Resource: Murray v. Cuomo

On March 14, Governor issued Executive Order 202.2, which reduced the time to collect designating petition signatures (changing date from April 2 to March 17) and reduced the number of required signatures (from 5% to 1.5%) of registered party members. After submission of designating petition, NYC Board of Elections found that the petition contained no valid signatures, as per signature requirements. Petitions filed in Bronx Supreme Court for review of validity of signatures under Article 16 proceeding. Bronx Court also ruled signatures were not valid and denied Plaintiff's request to make NY Board of Elections place her name on ballot. Plaintiff did not appeal state court decision, and filed case in USDC SDNY requesting same relief. USDC SDNY also denied mandatory injunctive relief, noting that Plaintiff must meet heightened standard of "clear" or "substantial" likelihood of success becuase the mandatory injunction cannot be undone even if Defendant prevails at trial, and finding that the challenged restrictions were reasonable and non-discriminatory in balancing the state interest in public health without undermining the state's interest in ensuring the orderly conduct of elections. Plaintiff filed an appeal to the 2d Cir, but then motioned to withdraw, which motion was granted.