arizona Independent Redistricting Commission, 576 U.S. 787.  That decision, by Justice Ruth Bader Ginsburg, said the initiative process can be used to alter state election laws that affect congressional elections.  The vote was 5-4.

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MONTANA EASES INDEPENDENT PETITION

On April 11, the Montana Senate amended HB 207, a bill that had originally been introduced to make ballot access for independents more difficult, and transformed it into a bill that makes ballot access for independents somewhat easier.  On April 11, State Senator Janet Ellis, a Democrat, introduced an amendment lowering the petition requirement for non-presidential independents from 5% of the winner’s vote to 4%.  The amendment passed unanimously.

Then, on April 17, the House passed the amended bill, so the bill is through the legislature.

The bill also helps ballot access by saying that if an independent candidate tries to get on the ballot, but the petition fails, the candidate gets a refund of the filing fee.

The bill also bans “sore losers” from being write-in candidates in the general election.

Ironically, even with the lower petition, Montana still has the nation’s most severe petition for statewide non-presidential independents.  See the chart on page four, which lists each state’s requirement in percentage order.  Montana is still at the bottom.  The 2026 requirement is now 12,788 signatures, assuming the Governor signs the bill, down from 15,985.

Given that the original bill had raised the petition to 15% of the winner’s vote, the outcome is gratifying.  As far as is known, this is the first time in the history of any state in which a bill that began by increasing the petition requirement transformed into a bill easing the number.

HB 207 is the only bill to help ballot access that has passed in any state legislature this year.

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CALIFORNIA TOP-TWO LAWSUIT

On April 11, California filed a brief in U.S. District Court in defense of the top-two system.  Peace & Freedom Party v Weber, n.d. 3:24cv-08308.  The state says the state interest in a top-two system is to “increase voter choice and voter participation by permitting voters to vote in the primary for whichever candidates they prefer regardless of political party affiliation or non-affiliation.”

This is a weak argument, because there are many methods for California to let independent voters vote in primaries without eliminating minor party members from the general election ballot.  The state hopes to obscure that point by suggesting that there are only two election systems, top-two or a closed primary.

Footnote one says, “A closed partisan primary is one in which each party-affiliated voter votes for the nominee of their party to proceed to the general election.  A nonpartisan blanket primary is one in which any voter may vote for any candidate and only the top two vote recipients proceed to the general election.”  This footnote fails to mention five other systems:  (1) an open primary, in which any voter is free to choose any party’s primary ballot; (2) an Alaska top-four system combined with Ranked Choice Voting; (3) a Louisiana-type system, in which there is no primary and everyone runs in the general election; (4) a semi-closed primary, in which the law tells parties that they must let independents vote in their primaries; (5) a blanket primary, which would not be unconstitutional if it also provided that any party that doesn’t want a blanket primary is free to nominate by convention.

Option (4) above is becoming more popular.  New Mexico just switched to that system, and Maine, Arizona and Colorado did so a few years ago.

The state also argues that the purpose of the top-two system is to “winnow” candidates, but there is nothing in the definition of “winnow” that says all candidates but two should be “winnowed.”  The term “winnow” refers to sifting grains of wheat from nonedible chaff, and under that original meaning, plenty of grains of wheat survive the process.

Finally, the state argues that the top-two system must be left in place, because the State Court of Appeals upheld it in 2015 in Rubin v Padilla, 233 Cal. App. 4^th 1128.  But that decision had three fundamental factual errors, which are explained in the March 1, 2015 print edition of B.A.N.  Past print issues can be read online at www.ballot-access.org.  Links to past print issues are on the upper right side.

At least eight times in history, courts have upheld restrictive ballot access laws, but then a few years later invalidated them.

Sometimes the passage of time reveals that a restriction, thought to be reasonable, is in fact not reasonable.  The U.S. Supreme Court said in Storer v Brown in 1974, and in Mandel v Bradley in 1977, that a ballot access restriction that is rarely used is probably unconstitutional.  But it takes time to make such a determination.

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ARKANSAS INITIATIVE LAWSUIT

On April 21, a federal lawsuit was filed to overturn many new Arkansas restrictions on the initiative process and to overturn the relatively old ban on out-of-state circulators.  Arkansas League of Women Voters v Jester, w.d., 5:25cv-5087.  Among the restrictions attacked are new laws that:  (1) require circulators to examine the photo ID of each person who signs; (2) require circulators to tell each person that they approach that “petition fraud” is a felony; (3) require paid circulators to reveal their names and postal addresses in a publicly-accessible database before they can begin to work; (4) require petitioners to read the entire summary of the initiative to each person they approach; (5) bar any circulator for his or her lifetime from working if the circulator had ever been convicted of any felony; (6) require initiative sponsors to pay the costs of publishing their idea in newspapers, which can cost close to $100,000; (7) prohibit paying petitioners on a per-signature basis.

The case is assigned to U.S. District Court Judge Timothy L. Brooks, an Obama appointee.  The lawsuit will be aided by the recent action of the U.S. Supreme Court described on page one, Brown v Yost.

The League is also circulating an initiative to repeal some of these restrictions.  The League started before the new laws took effect.

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BOOK REVIEW: UNCHARTED

Uncharted: How Trump Beat Biden, Harris, and the Odds in the Wildest Campaign in History, by Chris Whipple,  2025.

Every U.S. presidential election is always followed quickly by books that describe the campaign.  Whipple’s book is the first to tell the history of the 2024 campaign.  Whipple had already written several books on presidential politics, and he was well positioned to write Uncharted because he already had a friendly working relationship with the leaders of the Trump, Biden and Harris campaigns.

Whipple made an editorial decision not to mention anyone who ran for president in the general election other than Trump, Biden and Harris.  The name “Robert F. Kennedy, Jr.” appears on only two pages in the book.  On page 61, he writes, “On April 19, 2023, Robert F. Kennedy, Jr., announced that he was running for the Democratic nomination for president…Yet no one other than Williamson and Kennedy had come forward.  And no one was taking them seriously.”

And, on page 166, Whipple describes the October 27, 2024 Trump rally in Madison Square Garden.  He lists some of the speakers, including “anti-vaccination activist Robert F. Kennedy, Jr.”.  That is the final mention of Kennedy.  The book entirely fails to tell the readers that Kennedy had declared as an independent presidential independenrin October 2023, that he had been as high as 15% in some reputable polls in June 2024, and that his supporters tended to be voters who otherwise preferred Trump to Harris.  The books fails to relate that the Democratic Party took elaborate steps to keep Kennedy off state ballots, to block him from the June 2024 presidential debate, to attack his funding sources, and even to deny him Secret Service protection (until after the July attempted assassination of Trump).

So, obviously, the book also fails to tell readers that Kennedy dropped out of the race in late August and endorsed Trump.

The book does relate that Harris was leading in August.  Page 145 says, “Morning Consult’s tracking of the race on August 26, 2024 found that she led Trump nationally, 48 to 44 percent” but the book does not include the breakdown of the missing eight percent.

The book never tells the readers that the minor party and independent vote for president was greater than the margin of victory.  It says on page 177, “2024 was the closest presidential race in modern history” but it never tells the readers that the final percentages were Trump 49.8%, Harris 48.3%, and all others 1.9%.  The only vote statistic in the book is on page 200, which says “A victory margin of 1.5% in the popular vote was no landslide.”

Whipple also says nothing about Trump’s appearance at the Libertarian convention in May, nor any mention of Jill Stein or any other candidates, nor of No Labels.  With his contacts with the campaign managers for Trump, Biden, and Harris, he could surely have obtained information about how the Democratic Party decided to attack No Labels and the Kennedy, Stein, and West campaigns, if he had asked.  And he could have learned information about how the chair of the Libertarian Party arranged to have Trump appear at the Libertarian convention.  But none of that is in the book.

Whipple concludes that Harris lost the election in early October 2024.   She was asked on The View “Would you have done something differently than President Biden during the past four years?  She replied, “There is not a thing that comes to mind.”

Whipple also concludes that, if Biden had withdrawn earlier, that might not have changed the outcome.

He says a competitive process might have left the Democratic nominee “battered and bloodied by an extended primary fight.”

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BALLOT ACCESS BILLS

California:  Assemblyman Christopher Ward (D-Coronado) has introduced AB 930, which would require some write-in candidates to pay filing fees.  However, in 1974, the State Supreme Court ruled that write-in candidates cannot be required to pay filing fees.

Connecticut:  on April 14, the Joint Committee on Government Administration and Elections passed SB 1156, which eases paperwork for minor party candidates for district office if their party already had statewide status.

Delaware:  on April 8, the House passed HB 65, which would move the non-presidential primary from September to April.  That would have the effect of requiring minor parties, which nominate by convention, to have held their conventions no later than February.

Maryland:  on April 3, the legislature passed SB 267.  It moves the petition deadline for new parties from August to July and requires minor parties to start all over again if their original petition lacks enough signatures.  The old law let them continue to add more signatures to the original petition.

Nevada:  the Assembly Committee on Legislative Operations & Elections has introduced AB 534, which would require non-presidential independent candidates to file a declaration of candidacy in February.

Texas:  two bills have been introduced to alter filing fees.  Current law says that fees paid by the major parties go to their own party, but filing fees paid by members of qualified minor parties go to the state.  SB 2197 and HB 4309 would change the filing fees for minor parties so all parties are treated equally.

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2026 INDEPENDENT U.S. SENATE PETITION REQUIREMENTS 

State	No. of Sigs	Percent	Code Reference	Formula
Alaska	0	.00%	15.25.010,15.25.030	pay fee, then place in top 4 in primary
Okla.	0	.00%	Title 26, 10-101	pay filing fee
Fla.	0	.00%	97.021	pay filing fee
Wash.	0	.00%	29A.24.091	pay fee, then place in top 2 in primary
Tenn.	25	.00+%	2-5-101	number stated in law
Hi.	25	.00+%	Title 2, sec. 12-6	number stated in law
Cal.	65	.00+%	Election code 8062	must place in top 2 in primary
Nev.	250	02%	Title 24, 293.200	number stated in law
N.J.	2,000	.05%	19:13-5	number stated in law
Minn.	2,000	.06%	204B.08	number stated in law
Wis.	2,000	.06%	Title 2, sec. 8.20(4)	number stated in law
Pa.	5,000	.07%	Consti. Pty of Pa v Cortes	number in court settlement
Utah	1,000	.07%	20-3-38	number stated in law
Miss.	1,000	.08%	23-15-359	number stated in law
Ohio	5,000	.09%	3513.257	number stated in law
Idaho	1,000	.11%	34-708A	number stated in law
Vt.	500	.14%	Title 17, sec. 2402(b)	number stated in law
R.I.	1,000	.19%	17-4-7	number stated in law
Iowa	3,500	.21%	Title 4, sec. 45.1	number stated in law
Mich.	12,000	.21%	Graveline v Johnson	number from 2018 court order
Va.	10,000	.22%	24.2-543	number stated in law
Ky.	5,000	.24%	Title 10, sec. 118.315(2)	number stated in law
Colo.	8,000	.25%	1-4-802	1,000 signatures each US House dist.
La.	5,000	.25%	Title 18, 464B.1	number stated in law
No.D.	1,000	.27%	16.1-12-02	number stated in law
Mass.	10,000	.29%	Chapter 53, sec. 6	number stated in law
Md.	10,000	.33%	elec. law 5-703(e)	number stated in law
Mo.	10,000	.33%	Title 9, sec. 115.321	number stated in law
N.H.	3,000	.36%	Title 4, sec. 655:42	number stated in law
Ks.	5,000	.38%	25-303	number stated in law
S.C.	10,000	.39%	7-9-10	number stated in law
Neb.	4,000	.42%	32-620	number stated in law
Ct.	7,500	.43%	9-453(d)	number stated in law
Ill.	25,000	.44%	10 ILCS 5/10-2	number stated in law
Me.	4,000	.48%	Title 21, sec. 494.5	number stated in law
N.Y.	45,000	..54%	Chap. 17, sec. 6-142	number stated in law
Tx.	80,778	.71%	Elec. code 181.005	1% of 2022 gub. vote
Ark.	10,000	.82%	7-302(5)(B)	number stated in law
S.D.	3,502	.82%	12-7-1	1% of 2022 gub. vote
W.V.	7,790	.98%	3-5-23	1% of 2024 Senate vote
Ore.	23,744	1.00%	249.735	1% of 2024 pres. vote
Ind.	36,944	1.26%	3-8-6-3	2% of 2022 Sec. of State vote
Ga.	70,083	1.33%	21-2-170	1% reg. voters as of Nov. 2022
Ariz.	(est.) 45,000	1.42%	16-341.E	3% of number of reg. indps, Jan 2026
No.C.	82,542	1.47%	163-122	1.5% of 2024 gub. vote
Del.	(est.) 7,550	1.52%	Title 15, sec. 3001	1% of reg. voters as of Dec. 2025
N.M.	14,246	1.54%	1-8-51	2% of 2022 gub. vote
Ala.	42,459	1.87%	17-9-3(a)(3)	3% of 2022 gub. vote
Wyo.	3,879	1.93%	22-4-402(d)	2% of 2024 U.S. House vote
Mt.	12,788	2.12%	13-10-601	4% of winner’s vote Senate 2024

This chart shows the 2026 petition requirements for independent candidates for U.S. Senate.  States with easier requirements for a new party than for a US Senate independent candidate are Arizona, Delaware, Hawaii, Mississippi, Montana, North Carolina, and Vermont.  The percentage is the number of signatures divided by that state’s 2024 presidential vote cast.  This seems the fairest.

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2026 PETITIONING FOR STATEWIDE OFFICES

	Party sigs	Indp sigs	LIB’T	GREEN	CONSTIT	FORWRD	Pty due	Indp due
Alabama	42,459	42,459	0	0	0	0	May 26	May 26
Alaska	(reg) 5,000	Pay fee	already on	*1,495	*766	?	May 4	June 1
Arizona	34,127	(est) 48,000	already on	already on	0	0	Nov 28, 25	May 6
Arkansas	10,000	10,000	*2,500	0	0	0	April 28	May 31
Calif.	(reg 75,000	65	already on	already on	189	*1,500	Dec 31 25	March 6
Colorado	10,000	8,000	already on	already on	clready on	*312	Jan 9	July 9
Conn.	no procedure	7,500	can’t start	can’t start	can’t start	can’t start	– –	Aug 10
Del.	(reg) 780	7,800	already on	already on	*232	?	Aug 25	July 15
D.C.	no procedure	3,000	can’t start	already on	can’t start	can’t start	– –	Aug 5
Florida	be organized	0	already on	already on	already on	already on	Apr 24	Apr 24
Georgia	72,680	70,083	*0	*0	*0	*0	July 14	July 14
Hawaii	861	25	already on	*900	0	0	Feb 20	June 2
Idaho	18,102	1,000	already on	0	clready on	0	Aug 30	March 21
Illinois	no procedure	25,000	can’t start	can’t start	can’t start	can’t start	– –	May 25
Indiana	no procedure	36,944	already on	*0	*0	*0	– –	June 30
Iowa	no procedure	3,500	0	0	0	0	– –	Aug 14
Kansas	20,180	5,000	already on	0	0	0	June 1	Aug 3
Kentucky	no procedure	5,000	can’ t start	can’t start	can’t start	can’t start	– –	Aug 11
Louisiana	1,000  + 5,000	5,000	*already on	*already on	154	31	June 17	June 17
Maine	(reg) 5,000	4,000	already on	already on	0	0	Jan 2	June 1
Maryld.	10,000	10,000	*500	already on	0	0	*July 1	Aug 3
Mass.	(reg) 45, 500	10,000	15,672	3,545	289	35	Feb. 1	July 28
Michigan	44,618	12,000	already on	already on	already on	0	July 16	July 16
Minn.	163,621	2,000	can’t start	can’t start	can’t start	can’t start	May 2	June 2
Miss.	be organized	1,000	already on	already on	already on	0	March 1	Feb. 2
Missouri	10,000	10,000	already on	0	*100	0	Muly 27	July 27
Montana	5,000	*12,788	already on	0	0	0	March 2	May 26
Nebraska	6,726	4,000	already on	0	0	0	Aug 3	Sept 1
Nevada	14,271	250	already on	0	already on	*200	May 12	May 12
N.Hamp	24,375	3,000	can’t start	can’t start	can’t start	can’t start	Aug 4	Aug 4
N Jersey	no procedure	2,000	0	0	0	0	– –	June 2
N Mex	3,560 +14,246	14,246	*already on	*already on	0	*200	June 25	June 25
N York	no procedure	45,000	can’t start	can’t start	can’t start	can’t start	– –	May 26
No Caro	13,979	83,874	already on	already on	*200	*4,000	May 17	March 3
No Dak	7,000	1,000	0	0	0	0	April 6	Aug 31
Ohio	57,678	5,000	already on	0	0	*2,000	July 1	May 4
Okla	34,599	0	already on	0	0	0	March 2	April 10
Oregon	29,294	22,445	already on	already on	already on	0	Aug 11	Aug 11
Penn.	no procedure	5,000	can’t start	can’t start	can’t start	can’t start		Aug 3
R.I.	17,884	1,000	0	0	0	0	Aug 3	July 10
So.Car.	10,000	10,000	already on	already on	already on	already on	May 3	July 15
So.Dak.	3,502	3,502	already on	0	0	0	July 1	April 28
Tenn	43,498	25	in court	0	0	0	Aug 5	April 2
Texas	71,030	71,030	already on	already on	can’t start	can’t start	May 26	June 25
Utah	2,000	#1,000	already on	0	already on	already on	Nv  30 ‘25	June 15
Vermont	be organized	500	already on	0	0	0	Dec 31 ‘25	Aug 6
Virginia	no procedure	10,000	can’t start	can’t start	can’t start	can’t start	—	June 16
Wash.	no procedure	0	can’t start	can’t start	can’t start	can’t start	– –	May 8
W.Va.	no procedure	7,478	already on	already on	already on	0	– –	Aug 3
Wisc.	10,000	2,000	already on	already on	already on	can’t start	April 1	June 1
Wyoming	5,201	5,201	already on	0	already on	0	June 1	Aug 24
#ON			*31	*18	12	*3

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SPECIAL ELECTIONS

Florida U.S. House 1:  in the April 1 special election, the percentages were:  Republican 56.86%; Democratic 42.26%; independent Stephen Broden .81%.   Broden had been the Constitution Party’s vice presidential nominee in 2024.  At the November 2024 election in this district, the percentages had been:  Republican 66.0%; Democratic 34.0%.  The district is centered around  Pensacola.

Florida U.S. House 6:  in the April 1 special election, the percentages were:  Republican 56.68%; Democratic 42.69%; Libertarian .36%; independent Randall Terry .27%.  Terry had been the Constitution Party presidential nominee in 2024.  At the November 2024 election, the results had been:  Republican 66.5%; Democratic 33.5%.  The district is centered around Daytona Beach.

Pennsylvania State Senate 36:  in the March 25 special election, the results were:  Democratic 50.04%; Republican 49.07%; Libertarian .89%.  In 2022, the last time this district voted, the only candidate on the ballot had been a Republican.

Pennsylvania State House 36:  in the March 25 election, the results were:  Democratic 63.47%; Republican 34.98%; Libertarian 1.55%.  In 2024, when this district  last voted, only a Democrat was on the ballot.

UNITED UTAH AND FORWARD PARTY MERGE

On April 26, two qualified Utah parties held a joint state convention and agreed to merge.  They are the United Utah Party and the Forward Party.  The Forward Party has a Utah state legislator.  Both parties are considered centrist.

DEMOCRATIC CONGRESSMAN MAY JOIN NO LABELS PARTY

News reports in mid-April say that Maine Democratic Congressman Jared Golden is thinking of changing his registration to the No Labels Party.  If he does he may then seek the No Labels nomination for Governor.  The No Labels Party is ballot-qualified in Maine.  Golden represents the Second District, which has its own electoral vote and which voted for Donald Trump in November 2024.  His primary petition will need the signatures of 2,000 members of the No Labels Party, which has 17,000 members.

NEW YORK CITY MAYOR ERIC ADAMS WILL RUN FOR RE-ELECTION AS AN INDEPENDENT CANDIDATE

On April 3, New York city Mayor Eric Adams said he will run for re-election this year as an independent candidate.  New York has elected mayors in the past who were not major party nominees.  In 1951, the city re-elected Vincent Impellitieri as an independent, and in 1969, it re-elected John Lindsay, who was the nominee of the Liberal Party.

Adams’ ballot label will be, “Safe Streets, Affordable City.”

OKLAHOMA LIBERTARIANS WIN SEVEN LOCAL ELECTIONS

Oklahoma held non-partisan local elections on April 1.  Seven members of the Libertarian Party were elected.  They were Roger Dale Merrill, Mayor of Beggs; Sammy Kruckenberg, Alva City Council; Eric Catman, Maysville Board of Trustees; David Moss, Dover Creek/Lamont School Board; Vanessa Hass, Achville Board of Trustees; Patrick Jackson, Lehigh City Council; and Dayanna Hollis, Warner Board of Trustees.

OKLAHOMA LIBERTARIAN PARTY LETS INDEPENDENTS VOTE IN ITS PRIMARIES

Oklahoma law lets each party decide whether to let independents vote in its primaries.  The Democratic Party also permits this, and the Republican Party never does.  The Libertarian Party, the only other ballot-qualified party, has changed its policy over the years.  On April 12, it decided to let independents vote in its 2026 primary, the first time it had done so since 2016.

WORKING FAMILIES PARTY WON’T NOMINATE ANDREW CUOMO FOR MAYOR OF NEW YORK

The Working Families Party has been ballot-qualified in New York starting in 1998, and it has never failed to nominate the Democratic Party nominee for any statewide race, nor for Mayor of New York City.  But this year, if Andrew Cuomo wins the Democratic nomination of Mayor of New York, the Working Families Party will nominate someone else.