Case: Reed-Pratt v. Winfrey

3:20-cv-12129 | U.S. District Court for the Eastern District of Michigan

Filed Date: Aug. 9, 2020

Closed Date: Oct. 5, 2021

Clearinghouse coding complete

Case Summary

On August 9, 2020, a Detroit resident and registered voter sued the Detroit city clerk, Detroit Department of Elections, and Detroit Election Commission, in the U.S. District Court for the Eastern District of Michigan challenging Detroit's absentee ballot processes. The plaintiff alleged that, during the June 2020 primary elections, Detroit sent absentee ballots to all registered voters regardless of whether the voters requested them. The plaintiff asserted that sending unsolicited absentee bal…

On August 9, 2020, a Detroit resident and registered voter sued the Detroit city clerk, Detroit Department of Elections, and Detroit Election Commission, in the U.S. District Court for the Eastern District of Michigan challenging Detroit's absentee ballot processes. The plaintiff alleged that, during the June 2020 primary elections, Detroit sent absentee ballots to all registered voters regardless of whether the voters requested them. The plaintiff asserted that sending unsolicited absentee ballots contravened state statutory and case law and violated her 14th Amendment substantive and procedural due process rights. The plaintiff also advanced a criminal contempt claim against the defendants, alleging that they violated a 2006 Wayne County Circuit Court permanent injunction. The plaintiff sought compensatory and punitive damages, interest, costs, and attorney's fees, declaratory relief, and an injunction prohibiting the defendants from sending unsolicited absentee ballots in the 2020 general election. The plaintiff also sought an order finding the defendants in contempt of the state court order and resulting fines or imprisonment. The case was assigned to Judge Robert H. Cleland.

On August 10, 2020, the plaintiff sought a temporary restraining order, which the court denied the next day, holding that the plaintiff was not likely to succeed on the merits. 2020 WL 6580621. On August 13, the court ordered the plaintiff to show cause why the state law claims should not be stayed or dismissed pending similar litigation in state court based on Colorado River abstention grounds. 2020 WL 4700830. On August 14, the plaintiff filed an emergency motion for reconsideration of the show cause order, alleging that the defendants made misrepresentations that led the court to issue the show cause order. The same day, the plaintiff amended her complaint to withdraw the criminal contempt claim and add a claim seeking a writ of mandamus ordering the defendants not to issue unsolicited absentee ballots. On August 17, the court denied the motion for emergency reconsideration, determining that the defendants had not misled the court. 2020 WL 4799009. The court again ordered the plaintiff to show cause why the court should not abstain on Colorado River grounds. The plaintiff did not oppose the order to show cause, and on August 20 asked the court to dismiss the state law claims without prejudice.

On September 9, 2020, the court held that declining supplemental jurisdiction to hear the state law claims was appropriate since the case presented "novel and complex state law issues" and accordingly dismissed the plaintiff's state law claims without prejudice. The court also stayed the plaintiff's federal law claims on Colorado River abstention grounds, determining that the state law claims being resolved in concurrent state court litigation were likely to resolve the case. 2020 WL 5491443. The plaintiff appealed the court's dismissal and stay order to the United States Court of Appeals for the Sixth Circuit on September 10. The plaintiff failed to file briefing in the Sixth Circuit on the appeal, so the Sixth Circuit dismissed the appeal for lack of prosecution on December 7, 2020. On January 19, 2021, the district court denied the plaintiff's motion for a preliminary injunction as moot because the injunction would have applied to the 2020 general election, which had already taken place. On October 5, 2021, the district court dismissed the case with prejudice by stipulation of the parties. The case is closed. 

Summary Authors

Kevin Decker (6/14/2022)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/17427919/parties/reed-pratt-v-winfrey/


Judge(s)

Cleland, Robert Hardy (Michigan)

Attorney for Plaintiff

Paterson, Andrew A. (Michigan)

Attorney for Defendant

Noseda, James D. (Michigan)

Judge(s)

Cleland, Robert Hardy (Michigan)

Attorney for Plaintiff
Attorney for Defendant

show all people

Documents in the Clearinghouse

Document

3:20-cv-12129

Docket [PACER]

Sept. 10, 2020

Sept. 10, 2020

Docket
1

3:20-cv-12129

Complaint and Jury Demand

Aug. 9, 2020

Aug. 9, 2020

Complaint
8

3:20-cv-12129

Order Denying in Part Plaintiff's Emergency Motion for Temporary Restraining Order and Preliminary Injunction, Directing Plaintiff to Serve Defendants, and Setting a Preliminary Injunction Hearing

Aug. 11, 2020

Aug. 11, 2020

Order/Opinion

2020 WL 2020

17

3:20-cv-12129

Order Denying "Ex Parte Motion for an Order to Show Cause," Adjourning Preliminary Injunction Hearing, and Ordering Plaintiff to Show Cause on Two Issues

Aug. 13, 2020

Aug. 13, 2020

Order/Opinion

2020 WL 2020

19

3:20-cv-12129

Amended Complaint and Jury Demand

Aug. 14, 2020

Aug. 14, 2020

Complaint
22

3:20-cv-12129

Order Denying Motion for Reconsideration, Ordering Plaintiff to Show Cause, and Setting a Telephone Conference

Aug. 17, 2020

Aug. 17, 2020

Order/Opinion

2020 WL 2020

24

3:20-cv-12129

Third Order to Show Cause and Adjourning without Date the Deadline for Filing a Responsive Pleading

Aug. 19, 2020

Aug. 19, 2020

Order/Opinion
29

3:20-cv-12129

Opinion and Order Dismissing Without Prejudice Plaintiff's State Claims, Staying Plaintiff's Federal Claim, and Denying Plaintiff's Emergency Motion for Leave to File Reply Brief

Sept. 9, 2020

Sept. 9, 2020

Order/Opinion

2020 WL 2020

35

3:20-cv-12129

Order Terminating as Moot Plaintiff's Motion for Preliminary Injunction

Jan. 19, 2021

Jan. 19, 2021

Order/Opinion
37

3:20-cv-12129

Stipulated Order of Dismissal

Oct. 5, 2021

Oct. 5, 2021

Order/Opinion

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/17427919/reed-pratt-v-winfrey/

Last updated March 27, 2024, 3:13 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT filed by Leigh Reed-Pratt against All Defendants with Jury Demand. Plaintiff requests summons issued. Receipt No: AMIEDC-7976517 - Fee: $ 400. County of 1st Plaintiff: Wayne - County Where Action Arose: Wayne - County of 1st Defendant: Wayne. [Previously dismissed case: United States District Court Eastern District of Michigan, 20-cv-11991, Judge Matthew Leitman] [Possible companion case(s): None] (Paterson, Andrew) (Entered: 08/09/2020)

Aug. 9, 2020

Aug. 9, 2020

Clearinghouse
2

Emergency MOTION for Temporary Restraining Order or in the Alternative, Motion for Preliminary Injunction with Respect to Count I by Leigh Reed-Pratt. (Paterson, Andrew) (Entered: 08/10/2020)

Aug. 10, 2020

Aug. 10, 2020

PACER
3

INDEX of Exhibits re 2 Emergency MOTION for Temporary Restraining Order or in the Alternative, Motion for Preliminary Injunction with Respect to Count I by Leigh Reed-Pratt Affidavits in Support from Plaintiff and Nonparty Robert Davis will be filed separately (Attachments: # 1 Exhibit Ex. B- Letter and Unsolicited Absentee Voter Application Defendants Mailed Plaintiff Reed-Pratt, # 2 Exhibit Ex. C- Approved Minutes from Defendant Detroit Election Commission's May 14, 2020 Meeting, # 3 Exhibit Ex. D- Published Michigan Court of Appeals' July 14, 2020 Opinion in League of Women Voters v Secretary of State, # 4 Exhibit Ex. E- Michigan Supreme Court's July 31, 2020 Order denying leave to appeal in League of Women Voters v Secretary of State) (Paterson, Andrew) (Entered: 08/10/2020)

Aug. 10, 2020

Aug. 10, 2020

PACER

A United States Magistrate Judge of this Court is available to conduct all proceedings in this civil action in accordance with 28 U.S.C. 636c and FRCP 73. The Notice, Consent, and Reference of a Civil Action to a Magistrate Judge form is available for download at http://www.mied.uscourts.gov (LGra)

Aug. 11, 2020

Aug. 11, 2020

PACER
4

SUMMONS Issued for *Detroit Department of Elections* (LGra) (Entered: 08/11/2020)

Aug. 11, 2020

Aug. 11, 2020

PACER
5

SUMMONS Issued for *Detroit Election Commission* (LGra) (Entered: 08/11/2020)

Aug. 11, 2020

Aug. 11, 2020

PACER
6

SUMMONS Issued for *Janice Winfrey* (LGra) (Entered: 08/11/2020)

Aug. 11, 2020

Aug. 11, 2020

PACER
7

RESPONSE to 2 Emergency MOTION for Temporary Restraining Order or in the Alternative, Motion for Preliminary Injunction with Respect to Count I filed by All Defendants. (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1, # 3 Exhibit 2) (Noseda, James) (Entered: 08/11/2020)

Aug. 11, 2020

Aug. 11, 2020

PACER
8

ORDER DENYING IN PART Plaintiff's 2 Emergency MOTION for Temporary Restraining Order or in the Alternative, Motion for Preliminary Injunction with Respect to Count I; DIRECTING Plaintiff to Serve Defendants and Setting Hearing :( Response due by 8/17/2020, Motion Hearing set for 8/19/2020 02:00 PM before District Judge Robert H. Cleland) (A Separate Zoom Webinar Notice to be issued) Signed by District Judge Robert H. Cleland. (LWag) (Entered: 08/11/2020)

Aug. 11, 2020

Aug. 11, 2020

Clearinghouse
9

NOTICE OF HEARING BY VIDEO CONFERENCE on 2 Emergency MOTION for Temporary Restraining Order or in the Alternative, Motion for Preliminary Injunction with Respect to Count I. Motion Hearing set for 8/19/2020 02:00 PM before District Judge Robert H. Cleland |Zoom Webinar Information: https://zoom.us/j/92818845066?pwd=N3Q4djhvc0JDVDZoRDUxc0MybVB0Zz09 Passcode: 415976 Or iPhone one-tap : US: +13017158592,,92818845066#,,,,,,0#,,415976# or +13126266799,,92818845066#,,,,,,0#,,415976#| (LWag) (Entered: 08/11/2020)

Aug. 11, 2020

Aug. 11, 2020

PACER
10

AFFIDAVIT of Robert Davis re 1 Complaint,, 2 Emergency MOTION for Temporary Restraining Order or in the Alternative, Motion for Preliminary Injunction with Respect to Count I by Leigh Reed-Pratt (Paterson, Andrew) (Entered: 08/11/2020)

Aug. 11, 2020

Aug. 11, 2020

PACER

Notice to Parties of Consent of a Civil Action before a Magistrate Judge Option

Aug. 11, 2020

Aug. 11, 2020

PACER
11

AFFIDAVIT re 1 Complaint,, 2 Emergency MOTION for Temporary Restraining Order or in the Alternative, Motion for Preliminary Injunction with Respect to Count I by Leigh Reed-Pratt (Paterson, Andrew) (Entered: 08/12/2020)

Aug. 12, 2020

Aug. 12, 2020

PACER
12

Ex Parte MOTION for Order to Show Cause why Defendants Should Not Be Held In Criminal Contempt Under Michigan Law Pursuant to MCR 3.606(A) by Leigh Reed-Pratt. (Attachments: # 1 Index of Exhibits, # 2 Exhibit Ex. A- Asst. Attorney General Heather Meingast Email to Activist Robert Davis) (Paterson, Andrew) (Entered: 08/12/2020)

1 Index of Exhibits

View on PACER

2 Exhibit Ex. A- Asst. Attorney General Heather Meingast Email to Activist Robert

View on PACER

Aug. 12, 2020

Aug. 12, 2020

PACER
13

EXHIBIT Exhibit B- Michigan Court of Claims' Opinion and Order denying motion for preliminary injunction in the matter of Cooper-Keel v Benson re absentee ballot apps re 12 Ex Parte MOTION for Order to Show Cause why Defendants Should Not Be Held In Criminal Contempt Under Michigan Law Pursuant to MCR 3.606(A) by Leigh Reed-Pratt (Paterson, Andrew) (Entered: 08/12/2020)

Aug. 12, 2020

Aug. 12, 2020

PACER
14

CERTIFICATE of Service/Summons Returned Executed. Janice Winfrey served on 8/12/2020, answer due 9/2/2020. (Paterson, Andrew) (Entered: 08/13/2020)

Aug. 13, 2020

Aug. 13, 2020

PACER
15

CERTIFICATE of Service/Summons Returned Executed. Detroit Election Commission served on 8/12/2020, answer due 9/2/2020. (Paterson, Andrew) (Entered: 08/13/2020)

Aug. 13, 2020

Aug. 13, 2020

PACER
16

CERTIFICATE of Service/Summons Returned Executed. Detroit Department of Elections served on 8/12/2020, answer due 9/2/2020. (Paterson, Andrew) (Entered: 08/13/2020)

Aug. 13, 2020

Aug. 13, 2020

PACER
17

ORDER DENYING 12 ExParte Motion for an Order to Show Cause and ADJOURNING Preliminary Injunction Hearing; ORDER for Leigh Reed-Pratt to Show Cause why the entire case should not be stayed or dismissed without prejudice pursuant to issues of comity, federalism and abstention and why the court should not decline to exercise supplemental jurisdiction over Count II and dismiss it without prejudice.( Plaintiff's Show Cause Response due by 8/24/2020; Defendants' Responsive Brief due by 8/31/2020) Signed by District Judge Robert H. Cleland. (LWag) (Entered: 08/13/2020)

Aug. 13, 2020

Aug. 13, 2020

Clearinghouse
18

Emergency MOTION for Reconsideration re 17 Order,,, Order to Show Cause,, of the Court's August 13, 2020 Order (ECF No. 17) by Leigh Reed-Pratt. (Attachments: # 1 Exhibit Exhibit A- Stipulated Order Dismissing Without Prejudice A Felon's Crusade's State-Court Action, # 2 Exhibit Exhibit B- Register of Actions for A Felon's Crusade's State-Court Action, # 3 Exhibit Exhibit C- Email Chain Between Attorneys Paterson and Noseda) (Paterson, Andrew) (Entered: 08/14/2020)

Aug. 14, 2020

Aug. 14, 2020

PACER
19

AMENDED COMPLAINT with Jury Demand First-Amended Complaint filed by Leigh Reed-Pratt against All Defendants. NO NEW PARTIES ADDED. (Paterson, Andrew) (Entered: 08/14/2020)

Aug. 14, 2020

Aug. 14, 2020

Clearinghouse
20

EXHIBIT Wayne County Circuit Court Chief Judge Tim Kenny's Signed Order Dismissing Without Prejudice A Felon's Crusade's State-Court Action Against Defendants Winfrey, Detroit Election Commission, and Detroit Department of Elections re 18 Emergency MOTION for Reconsideration re 17 Order,,, Order to Show Cause,, of the Court's August 13, 2020 Order (ECF No. 17) by Leigh Reed-Pratt (Paterson, Andrew) (Entered: 08/14/2020)

Aug. 14, 2020

Aug. 14, 2020

PACER
21

RESPONSE TO ORDER TO SHOW CAUSE by Leigh Reed-Pratt. (Attachments: # 1 Exhibit Exhibit A- Wayne Co. Circuit Court Chief Judge Tim Kenny's Signed Stipulated Order Dismissing Without Prejudice A Felon's Crusade's State-Court Action) (Paterson, Andrew) (Entered: 08/17/2020)

Aug. 17, 2020

Aug. 17, 2020

PACER
22

ORDER DENYING 18 Emergency MOTION for Reconsideration; ORDER to Show Cause why the court should not decline to exercise supplemental jurisdiction over Counts II and III and dismiss them without prejudice.( Show Cause Response due by 8/24/2020 AND SETTING a ( TELEPHONIC Status Conference for 8/18/2020 03:30 PM before District Judge Robert H. Cleland, (SEE ORDER FOR DETAILS) Signed by District Judge Robert H. Cleland. (LWag) (Entered: 08/17/2020)

Aug. 17, 2020

Aug. 17, 2020

Clearinghouse
23

RESPONSE to 18 Emergency MOTION for Reconsideration re 17 Order,,, Order to Show Cause,, of the Court's August 13, 2020 Order (ECF No. 17) filed by All Defendants. (Attachments: # 1 Index of Exhibits, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit) (Noseda, James) (Entered: 08/18/2020)

Aug. 18, 2020

Aug. 18, 2020

PACER

Minute Entry for proceedings before District Judge Robert H. Cleland: Telephonic Status Conference held on 8/18/2020. Disposition: Order to Enter (LWag)

Aug. 18, 2020

Aug. 18, 2020

PACER
24

ORDER ADJOURNING without date the hearing on Plaintiff's request for a preliminary injunction, ADJOURNING without date deadline for a responsive pleading and THIRD ORDER for Leigh Reed-Pratt to Show Cause why the entire case should not be stayed or dismissed without prejudice pursuant to issues of comity, federalism and abstention..( Show Cause Response due by 8/24/2020, Defendants' responsive brief due by 8/31/2020) Signed by District Judge Robert H. Cleland. (LWag) (Entered: 08/19/2020)

Aug. 19, 2020

Aug. 19, 2020

Clearinghouse

TEXT-ONLY ORDER re 22 Order, 23 Response to Motion, filed by Detroit Department of Elections, Janice Winfrey, Detroit Election Commission. -- Concerning the parties earlier statements concerning the existence or absence of a date for hearing dispositive motions in state court (Chief Judge Kenny presiding), the court acknowledges Defendants response addressing Plaintiffs allegation that Defendants had intentionally misled this court; the court notes Defendants explanation of the motion date-setting process in state court. The court has no further need for information on this issue and sees no basis to criticize Defendants statements about the state court motion hearing date. Signed by District Judge Robert H. Cleland. (LWag)

Aug. 19, 2020

Aug. 19, 2020

PACER

Text-Only Order

Aug. 19, 2020

Aug. 19, 2020

PACER
25

RESPONSE TO ORDER TO SHOW CAUSE Plaintiff Reed-Pratt does not oppose the Court declining to exercise supplemental jurisdiction over the state-law claims and Plaintiff prays and requests the Court to IMMEDIATELY enter an order dismissing without prejudice the state-law claims Counts II and III by Leigh Reed-Pratt. (Paterson, Andrew) (Entered: 08/20/2020)

Aug. 20, 2020

Aug. 20, 2020

PACER
26

RESPONSE TO ORDER TO SHOW CAUSE Response to Court's Third Order to Show Cause Dated August 19, 2020 (ECF No.24) Addressing Colorado River Abstention Doctrine by Leigh Reed-Pratt. (Attachments: # 1 Index of Exhibits, # 2 Exhibit Ex. A- Michigan Court of Claims Judge Cynthia Stephens June 18, 2020 Opinion and Order denying preliminary injunctions in consolidated Court of Claims cases re SOS Benson's authority and powers, # 3 Exhibit Ex. B- Assistant Attorney General Meingast's Email to Robert Davis, # 4 Exhibit Ex. C- Minutes from Defendant Detroit Election Commission Meeting, # 5 Exhibit Ex. D- Unsolicited Absentee voter application Plaintiff Reed-Pratt received from Defendants, # 6 Exhibit Ex. E- Verified Complaint Filed in Activist Robert Davis' Court of Claims case against Secretary of State Benson) (Paterson, Andrew) (Entered: 08/23/2020)

Aug. 23, 2020

Aug. 23, 2020

PACER
27

RESPONSE TO ORDER TO SHOW CAUSE by All Defendants. (Attachments: # 1 Index of Exhibits, # 2 Exhibit A, # 3 Exhibit b, # 4 Exhibit c, # 5 Exhibit d, # 6 Exhibit e, # 7 Exhibit f, # 8 Exhibit g) (Noseda, James) (Entered: 08/31/2020)

Aug. 31, 2020

Aug. 31, 2020

PACER
28

Emergency MOTION for Leave to File Reply Brief Not to Exceed 5 Pages by Leigh Reed-Pratt. (Attachments: # 1 Exhibit Exhibit A- Michigan Court of Claims Judge Cynthia Stephens' August 25, 2020 Opinion and Order, # 2 Exhibit Exhibit B- August 27, 2020 Order of the Michigan Court of Appeals Granting Robert Davis' Motion to Expedite Appeal, # 3 Exhibit Exhibit C- August 28, 2020 Amended Order of Court of Appeals Granting Robert Davis' motion to expedite appeal and setting expedited briefing and submission schedule, # 4 Exhibit Exhibit D- August 31, 2020 Letter from Michigan Court of Appeals informing parties in Robert Davis state-court appeal of date of submission for decision) (Paterson, Andrew) (Entered: 09/02/2020)

Sept. 2, 2020

Sept. 2, 2020

PACER
29

OPINION AND ORDER DISMISSING WITHOUT PREJUDICE Plaintiff's State Claims, STAYING Plaintiff's Federal Claim and DENYING 28 Emergency Motion for Leave to File a Reply Brief. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 09/09/2020)

Sept. 9, 2020

Sept. 9, 2020

Clearinghouse
30

NOTICE OF APPEAL by Leigh Reed-Pratt re 29 Order on Motion for Leave to File. Receipt No: AMIEDC-8037350 - Fee: $ 505 - Fee Status: Fee Paid. (Attachments: # 1 Exhibit September 9, 2020 Order Granting Stay of Plaintiff's Federal Claims Under Colorado River Abstention Doctrine) (Paterson, Andrew) (Entered: 09/10/2020)

Sept. 10, 2020

Sept. 10, 2020

PACER
31

Certificate of Service re 30 Notice of Appeal,. (SOso) (Entered: 09/10/2020)

Sept. 10, 2020

Sept. 10, 2020

PACER
32

ORDER from U.S. Court of Appeals - Sixth Circuit re 30 Notice of Appeal, filed by Leigh Reed-Pratt [Appeal Case Number 20-1876] (SKra) (Entered: 12/08/2020)

Dec. 7, 2020

Dec. 7, 2020

PACER
33

ORDER Directing Plaintiff to File Notice of Intention to Proceed., ( Response due by 1/19/2021) Signed by District Judge Robert H. Cleland. (LWag) (Entered: 01/14/2021)

Jan. 14, 2021

Jan. 14, 2021

PACER
34

NOTICE by Leigh Reed-Pratt re 33 Order, Set Deadlines/Hearings Plaintiff's Notice of Intent to Proceed (Paterson, Andrew) (Entered: 01/17/2021)

Jan. 17, 2021

Jan. 17, 2021

PACER
35

ORDER terminating as moot 2 Motion for TRO/Preliminary Injunction. Signed by District Judge Robert H. Cleland. (LWag) (Entered: 01/19/2021)

Jan. 19, 2021

Jan. 19, 2021

Clearinghouse
36

NOTICE by All Defendants Notice of Ruling By Michigan Court of Appeals Pending Which This Case Was Stayed (Attachments: # 1 Index of Exhibits, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3) (Noseda, James) (Entered: 09/23/2021)

Sept. 23, 2021

Sept. 23, 2021

PACER
37

STIPULATED ORDER DISMISSING CASE with prejudice Signed by District Judge Robert H. Cleland. (LWag) (Entered: 10/05/2021)

Oct. 5, 2021

Oct. 5, 2021

RECAP

Case Details

State / Territory: Michigan

Case Type(s):

Election/Voting Rights

Special Collection(s):

COVID-19 (novel coronavirus)

Healthy Elections COVID litigation tracker

Key Dates

Filing Date: Aug. 9, 2020

Closing Date: Oct. 5, 2021

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Individual registered voter

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Detroit (Detroit), City

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

State law

Declaratory Judgment Act, 28 U.S.C. § 2201

Available Documents:

Complaint (any)

Non-settlement Outcome

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

Voting:

Voting: General & Misc.

Election administration