U.S. SUPREME COURT WON’T HEAR ALABAMA BALLOT ACCESS CASE, DESPITE EXTREME CIRCUIT SPLIT

COURT HAS REFUSED ALL 52 BALLOT ACCESS CASES SINCE 1991

On October 7, the U.S. Supreme Court refused to hear Hall v Merrill, 18-1362, an Alabama ballot access case. The refusal is shocking, because the lower court decision, from the Eleventh Circuit, is in disagreement with nine other Circuits that have considered the same issue. That issue is whether ballot access constitutional cases are moot just because the election is over. The Eleventh Circuit said that in special elections, constitutional ballot access casesare moot once the election is over.

Therefore, the Eleventh Circuit vacated the U.S. District Court decision that struck down the 3% petition in special elections. The basis for the U.S. District decision is that collecting signatures of 3% of the last gubernatorial vote is too difficult when the petitioning period is only three months or so. Alabama lets independent candidate petitions start to circulate any time, but obviously in a special election, when no one is expecting the election, the time is necessarily short.

Generally, the U.S. Supreme Court is expected to hear cases when there is a split among the various circuits. But the Court ignored that tradition in this instance.

Thus, the excellent decision from the U.S. District Court is now erased, although because it is reported in the Federal Supplement, anyone can still read it. The cite is 212 F.Supp.3d 1148 (m.d. 2016). It is quite lengthy and very solid in its analysis.

The U.S. Supreme Court said in 1969 in Moore v Ogilvie that constitutional ballot access cases are not moot just because the election is over. No other court ever said that somehow that principle doesn’t apply to special elections.

The Eleventh Circuit decision was 2-1, and was written by a judge who had previously been Attorney General of Alabama, William Pryor.

As a result of the Eleventh Circuit opinion, no one can ever bring a constitutional ballot access challenge in the Eleventh Circuit in a special election unless the case is expedited and is decided before the election is held. The Eleventh Circuit covers Alabama, Florida, and Georgia. Florida and Georgia don’t require petitions for any candidates in special elections, so the issue doesn’t really arise in those states. So the only practical effect is that Alabama, and no other state, is forever protected from a ballot access challenge in a special election, unless the court expedites the case, which is tough to do in the short time frames of a special election.

No candidate for a U.S. House special election in Alabama has ever managed to get on the ballot, in the entire history of government-printed ballots. So the outcome violates U.S. Supreme Court teaching that ballot access laws that are seldom used are probably unconstitutional.

Supreme Court Hostility to Minor Parties and Independent Candidates

The U.S. Supreme Court has refused to hear every election law cert petition presented by a minor party or independent candidate starting in 1992, unless the Republican Party or the Democratic Party was also a party to the same case. Most of these cert petitions have been filed in ballot access cases. The chart "SUPREME COURT REFUSALS TO HEAR BALLOT ACCESS CASES, 1992-2019" further down in this issue, lists all 52 ballot access cert petitions filed by minor parties and independent candidates starting in 1992. The Court has rejected all of them.

Supreme Court defeats for minor party and independents in other election issues (starting in 1992) are:

Debate exclusion: Marcus v Iowa Public Television (Iowa 1999); DeBauche v Trani (Virginia 2000); Nader v FEC (2001); Jones v Montana University System (Montana 2007; Johnson v Commission on Presidential Debates (federal 2018).

But, when an independent candidate won a debates case in the Eighth Circuit, and the public television station appealed that to the U.S. Supreme Court, the Court took that case and reversed it, even though there was no circuit split. That case was Arkansas Educational TV v Forbes, 1998. The decision, by Justice Anthony Kennedy, said each case must be decided on a case-by-case basis, so theoretically it should not have stopped other future debates cases from winning. But they did all lose in lower courts and the Supreme Court then rejected them.

Discriminatory public funding: Green Party of Connecticut v Lenge (Connecticut 2011).

Fusion: Swamp v Kennedy (Wisconsin 1992). The Seventh Circuit upheld a ban on fusion and the U.S. Supreme Court refused the case. But when the Eighth Circuit struck down Minnesota’s ban on fusion and Minnesota asked for U.S. Supreme Court review, the court accepted the case and reversed it. However, in defense of the Supreme Court, at least in that instance there was a circuit split.

Immunity for election officials who corruptly invalidate petition signatures: Tobin for Governor v State Board of Elections (Illinois 2002).

Discriminatory list of parties on voterregistration form: Arizona Libertarian Party v Reagan (Arizona 2016).

Discriminatory order of candidateson ballot: Sarvis v Alcorn (Virginia 2017).

Party Autonomy on Who Can Vote inits Primary: Clingman v Beaver (Oklahoma 2005). This is a case that a minor party won in the Tenth Circuit, over whether it was free to demand an open primary for itself. When Oklahoma asked for U.S. Supreme Court review, the Court took the case and reversed it, even though there was no circuit split.

Starting in 1992, the only cases in which a minor party or independent won in the lower court, and the state then asked for Supreme Court review, and the Court refused, are these five ballot access cases: Nader v Brewer (Arizona); Campbell v Davidson (Colorado); Lerman v State Board of Elections (New York); Libertarian Party of Virginia v State Board of Elections (Virginia); and Moore v Martin (Arkansas).

To summarize, starting in 1992, the Court has refused to hear all sixty election law cases brought by minor parties or independent candidates (unless there was a major party in the same case). But when a state filed a cert petition, the Court accepted the case four times out of nine, for a 44% acceptance rate. And every time the Court accepted a state’s cert petition, it ruled for the state.

As a final note, another very hostile act by the U.S. Supreme Court was its 2008 decision in Washington State Grange v Washington State Republican Party. This case is not covered in the analysis above because the Democratic and Republican Parties were also in the case. The Ninth Circuit had struck down the Washington state top-two system, but the Supreme Court reversed, at least as to the freedom of association issue. The Court did not decide the ballot access aspect. But when the ballot access case aspect returned to the Supreme Court, the Court refused to hear it (that refusal is included in the chart "SUPREME COURT REFUSALS TO HEAR BALLOT ACCESS CASES, 1992-2019" further down in this issue).

On October 9, California Governor Gavin Newsom vetoed SB 696, the bill that said no party could have "independent" or "independence" in its name. The Governor’s Veto Message said the bill was clearly aimed at the American Independent Party, which has been on the California ballot since 1968. He said the bill probably would violate the First Amendment. If the bill had not been vetoed, the party was prepared to sue. The bill said that the party had to choose a new name by October 29 or it would be removed from the ballot and all its registrants would be converted to independents.

The bill’s author, Senator Tom Umberg, said he would not ask that the veto be overridden, but he said he will introduce a similar bill in 2020. However, that bill could not take effect in time to affect the 2020 election.

During October, both "faithless elector" cases reached the U.S. Supreme Court. One is from Washington and one from Colorado. The two decisions conflict with each other. The Washington State Supreme Court said electors may be fined if they vote for someone in the electoral college who did not receive the most popular votes in the state. But the Tenth Circuit said the U.S. Constitution permits electors to vote for anyone who meets the constitutional qualifications.

The electors from Washington filed their cert petition on October 7, Chiafalo v Washington, 19-465. The Colorado government filed its cert petition on October 17, Colorado Department of State v Baca, 19-518. Probably the Supreme Court will decide to take these cases. That decision could be as early as December.

On October 22, U.S. District Court Judge Algenon Marbley issued an opinion in Libertarian Party of Ohio v Wilhem, s.d., 2:19cv-2501. He said that the law that dictates that the State Elections Commission will always have three Republicans, three Democrats, and one independent, is likely unconstitutional unless the state can show that it has a compelling reason to always exclude members of other parties.

He wrote, "The Commission is authorized to find violations of Ohio’s campaign fiancé laws, assess fines, and refer violations to the local prosecutor. These decisions, in theory, should not bear on political affiliation; rather, they should be objective determinations based on the law. It is difficult to ascertain why an individual who is affiliated with a minor political party cannot effectively perform this function, or even be considered for a position on the Commission."

However, the order also ruled against the Libertarian Party, on the issue of whether the party could sue the Commission for setting up gubernatorial debates in 2018 that did not have objective standards as to which candidates should be invited.

On October 22, the Pennsylvania Senate Government Committee passed SB 421, which repeals the straight-ticket device. Legislators from both major parties, and Governor Tom Wolf, support the bill.

The bill also eases the voter registration deadline from 30 days, to 15 days, before an election; authorizes early voting; makes it legal for voters who support a write-in candidate to use a rubber stamp; eases the deadline for absentee ballots to be received; and repeals the residency requirement for petition circulators.

On October 1, U.S. District Court Judge Morrison England explained why he had enjoined the California law that requires presidential primary candidates to show their tax returns. He had enjoined the law orally in court on September 19. At the time he said the law conflicts with federal law. But his written opinion on October 1 not only mentioned the conflict with federal law, but it also says that the state law violates the First Amendment (which protects voting rights), and it also adds a qualification for holding federal office, which states aren’t permitted to do. On October 8, the state filed notice of appeal to the Ninth Circuit. There was no request for an expedited hearing.

Meanwhile, on November 6, the State Supreme Court will hear arguments on whether the law violates the state Constitution.

California: on October 20, Rocky De La Fuente asked the U.S. Supreme Court to hear his case against the independent petition for presidential candidates, which requires almost 200,000 signatures to be collected in 105 days. De La Fuente v Padilla, 19-524.

Florida: on October 18, U.S. District Court Judge Robert Hinkle, a Clinton appointee, issued a 55-page ruling in Jones v DeSantis, n.d., 4:19cv-300. He said that no ex-felon can be prevented from registering to vote on the grounds that he or she hasn’t paid court fines or restitution, if that individual can’t afford to pay. So far the state has not filed a notice of appeal.

Georgia: on October 10, the Libertarian Party appealed its ballot access case to the Eleventh Circuit. Cowen v Raffensperger, 19-14055. The issue is the state’s petition requirement for U.S. House candidates, which are so severe no minor party has complied with it since it was passed in 1943.

New York: on November 12, the Niagara County Supreme Court will hear Hurley v Public Campaign Finance & Election Commission, E169547/2019. The issue is whether the Commission has the authority to eliminate fusion.

South Carolina: on October 18, oral argument was held in Inglis v South Carolina Republican Party, Richland Co., 2019-CP-4005486. The issue is whether the Republican Party broke its own rules when it cancelled the presidential primary. Party rules say only the state convention can make a decision like that, but the decision was made by the State Committee.

Utah: on October 10, the State Supreme Court upheld the law that lets opponents of an initiative have 30 days after an initiative petition has been submitted to try to persuade signers to remove their signatures. During that same period, the proponents cannot collect any more signatures. Count My Vote v Cox, 2019-UT-60. The law also requires a substantial number of signatures from 26 of the state’s 29 State Senate districts, so opponents can concentrate their work on just a few districts.

national: on September 27, U.S. District Court Judge Trevor McFadden, a Trump appointee, ruled against Willie Wilson in his lawsuit against the Democratic National Committee. Wilson was a candidate for the Democratic presidential nomination in 2016. He sued the party because it wouldn’t share its voter list, but the opinion said there is nothing unlawsuit about the party’s decision. Wilson v DNC Services, D.C., 1:17cv-730.

On September 26, New York Governor Andrew Cuomo signed A8228, which lets voters switch parties as late as February of an election year. The old law said they couldn’t switch later than October of the year before the election. The 2020 presidential primary is in April.

Alabama: on October 11, a U.S. District Court approved a settlement in State Conference of NAACP v Pleasant Grove, n.d., 2:18cv-2056. The case had been filed against the at-large election for city council. The settlement avoids the need for districts. Instead, when the five city council seats are up, any voter is free to cast five votes for a single candidate, or to cast a single vote for each of five candidates, or any combination in-between, such as two votes for one candidate and three for another.

California: on October 13, Governor Gavin Newsom vetoed SB 212, which would have let non-charter cities and counties use ranked choice voting to elect their own officers. Currently only charter cities and counties may use RCV. The Governor said some voters are confused by RCV.

New Mexico: on November 5, 2019, the city of Las Cruces will use ranked choice voting for the first time.

On October 7, California Governor Gavin Newsom vetoed AB 1451, which would have outlawed paying initiative petitioners on a per-signature basis, and which also would have required 10% of the signatures to be collected by unpaid individuals.

On October 11, the Commission on Presidential Debates announced the locations and dates of 2020 general election presidential debates. They will be on September 29, October 15, and October 22.

Errata: the August 1, 2019 B.A.N. carried a list of parties in each state with "independent" or "independence" in their names. The Michigan entry should have mentioned the Tisch Independent Citizens Party, not the American Independent Party.

State	Requirements		Signatures Collected			Three Types of Deadlines
	Full Party	Cand.	Lib’t	Green	Consti	Full Party	Pres Party	Pres. Ind.
Ala.	51,588	5,000	*500	0	0	Mar. 3	Mar. 3	Aug. 13
Alaska	(est) (reg) 8,358	#3,212	*7,238	*1,626	*524	May 4	Aug. 5	Aug. 5
Ariz.	31,686	(est) #37,000	already on	*3,900	600	Nv 29 2019	Sep. 4	Sep. 4
Ark.	*10,000	#1,000	*already on	0	already on	in court	Aug. 3	Aug. 3
Calif.	(es) (reg) 65,000	196,964	already on	already on	296	Oct 2 2019	July 6	Aug. 7
Colo.	(reg) 1,000	#pay $1,000	already on	already on	already on	Jan. 10	Aug. 5	Aug. 5
Conn.	no procedure	#7,500	already on	already on	can’t start	– –	Aug. 5	Aug. 5
Del.	(est.) (reg) 700	(est.) 7,000	already on	already on	*270	Aug. 23	Aug. 25	July 15
D.C.	no procedure	(est.) #5,000	already on	already on	can’t start	– –	Aug. 5	Aug. 5
Florida	132,781	132,781	already on	already on	already on	April 15	July 15	July 15
Georgia	64,354	#7,500	already on	0	0	July 14	July 14	July 14
Hawaii	757	#4,347	already on	already on	*1,000	Feb. 24	Aug. 5	Aug. 5
Idaho	13,809	1,000	already on	*1,000	already on	Aug. 31	Aug. 31	Aug. 24
Illinois	no procedure	#25,000	can’t start	can’t start	can’t start	– –	June 22	June 22
Indiana	no procedure	#44,935	already on	0	0	– –	June 30	June 30
Iowa	no procedure	#1,500	0	0	0	– –	Aug. 14	Aug. 14
Kansas	21,112	5,000	already on	*2,000	0	June 1	June 1	Aug. 3
Ky.	no procedure	#5,000	already on	can’t start	can’t start	– –	Sep. 4	Sep. 4
La.	(reg) 1,000	#pay $500	already on	already on	174	May 18	Aug. 21	Aug. 21
Maine	(reg) 5,000	#4,000	*270	already on	0	Jan. 2	Aug. 3	Aug. 3
Md.	10,000	10,000	*800	*3,000	0	Aug. 3	Aug. 3	Aug. 3
Mass.	(est) (reg) 45,000	#10,000	already on	already on	244	Feb. 4	Aug. 2	July 28
Mich.	42,506	30,000	already on	already on	already on	July 16	July 16	July 16
Minn.	129,365	#2,000	0	0	0	May 1	Aug. 18	Aug. 18
Miss.	be organized	1,000	already on	already on	already on	Feb. 1	Sep. 4	Sep. 4
Mo.	10,000	10,000	already on	already on	already on	July 27	July 27	July 27
Mont.	5,000	#5,000	already on	in court	0	*in court	Aug. 12	Aug. 12
Nebr.	6,980	2,500	already on	0	0	Aug. 3	Aug. 3	Aug. 3
Nev.	9,608	9,608	already on	0	already on	June 5	June 5	July 10
N. Hamp.	17,209	#3,000	can’t start	can’t start	can’t start	Aug. 5	Aug. 5	Aug. 5
N.J.	no procedure	#800	0	0	0	– –	July 27	July 27
N. M.	3,483	3,483	already on	already on	already on	June 25	June 25	June 25
N.Y.	no procedure	#15,000	already on	already on	can’t start	– –	May 26	May 26
No. Car.	11,778	70,666	already on	already on	already on	May 18	May 18	*March 3
No. Dak.	7,000	#4,000	*already on	0	0	Apr. 10	Aug. 31	Aug. 31
Ohio	44,296	5,000	already on	*4,000	0	July 1	Aug. 5	Aug. 5
Okla.	35,592	#pay $35,000	already on	0	0	Feb. 28	July 15	July 15
Oregon	27,960	17,893	already on	already on	already on	Aug. 25	Aug. 25	Aug. 25
Penn.	no procedure	#5,000	can’t start	can’t start	can’t start	– –	Aug. 3	Aug. 3
R.I.	18,758	#1,000	0	0	0	Aug. 3	Sep. 4	Sep. 4
So. Car.	10,000	10,000	already on	already on	already on	May 4	May 8	July 15
So. Dak.	3,393	3,393	already on	0	0	July 1	July 1	Aug. 4
Tenn.	56,083	275	0	0	0	Aug. 5	Aug. 5	Aug. 18
Texas	83,435	79,939	already on	already on	in court	May 25	May 25	May 11
Utah	2,000	1,000	already on	already on	already on	Nv 30 2019	Nv 30 2019	Aug. 17
Vermont	be organized	#1,000	already on	organizing	0	12/31 2019	Aug. 3	Aug. 3
Virginia	no procedure	#5,000	can’t start	can’t start	can’t start	– –	Aug. 21	Aug. 21
Wash.	no procedure	#1,000	can’t start	can’t start	can’t start	– –	July 25	July 25
West Va.	no procedure	#7,145	already on	already on	0	– –	Aug. 3	Aug. 3
Wisc.	10,000	#2,000	can’t start	can’t start	already on	April 2	Aug. 2	Aug. 4
Wyo.	4,018	4,018	already on	can’t start	already on	June 1	June 1	Aug. 25
States On			*36	*21	*15	~

# partisan label permitted.
*change since the last petitioning chart, which was in the August 1, 2019 newsletter.

STATE	REFUSAL DATE	NAME OF CASE	ISSUE
Ala.	Oct. 7, 2019	Hall v Merrill	Number of signatures in special elections
Cal.	March 26, 2018	Independent Party v Padilla	Can two parties use same word in name
Ky.	May 15, 2017	Libt. Party of Ky. v Grimes	How party remains on ballot
Ohio	Jan. 9, 2017	Libt. Party of Ohio v Husted	Petitions must show employer of circulator
Cal.	Oct. 13, 2015	Rubin v Padilla	Top-two primary
Mich.	Dec. 16, 2013	Libt. Party of Mich. v Johnson	Presidential sore loser ban
D.C.	March 18, 2013	Libt Party v D.C. Board of Elections	Failure to count write-ins
Wash.	Oct. 1, 2012	Libt Party of Wash v Wash Grange	Top-two primary
N.D.	April 16, 2012	Libt Party of N.D. v Jaeger	Minimum vote in primary
N.C.	Feb. 27, 2012	Greene v Bartlett	Independent candidate number of signatures
N.H.	Oct. 11, 2011	Libertarian Party of NH v Gardner	Political party protection of its name on ballot
Mass.	Oct. 3, 2011	Barr v Galvin	Presidential stand-ins on petition
Hawaii	April 4, 2011	Nader v Nago	Independent candidate number of signatures
Georgia	Jan. 18, 2011	Coffield v Kemp	Independent candidate number of signatures
Virginia	Sep. 30, 2010	Lux v Rodrigues	Residency requirement for circulators
Ala.	June 7, 2010	Shugert v Chapman	Independent candidate number of signatures
La.	June 7, 2010	Libertarian Party v Dardenne	Deadline for qualified party to submit electors
Illinois	May 18, 2009	Stevo v Keith	Independent candidate number of signatures
Maine	Aug. 20, 2008	Hoffman v Dunlap	Validity of signatures
Ala.	Jan. 7, 2008	Swanson v Chapman	Independent candidate number of signatures
Pennsy.	Oct. 1, 2007	Rogers v Cortes	Petitions needed for nominees of qualified parties
Pennsy.	Feb. 16, 2007	Romanelli v Election Board	Large fees when petition is held invalid
Pennsy.	Jan. 8, 2007	Nader v Seroty II	Large fees when petition is held invalid
Ohio	June 5, 2006	Lawrence v Blackwell	Independent candidate petition deadline
Oregon	May 23, 2005	Kucera v Bradley	Arbitrary invalidation of petition signatures
Texas	March 21, 2005	Nader v Connor	Independent candidate number of signatures
Pennsy.	Jan. 10, 2005	Nader v Seroty I	Burdensome procedure for checking signatures
Calif.	Nov. 29, 2004	Baum v Superior Court	Validity of certain type of write-in votes
Ohio	Oct. 26, 2004	Blankenship v Blackwell	Residency requirement for circulators
Pennsy.	Oct. 4, 2004	Zulick v Wise	Discriminatory law on fusion
Calif.	Jan. 13, 2004	Van Susteren v Shelley	Party can’t nominate a non-member
Georgia	March 10, 2003	Cartwright v Barnes	Minor party U.S. House number of signatures
Arizona	Dec. 16, 2002	Browne v Bayless	Independent candidate petition deadline
Ohio	Oct. 7, 2002	Nader v Blackwell	Ballot labels, candidates who use indp. procedure
Ohio	Oct. 1, 2001	Schrader v Blackwell	Ballot labels, candidates who use indp. procedure
Virginia	April 30, 2001	Wood v Quinn	Independent candidate petition deadline
Mich.	Oct. 9, 2000	Buchanan v Miller	State fails to adjudicate internal party dispute
P.R.	Oct. 2, 2000	Civil Action Party v Puerto Rico	Only notary-attorney may circulate petition
So. D.	Oct. 2, 2000	Nader 2000 v Hazeltine	When deadline held invalid, what relief due
Idaho	Sep. 28, 2000	Nader 2000 v Cenarrusa	Independent candidate number of signatures
Ohio	Oct. 5, 1998	Miller v Lorain Co. Bd. Elections	Independent candidate number of signatures
Fla.	Oct. 6, 1997	Libertarian Party of Fl. V Smith	Discriminatory filing fees
Ill.	Oct. 6, 1997	Libertarian Party of Il. V Rednour	Minor party U.S. House number of signatures
No.C.	March 25, 1996	McLaughlin v N.C. Bd. Elections	How a party remains on ballot
Okla.	Oct. 2, 1995	COFOE v McElderry	Write-in ban combined with tough ballot access
Ark.	Feb. 21, 1995	Langguth v McKuen	Independent candidate petition deadline
Kansas	Jan. 23, 1995	Hagelin for President v Graves	Independent candidate petition deadline
Me.	Oct. 11, 1993	Libertarian Party of Me. v Diamond	Number of signatures in small party primary
Illinois	June 21, 1993	Reed v Kusper	Must new party run a full slate
Calif.	Feb. 22, 1993	Lightfoot v Eu	Number of write-ins to win a party primary
Cal.	Sep. 24, 1992	Natural Law Party v Eu	Independent candidate petition deadline
Colo.	Apr. 20, 1992	Libertarian Party v Colo. Sec. of State	Party can’t nominate a non-member

On October 19, Don Blankenship attended the Constitution Party’s national committee meeting in Pittsburgh, Pennsylvania, and said in his speech that he would accept the Constitution Party presidential nomination if it is offered. He is former CEO of Massey Energy Company, the sixth largest coal company in the U.S. He was the party’s nominee for U.S. Senate from West Virginia in 2018, but he did not get on the ballot because he had also run in that year’s Republican primary for the same office.

The only minor party state legislator outside of Vermont is Roy Daryl Adams, of the Independent Party of Louisiana. He was elected to the House, 62^nd district, in a special election on March 30, 2019.

Louisiana held its regular election for state office on October 12, 2019. Adams placed first in a four-way race, but because no one got 50%, he must run again in the runoff being held on November 16. The district includes West Feliciana and East Feliciana Parishes, in the eastern part of Louisiana bordering the state of Mississippi.

A new party in California, the Common Sense Party, tried to register enough voters to gain qualified status. However, it fell short. The deadline was October 2, 2019, for new parties that wanted to participate in the 2020 congressional and legislative election. But it can still qualify for the presidential election; the deadline for that is not until July 2020. The state has still not released the registration data; the new issue of B.A.N. will carry the data. The party holds itself out as a centrist party.

On October 18, Hillary Clinton was interviewed on CNN. She said that the Russians are grooming someone to be a third party presidential candidate in 2020. She also said that 2016 Green Party nominee Jill Stein was a tool of the Russians.

Tunisia elected a president on September 15, with 26 candidates on the ballot. No one got a majority, and a runoff was held on October 13, which was won by an independent candidate, Kais Saief.

Canada held a parliamentary election on October 21. No party won a majority of seats. The Liberal government will remain in power only because it is supported by the New Democratic Party’s representatives in parliament.

However, the New Democratic Party will push the government to pass a law for proportional representation. It is possible that the Conservative Party will support that goal, because it got the most popular votes, but substantially fewer seats than the Liberal Party.

The Green Party elected three members to parliament, one from New Brunswick and two from British Columbia. This was the most the party had ever won.

The Approval Voting Party, which exists only in Colorado, recently became ballot-qualified, by increasing its registration above 1,000 members. Its purpose is to publicize Approval Voting, a voting system that lets voters vote for every candidate that they wish.