Background
Namita Sharma, an incumbent judge of Michigan’s 8th District Court, sought reelection in the November 2026 general election. Her affidavit of identity certified that all late filing fees owed by her or her candidate committee had been paid, but that statement was false because fees incurred through actions of her committee’s treasurer remained outstanding. The Bureau of Elections therefore disqualified her from the ballot under MCL 168.558(4).
Sharma later paid the fees, gathered signatures on nominating petitions, and notified the Bureau that she intended to submit the petitions with a new affidavit. A deputy director told her the petitions would be rejected, citing both the false statement in her original affidavit and defects in the petition headings. The Bureau subsequently rejected the new affidavit. Sharma and two electors sued for declaratory and injunctive relief, but the Court of Claims granted summary disposition to the Bureau.
The Court’s Holding
The Court of Appeals affirmed. It first held that Sharma’s original affidavit independently required her exclusion because MCL 168.558(4) directs election officials not to certify a candidate who executes an affidavit of identity containing a false statement. Candidates must comply strictly with that requirement, and the election statutes did not give Sharma a right to cure the defect by filing a second affidavit.
The court also rejected Sharma’s constitutional arguments. Const 1963, art 6, § 22 addresses incumbent Court of Appeals, circuit, and probate judges—not district judges—and Sharma’s exercise of circuit-court jurisdiction did not transform her district-court office into a circuit judgeship. In any event, the affidavit requirement applies to the judicial offices identified in that provision as well. The requirement regulates ballot access rather than adding a qualification for judicial office, and its uniform application did not violate the Purity of Elections Clause.
Finally, the court held that Sharma’s disqualification did not deny the elector plaintiffs their right to vote. They remained able to vote, and limiting ballot choices to candidates who comply with election laws imposed only a small burden under the Anderson-Burdick framework. That burden was justified by Michigan’s substantial interest in accurate candidate identification and ballot integrity.
Key Takeaways
- A candidate’s false statement in an affidavit of identity triggers the mandatory noncertification rule in MCL 168.558(4).
- Michigan election law provides no right to cure a false affidavit by submitting a second or amended affidavit.
- A district judge does not become a circuit judge merely by exercising circuit-court authority under a concurrent-jurisdiction plan.
- Removing a noncompliant candidate from the ballot does not amount to a complete denial of electors’ right to vote.
Why It Matters
The decision underscores the strict consequences of inaccurate candidate filings in Michigan. Paying outstanding fees after submitting a false affidavit does not restore ballot eligibility, and election officials need not accept a replacement affidavit as a cure.
The opinion also distinguishes constitutional qualifications for holding judicial office from procedural requirements for appearing on the ballot. It confirms that Michigan may enforce uniform affidavit requirements against judicial candidates while protecting the accuracy and integrity of elections.