Background
Mark Michael Koroi sought election as a judge of Michigan’s 31st District Court, which covers Hamtramck. He filed nominating petitions and an affidavit of identity on April 21, 2026, listing a Hamtramck address and certifying that he met the statutory and constitutional qualifications for office. But a petition he circulated one day earlier identified his residence as being in Warren.
The Bureau of Elections determined that Koroi had not resided in Hamtramck for the 30 days required to qualify as an elector there and declined to certify his candidacy. After the Board of State Canvassers deadlocked on a conditional determination concerning his petitions, Koroi sought mandamus and declaratory relief. The Court of Claims granted summary disposition to the Board and Secretary of State and dismissed the case with prejudice.
The Court’s Holding
The Michigan Court of Appeals affirmed. It held that the 2018 constitutional amendment allowing voter registration through Election Day did not supersede MCL 168.10(1)’s 30-day local-residency requirement. Article 2, § 4(1)(f) grants registration rights to people already qualified to vote, while Article 2, § 1 permits local-residency requirements established by law. A registration applicant also must state that the applicant will have established local residence at least 30 days before the election.
Because Koroi had not lived in Hamtramck for 30 days by the April 21 filing deadline, he was not a qualified elector of the judicial district as required by MCL 168.467. He therefore had no clear legal right to certification, and the Secretary of State had no clear legal duty to certify him. His disqualification made his challenge to the Board’s review of his petitions moot.
The court also rejected Koroi’s attempt to add an equal-protection theory. It lacked jurisdiction to review the postjudgment order denying his formal motion to amend, and it found no abuse of discretion in refusing the amendment informally requested during summary-disposition briefing because the request was delayed and would have prejudiced defendants in the expedited proceeding.
Key Takeaways
- Michigan’s constitutional right to register through Election Day does not eliminate the statutory 30-day local-residency requirement for qualified electors.
- A district-court candidate must be a registered and qualified elector of the relevant judicial district by the filing deadline.
- A candidate who fails the residency requirement cannot compel certification by mandamus, and disqualification can moot disputes over petition sufficiency.
Why It Matters
The decision confirms that same-day voter registration and candidate eligibility are distinct questions under Michigan law. Although an individual may register close to or on Election Day, a judicial candidate still must satisfy the statutory local-residency qualification by the applicable filing deadline.
It also underscores the procedural risks of introducing a new constitutional claim late in an expedited election case, particularly when the claim could have been pleaded initially and the compressed schedule leaves the opposing parties little time to respond.