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Reason
Reason
Eugene Volokh

Sixth Circuit OKs Disqualifying Republican Primary Candidate Who Admits He's a Democrat Infiltrating the Party

Source: Wikimedia Commons

From Sixth Circuit Judges Alice Batchelder, Joan Larsen, and Chad Readler in Monday's Ronan v. LaRose:

Samuel Ronan declared his candidacy in the State of Ohio's Fifteenth Congressional District as a Republican. To become eligible for the ballot, Ronan signed a declaration of candidacy stating: "I am a member of the Republican Party," and "I further declare that, if elected to said office or position, I will qualify therefor, and that I will support and abide by the principles enunciated by the Republican Party." See Ohio Rev. Code § 3513.07. The declaration also contains a notice that "whoever commits election falsification is guilty of a felony of the fifth degree."

Sometime after signing this declaration, Ronan posted on Facebook that "Leftists need to infiltrate [R]epublican spaces and primary them" and that's why he is "running as a Repub[l]ican now." Ronan had previously run for Chair of the Democratic National Committee. Referencing that campaign, he separately posted a Facebook comment stating, "I believe [I] very clearly mentioned [in the] DNC Chair race that Democrats, if they wanted to govern and regain the trust of Americans, would have to primary Republicans in deep red districts, as Republicans .… So, if l am doing anything, it's following the argument I made on that stage."

As permitted by Ohio law, an Ohio voter then protested Ronan's Republican candidacy. During a March 6, 2026 hearing on the protest, the Franklin County Board of Elections tied two-to-two on whether to remove Ronan from the ballot. On March 13, the issue was referred to Secretary Frank LaRose for a tie-breaking vote …. After LaRose broke the tie in favor of the protest, Ronan and one of his supporters filed this suit against LaRose and the members of the Franklin County Board of Elections….

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