Background
Mark Michael Koroi sought election as a judge of Michigan’s 31st District Court, which covers Hamtramck. On April 21, 2026, he filed nominating petitions and an affidavit of identity stating that he lived in Hamtramck and met the statutory and constitutional qualifications for office. A petition he had circulated one day earlier, however, identified his residence as Warren. The Bureau of Elections concluded that Koroi had not lived in Hamtramck for the 30 days required to be a qualified elector and therefore could not be certified as a candidate.
Koroi sued the Board of State Canvassers and the Secretary of State, seeking mandamus and declaratory relief. He argued that the same-day voter-registration provision added to the Michigan Constitution in 2018 superseded the statutory 30-day local-residency requirement. The Court of Claims rejected that argument, granted summary disposition to defendants, and dismissed the case with prejudice.
The Court’s Holding
The Michigan Court of Appeals affirmed. It held that the constitutional right to register through Election Day applies to a person who is an elector qualified to vote, and qualification still includes compliance with local-residency requirements established by law. The same-day-registration provision therefore did not invalidate the 30-day residency requirement in MCL 168.10(1).
Because Koroi had not resided in Hamtramck for 30 days by the filing deadline, he was not a qualified elector of the judicial district under MCL 168.467 and had no clear legal right to certification. His affidavit of identity falsely certified that he met the requirements for office, requiring the Secretary of State not to certify him. The court also found no abuse of discretion in refusing his late request to add an equal-protection claim and concluded that his disqualification made his challenge to the Board’s review of his petitions moot.
Key Takeaways
- Michigan’s constitutional right to register to vote through Election Day does not eliminate the statutory requirement that a qualified elector reside in the relevant city or township for 30 days.
- A district-court candidate must be a registered and qualified elector of the judicial district by the filing deadline.
- A candidate who does not satisfy the residency requirement cannot obtain mandamus compelling election officials to certify the candidacy.
- A late request to add a constitutional claim may be denied when delay and an expedited election schedule would prejudice the opposing parties.
Why It Matters
The decision distinguishes eligibility to use Michigan’s same-day voter-registration process from satisfaction of the substantive qualifications for voting and candidacy. Election Day registration does not permit a judicial candidate to bypass the statutory local-residency period.
The opinion also underscores the practical difficulty of introducing new constitutional theories late in expedited election litigation, particularly when the asserted claim could have been pleaded from the outset.