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

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….

Ronan is unlikely to show that Ohio Rev. Code § 3513.07 violates the First Amendment…. Ohio Rev. Code § 3513.07 requires candidates to sign a declaration of candidacy stating: “I am a member of the ___ 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 ___ Party.” The declaration also contains a notice that “whoever commits election falsification is guilty of a felony of the fifth degree.” While Ohio law permits candidates to change parties based on self-identification, we agree with the district court that Ohio law requires that change to be made in good faith….

Ronan [is not] likely to show that the good-faith requirement violates the First Amendment as applied to him. “[T]he right to vote in any manner and the right to associate for political purposes through the ballot [are not] absolute”—especially because “states retain the power to regulate their own elections.” Burdick v. Takushi (1992). A look at the facts here shows that the Board removed Ronan because Ronan’s own speech disavowed his sworn statement, not, as Ronan claims, because the Board deemed Ronan’s policies “unRepublican.”

Under our caselaw, we use the Anderson-Burdick framework to determine whether a state ballot-access regulation violates the First Amendment. To apply this framework, “a court must: (1) evaluate whether an election restriction imposes a severe or incidental burden; (2) assess the state’s interests in the restriction; and (3) ask if the state’s interests make the burden necessary.”

First, this ballot-access restriction does not impose a severe burden on Ronan. The good-faith requirement prevents a candidate from running a sham election in which he self-identifies as a Democrat but tells voters that he is a Republican, or vice versa. That restriction does not prevent Ronan from voting, supporting candidates, endorsing candidates, running for office, or even switching parties. The only requirement is that he switch parties truthfully.

Second, the state has a substantial interest in this restriction. States may protect the fairness and integrity of elections, prevent fraud and corrupt practices, and avoid confusion. See Burdick (“The State has a legitimate interest in preventing … maneuvers” like “party raiding” and may “require that party candidates be members of the party.”).

Finally, a good-faith requirement is a reasonable means to achieve the state’s interest. That’s especially true in the case before us, which as the district court noted, presents “unique factual circumstance[s].” Here, Ronan swore that he was a Republican and would abide by Republican Party doctrine; afterwards he made public statements that the factfinders here could reasonably decide showed that Ronan had made those declarations in bad faith. So Ronan is unlikely to “succeed on his federal constitutional claims because he has not shown that the application of Ohio law’s ‘good faith’ standard … violated his constitutionally protected rights as a candidate.” …

The court also rejected Ronan’s Elections Clause claim, and Ronan’s Due Process Clause claim that one of the Elections Board members was unacceptably biased.

Julie M. Pfeiffer and Mark R. Brown represent defendants.

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