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 listing a Hamtramck address and certifying that he met the requirements for office. But a petition he circulated one day earlier identified his residence as Warren. The Bureau of Elections concluded that Koroi had not resided in Hamtramck for the 30 days required to be a qualified elector and therefore could not qualify as a judicial candidate.
After the Board of State Canvassers split 2-2 on whether his petitions would otherwise be sufficient, Koroi sued the Board and Secretary of State. He sought mandamus compelling certification of his candidacy and a declaration that the Michigan Constitution’s same-day voter-registration provision superseded the statutory 30-day local-residency requirement. The Court of Claims granted summary disposition to the defendants and dismissed the case with prejudice.
The Court’s Holding
The Court of Appeals affirmed. It held that Michigan Constitution article 2, § 4(1)(f), which permits voter registration through Election Day, does not invalidate the 30-day local-residency requirement in MCL 168.10(1). The constitutional right applies to an elector qualified to vote, and qualification still incorporates local-residency requirements provided by law. Because Koroi had not lived in Hamtramck for 30 days by the filing deadline, he was not a qualified elector of the judicial district under MCL 168.467.
Koroi therefore had no clear legal right to certification, and the Secretary of State had no clear duty to certify him. His disqualification also rendered moot his challenge to the Board’s review of his petitions. The court further found no abuse of discretion in refusing his belated request to add an equal-protection claim during expedited summary-disposition proceedings, citing undue delay and prejudice. It lacked jurisdiction to review the separate order denying Koroi’s postjudgment motion to amend because that order was entered after the final order from which he appealed.
Key Takeaways
- Michigan’s same-day voter-registration provision does not eliminate the statutory requirement that an elector reside in the relevant city or township for 30 days before the election.
- A district-court candidate must be a registered and qualified elector of the judicial district by the filing deadline.
- A request to introduce a new constitutional claim during expedited briefing may be denied when delay and compressed response time would prejudice the opposing parties.
Why It Matters
The decision confirms that eligibility to register close to or on Election Day is distinct from satisfying the local-residency qualifications required of judicial candidates. Candidate filings that contradict the candidate’s claimed residence can support disqualification and defeat the clear-right and clear-duty elements necessary for mandamus.