Debbie Mayfield v. Secretary, Florida Department of State

Supreme Court of Florida
____________

No. SC2025-0162
____________

DEBBIE MAYFIELD,
Petitioner,

vs.

SECRETARY, FLORIDA DEPARTMENT OF STATE, et al.,
Respondents.

February 13, 2025

GROSSHANS, J.

This election case stems from a dispute that arose when

Respondents—the Secretary of State and Director of the Division of

Elections (collectively “Secretary”)—refused to place Petitioner

Deborah Mayfield on the special election ballot for a senate seat in

Brevard County. That refusal was based on the Secretary’s

interpretation of a constitutional provision creating term limits for

certain elective offices, including state senator. Arguing that the

Secretary misapprehended his authority and failed to properly fulfill

his statutory duty, Mayfield asks us to issue writs of mandamus
and quo warranto. For the reasons given below, we grant Mayfield’s

petition for mandamus relief. 1

I

Mayfield was first elected to the Florida House of

Representatives in 2008 and served in that office for eight years.

Following that, she was elected to the Florida Senate, serving in

Senate District 17 for six years and Senate District 19 (SD 19) for

two. Her most recent term ended in November 2024.

At the completion of her Senate term, she ran for and won

election to the Florida House of Representatives. She was sworn in

on November 19, 2024, as the representative from District 32.

Early into that term, Mayfield learned that Senator Randy Fine—the

new holder of SD 19—would be resigning to run for federal office.

On January 21, 2025, the Governor issued an executive order,

calling for a special election in SD 19. Under that order, the special

election primary is set for April 1, 2025, with the general election to

take place on June 10, 2025. Days after the executive order issued,

Mayfield completed and submitted the appropriate paperwork to

1. We have jurisdiction. See art. V, § 3(b)(8), Fla. Const.

-2-
qualify as a candidate—doing so before the deadline set by the

Secretary’s notice. 2 This paperwork included a completed oath of

office, a filing fee in the form of a check, and certain notarized

forms.

On February 5, the Department of State’s Director of the

Division of Elections informed Mayfield that she did not qualify for

placement on the ballot. As the sole reason given for Mayfield’s

disqualification, the notice stated, “Upon review and consultation

with counsel regarding your candidacy for state senate district 19,

the Division of Elections has determined that your name cannot

appear on the special election ballot, as it violates article VI, section

4 of the Florida Constitution.” The next day, Mayfield filed the

petition at issue in this case.

II

Florida’s constitution gives this Court the authority to issue

writs of quo warranto and mandamus, see art. V, § 3(b)(8), Fla.

2. See § 99.061(7), Fla. Stat. (2024) (listing required items for
qualification); § 101.252, Fla. Stat. (2024) (describing right to
appear on ballot as “entitlement” if candidate is qualified);
§ 100.141, Fla. Stat. (2024) (requiring issuance of order and notice
of special election).

-3-
Const.—both being “extraordinary” writs that have common law

roots. See Richardson v. Sec’y, Fla. Agency for Health Care Admin.,

395 So. 3d 500, 504 (Fla. 2024) (“In its earliest applications, we

described the writ as narrow and limited by its common law

roots.”); State ex rel. Buckwalter v. City of Lakeland, 150 So. 508,

511 (Fla. 1933) (“A writ of mandamus is a common-law writ used to

coerce the performance of any and all official duties where the

official charged by law with the performance of such duty refused or

failed to perform the same . . . .”); Vassar v. State ex rel. Gleason,

190 So. 434, 435 (Fla. 1939) (noting “common law” origin).

Mandamus is a discretionary writ that offers relief only in

narrow circumstances. The limited scope of this writ is reflected in

the demanding standard governing its issuance. In describing that

standard, we have said that “the petitioner must have a clear legal

right to the requested relief, the respondent must have an

indisputable legal duty to perform the requested action, and the

petitioner must have no other adequate remedy available.” Pleus v.

Crist, 14 So. 3d 941, 945 (Fla. 2009) (quoting Huffman v. State, 813

So. 2d 10, 11 (Fla. 2000)); see also State ex rel. Knott v. Haskell, 72

So. 651, 659 (Fla. 1916) (“The writ of mandamus is granted by the

-4-
courts to enforce the performance of a ministerial duty imposed by

law where such duty has not been performed as the law requires.

Such writ issues only when the law affords no other adequate

remedy; and where the writ is applicable it should be framed so as

to meet the exigencies of the case.”).

A

With this backdrop, we now consider whether there are legal

rights and duties sufficient to support a writ of mandamus in this

case. Contained in chapters 97 through 106, Florida’s election code

establishes a comprehensive body of law on the topic of elections,

including rules regulating candidate qualification.

In the chapter governing candidates, the applicable language

defines the term “qualify” as “to fulfill the requirements set forth in

s. 99.061(7)(a).” § 99.012(1)(b), Fla. Stat. (2024). Section

99.061(7)(a), in turn, lists the specific items that must be submitted

to a filing officer within the qualifying period “[i]n order for a

candidate to be qualified.” 3 This list consists of proper payment of

3. The filing officer may be with the Department of State, or a
local supervisor of elections office for certain elected county
positions. See, e.g., § 106.07(2)(a)(1.), Fla. Stat. (2024);

-5-
the filing fee, the candidate’s oath, a written statement of party

affiliation, a form specifying the campaign treasurer and campaign

depository, and a statement of financial interest. § 99.061(7)(a).

Once the paperwork has been submitted, the filing officer carries

out a narrow review function. See § 99.061(7)(c). The statute

specifically circumscribes the responsibilities of the filing officer as

follows:

The filing officer performs a ministerial function in
reviewing qualifying papers. In determining whether a
candidate is qualified, the filing officer shall review the
qualifying papers to determine whether all items required
by paragraph (a) have been properly filed and whether
each item is complete on its face, including whether
items that must be verified have been properly verified
pursuant to s. 92.525(1)(a). The filing officer may not
determine whether the contents of the qualifying papers
are accurate.

Id.

If the papers are incomplete, it is the obligation of the filing

officer to make a reasonable effort to apprise the candidate “of the

missing or incomplete items” and also “inform” the candidate of the

filing deadline. § 99.061(7)(b). No other requirements for

§ 106.0702(2)(a), Fla. Stat. (2024); § 106.0703(1)(e), Fla. Stat.
(2024).

-6-
qualification are listed in section 99.061(7)(a), and no other tasks

are assigned to the filing officer with respect to review of the

qualifying papers. 4

Notably, once the candidate qualifies under this statute, the

Department of State “shall certify to the supervisor of elections,

within 7 days after the closing date for qualifying, the names of all

duly qualified candidates for nomination or election.” § 99.061(6).

Finally, section 101.252(1) ties a candidate’s right to appear on the

ballot with that candidate’s qualification. Specifically, the statute

says that “[a]ny candidate for nomination who has qualified as

prescribed by law is entitled to have his or her name printed on the

official primary election ballot.” § 101.252(1). And the right to

appear on the general ballot, in turn, depends on the result of the

primary. § 101.2512.

Considering these statutes collectively, we conclude that a

candidate for elective state office who timely submits the paperwork

required by section 99.061(7)(a) has met the statutory requirements

4. The Secretary does not cite any other statute governing
qualification.

-7-
for qualification and has a clear legal right to appear on the primary

ballot.

B

Nevertheless, for mandamus relief, it is not enough for a

petitioner to simply establish a legal right. A petition must also

show that the respondent has an indisputable legal duty to perform

the requested action. Thus, we must consider whether the

Secretary has a ministerial obligation to place a candidate on the

ballot who has met the qualifying standards required by statute.

The answer is a straightforward yes.

Pursuant to statute, the filing officer reviews the paperwork,

and that review is a “ministerial function.” § 99.061(7)(c). As

discussed earlier, that function is limited to assessing whether the

required items have been properly and timely filed and whether

each item is facially complete. Indeed, “in determining whether a

candidate is qualified,” the filing officer “may not determine whether

the contents of the qualifying papers are accurate.” Id. Further,

the Department is required to submit the names of those qualified—

pursuant to section 99.061(7)(a)—to the supervisor of elections. §

99.061(6). These provisions operate in concert, creating a legal

-8-
duty to perform tasks that are expressly ministerial in nature, and

which do not involve the exercise of judgment, factfinding, or

discretion. We have traditionally held such duties to be enforceable

by writ of mandamus.

Nearly a century ago, we found that comparable statutes did

not afford the Secretary discretion in determining whether a

candidate was eligible to be placed on the ballot. Davis ex rel.

Taylor v. Crawford, 116 So. 41, 42-43 (Fla. 1928). In granting

mandamus relief, we said:

The law does not give the secretary of state any
power or authority to inquire into or pass upon the
eligibility of a candidate to hold office for the nomination
for which he is running. It merely provides that the
candidate shall file the sworn statement in the form
provided by statute . . . . And, when he has done this,
the statute provides that he shall then be entitled to have
his name printed on the official primary election ballot.
No discretion is vested in the secretary of state. If the
simple requirements plainly provided by the statute are
complied with by the candidate, as was done here, such
state official should, as provided by the statute, receive
for filing the sworn statement and receipt, and accept the
proper filing fee.

Id. at 42 (internal quotation marks and citations omitted). 5

5. See also Haskell, 72 So. at 659 (“The rights of a candidate
which arise under and are created by the primary election laws of
the state of Florida are such that when violated the courts of this

-9-
Consistent with that precedent, we find that the Department of

State has an indisputable legal duty (ministerial in nature) to notify

the supervisor of elections of all candidates that have qualified

pursuant to statute. And a duly qualified candidate has a right to

be placed on the ballot.

C

Turning to the facts of this case, Mayfield submitted the

notarized paperwork and payment called for by statute. Indeed,

there is no claim that a form was missing or incomplete, nor was

she notified that her paperwork was deficient in any way.

Furthermore, the record shows that the paperwork and payment

were submitted prior to the Secretary’s filing deadline.

At this point, with the facial sufficiency of the paperwork

established, the Department of State’s review should have ceased.

But the Department looked further.

state may be resorted to for their enforcement, and the writ of
mandamus may be used to compel the performance of the duties
which are imposed by law . . . such duties being ministerial in their
nature involving no discretion.”).

- 10 -
To defend this expanded review, the Secretary argues that his

office may go beyond the face of the paperwork to assess whether a

candidate is legally and constitutionally eligible for the office. 6 We

have not found, nor has the Secretary cited, any source of law that

grants the Secretary this authority. 7 Instead, we find the opposite—

a statute that expressly limits the Department’s scope of review. In

light of these facts, we cannot accept the Secretary’s contention that

he, in fact, has discretion to exercise independent judgment as to a

candidate’s constitutional eligibility for office as part of the

qualifying review process.

The Secretary also argues that the ability to verify the oath of

the candidate necessarily encompasses the ability to determine if

that candidate is truly eligible for the office. He is wrong. It is clear

to us that the relevant provision merely authorizes the Secretary to

6. As an example, the Secretary argues that the filing officer
could consider a legal memorandum that Mayfield included with
her paperwork.

7. We reject the Secretary’s conclusory assertion that his
obligation to “maintain uniformity in the interpretation and
implementation of the election laws” pursuant to section 97.102,
Florida Statutes (2024), permits him to go beyond the clear
mandate to perform a ministerial function in the context of
qualification.

- 11 -
determine if the form of the candidate’s oath complies with

statutory requirements. We know this because the statute

characterizes review of the candidate’s oath as one for facial

completeness and expressly forbids an assessment of whether the

contents “are accurate.” See § 99.061(7)(c). Moreover, the filing

officer’s responsibility for verification (referred to in section

99.061(7)(c)) specifically directs to a statute that governs only the

manner of verification. See § 92.525(1)(a).

D

Finally, to grant mandamus relief, we must determine there is

no other adequate remedy at law. On the unique circumstances

presented by this case, we conclude there is not. In so concluding

we emphasize several facts. One, based on the scheduling of the

special election, the time to issue the primary ballot is fast

approaching. The Governor and Secretary set the primary election

for April 1, 2025, and the deadline for shipping ballots to military

and overseas voters is Friday, February 14. See § 101.62(3), Fla.

Stat. (2024). Two, Mayfield’s conduct did not create this timing

issue. And three, the Secretary’s decision has the effect of

preventing the Republican electors of SD 19 from selecting the

- 12 -
candidate of their choice from among those duly qualified to be

placed on the primary ballot. 8

III

The Secretary presents a myriad of other reasons why the

Court should not grant Mayfield’s petition. None have merit.

One such argument is that Mayfield’s failure to seek

declaratory relief or an advisory opinion warrants dismissal, and

that closeness to the election also supports dismissal due to the

hardships faced by election officials as a result of last-minute

changes to the ballot.

We reject these arguments as being inconsistent with the

principles of equity that bear upon our discretion to issue

extraordinary writs. See State ex rel. Perkins v. Lee, 194 So. 315,

317 (Fla. 1940) (“While mandamus is classed as a legal remedy, it is

a remedial process, which is awarded, not as a matter of right, but

in the exercise of a sound judicial discretion and upon equitable

8. Finally, we note that the Secretary’s argument—that a
lower court proceeding would allow a fuller record with the benefit
of factual development—directly contradicts his assertion that the
issue to be decided is clear on the face of the record.

- 13 -
principles.”); see also State ex rel. Haft v. Adams, 238 So. 2d 843,

844 (Fla. 1970).

Here, Mayfield timely filed her paperwork and sought relief

just one day after the Secretary notified her of his decision to keep

her off the ballot. Mayfield’s conduct, coupled with timing

restraints imposed by the executive order, tip the equities in favor of

relief. See Cheney v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 379-80

(2004) (“The law does not put litigants in the impossible position of

having to exhaust alternative remedies before petitioning for

mandamus, on the one hand, and having to file the mandamus

petition at the earliest possible moment to avoid laches, on the

other.”).

Relying on his interpretation of the term-limits provision in

article VI, section 4, the Secretary also maintains that, in deciding

whether to grant relief, we should not overlook Mayfield’s alleged

constitutional ineligibility. We agree that Mayfield’s constitutional

eligibility is relevant to whether we should exercise our discretion in

granting her petition. See Whitehouse v. Ill. Cent. R. Co., 349 U.S.

366, 373 (1955) (“[M]andamus is itself governed by equitable

considerations and is to be granted only in the exercise of sound

- 14 -
discretion.”); Davis, 116 So. at 43 (“It is a well-established

fundamental principle of the law of mandamus that ‘the writ will

never be granted in cases when, if issued, it would prove

unavailing, or when compliance with it would be nugatory in its

effects, or would be without beneficial results and fruitless to the

relator.’ ” (quoting State ex rel. Kehoe v. McRae, 38 So. 605, 606

(Fla. 1905))); see also State ex rel. Ostroff v. Pearson, 61 So. 2d 325,

326 (Fla. 1952); Joyner v. Fla. House of Representatives, 163 So. 3d

503, 503 (Fla. 2015). However, we reject the Secretary’s

interpretation of the governing constitutional provision.

Our approach to interpreting the constitution reflects a

commitment to the supremacy-of-text principle, “recognizing that

the words of a governing text are of paramount concern, and what

they convey, in their context, is what the text means.” Planned

Parenthood of Sw. & Cent. Fla. v. State, 384 So. 3d 67, 77 (Fla.

2024) (cleaned up); see also City of Tallahassee v. Fla. Police

Benevolent Ass’n, Inc., 375 So. 3d 178, 183 (Fla. 2023) (“[W]ords

must be read and interpreted in their context, not in isolation.”

(quoting Sw. Airlines Co. v. Saxon, 596 U.S. 450, 455 (2022)));

Advisory Opinion to Governor re Implementation of Amend. 4, The

- 15 -
Voting Restoration Amend., 288 So. 3d 1070, 1079 (Fla. 2020) (a

provision’s meaning “must be drawn from the context in which it is

used”).

Article VI, section 4 states in part:

(c) No person may appear on the ballot for re-election to
any of the following offices:
(1) Florida representative,
(2) Florida senator,
(3) Florida Lieutenant governor,
(4) any office of the Florida cabinet,
(5) U.S. Representative from Florida, or
(6) U.S. Senator from Florida
if, by the end of the current term of office, the person will
have served (or, but for resignation, would have served)
in that office for eight consecutive years.

The Secretary’s reading of the text severs the phrase

“consecutive years” from the rest of the provision, leading him to

conclude that, if successful in the upcoming election, Mayfield “will

have served” in SD 19 for twelve consecutive years. This

interpretation fails to consider the words in context. See Lab’y

Corp. of Am. v. Davis, 339 So. 3d 318, 324 (Fla. 2022).

Our analysis of the various terms and phrases in this

provision must consider the text as an integrated whole. Several

factors stand out. First, the text refers to the “current term,”

inviting the reader to analyze the term of office that the potential

- 16 -
candidate currently holds, rather than looking back to an office the

potential candidate once held. If “that office” is the one to which

the potential candidate seeks election, then the text forbids the

potential candidate from doing so if he or she (but for resignation)

will have served in that office for “eight consecutive years” at the

end of the current term.

In context, we also conclude that “consecutive years” describes

unbroken periods of service in office, rather than any part of

sequential calendar years as suggested by the Secretary. And the

operation of these phrases together also sheds light on the meaning

of “re-election” in this context. The term refers to the re-election of

an incumbent who holds “that office” for the “current term.”

Our conclusion is consistent with how an ordinary person

would understand the statute’s text. Elected officials serve a term,

a fixed and continuous period of time, in a specified office. In this

context, a reasonable and informed reader would not understand

the concept of “consecutive years” of service to include periods

(other than those caused by resignation) during which the potential

candidate did not hold the specified office at all.

- 17 -
Contrary to the Secretary’s position, even if Mayfield returns to

the Senate, she would not have served as a senator for more than

eight consecutive years, for purposes of article VI, section 4.

Mayfield experienced a break in service when her senate term ended

in November 2024. The conclusion of that term, after which

Mayfield left the office of senator, brought an end to a period of

“consecutive” years of service. And if Mayfield were to win election

to SD 19 in the upcoming special election, that will restart the clock

on the calculation of her “consecutive” years of service for purposes

of article VI, section 4(c).9

If the people of Florida want other limitations on the time their

elected officials may serve, they can incorporate such language

explicitly through the constitutional amendment process. However,

until they choose to do so, we cannot read a prohibition into the

constitution that does not exist because of policy concerns over

9. We note that the language of the provision “or, but for
resignation, would have served,” bolsters our reading that this
applies to those currently holding the office they wish to seek by re-
election. Art. V, § 4(c). A current office holder is precluded from
resigning early from his or her position simply to seek re-election for
the same office. Again, that is not the factual scenario we have
here.

- 18 -
gamesmanship. Floridians are entitled to vote for the candidate of

their choice that has qualified for the office pursuant to

constitutional and statutory requirements, as Mayfield has done in

this case.

IV

For the reasons given above, we grant the petition for

mandamus but withhold the writ confident that the Secretary will

promptly comply with this opinion no later than 3:00 p.m. on

Friday, February 14. We deny the petition for quo warranto as

moot.

No motion for rehearing will be considered by this Court.

It is so ordered.

MUÑIZ, C.J., and LABARGA, COURIEL, and SASSO, JJ., concur.
CANADY, J., concurs specially with an opinion, in which LABARGA,
J., concurs.
FRANCIS, J., concurs with an opinion.

CANADY, J., concurring specially.

I agree with the majority’s conclusion that the Secretary failed

to carry out his clear ministerial duty and that article VI, section 4

of the Florida Constitution (“section 4”) does not bar Representative

Mayfield from placement on the ballot for the Senate District 19

- 19 -
special election. I write separately to express the view that this case

presents circumstances that would justify departure from our

standard practice in similar writ proceedings of assuming that

compliance will be forthcoming and therefore withholding issuance

of the writ.

Here, two circumstances support immediate issuance of the

writ of mandamus compelling immediate compliance. First, this

case has come to us because the Secretary has—without any

plausible legal basis—taken action that threatens to disrupt the

orderly and fair administration of the special election for Senate

District 19. Second, time is of the essence.

As the majority explains, in determining a candidate’s

qualification under section 99.061(7)(c), Florida Statutes (2024), the

Secretary “performs a ministerial function.” Majority op. at 6

(quoting § 99.061(7)(c), Fla. Stat.). The statute makes clear beyond

any doubt that the ministerial function involves determining only

whether the items required to be filed in connection with

qualifying—that is, the qualifying papers—have been “properly filed”

and “whether each item is complete on its face.” § 99.061(7)(c), Fla.

Stat. Determining the facial completeness and proper filing of those

- 20 -
items includes evaluating whether “items that must be verified have

been properly verified” by the candidate under oath or affirmation

as required by section 92.525(1)(a), Florida Statutes (2024).

§ 99.061(7)(c), Fla. Stat. The determination of facial completeness

and proper filing does not involve an inquiry into the truthfulness of

anything in the qualifying papers. The Secretary must determine

whether the verification is in proper form but must not determine

whether the facts that are sworn to or affirmed in the verification

are true.

The statute leaves no doubt about the strictly circumscribed

nature of the Secretary’s ministerial duty and authority. It provides

that the Secretary “may not determine whether the contents of

the qualifying papers are accurate.” Id. (emphasis added). What

could be more clear? And if the Secretary is not the arbiter of the

accuracy of the qualifying papers, he certainly cannot be the arbiter

of other facts or legal questions related to the candidacy of a person

who has submitted qualifying papers that on their face satisfy the

statutory requirements for qualification.

The Secretary gives short shrift to the clear command of the

statute, arguing in effect that the Secretary has a “duty” to ignore

- 21 -
the statutory restrictions placed on his role in the qualifying

process. But the Secretary is required to obey the restrictions laid

down in the statute. It is indeed remarkable that the Secretary

must be instructed on this elementary legal principle.

Rather than coming to grips with the statute governing the

submission and acceptance of qualifying papers, the Secretary

submits an argument that distorts what the statute says about

verified documents and that turns a blind eye to key portions of the

statutory text. The Secretary—purporting to quote the statute—

says that he rejected Representative Mayfield’s candidacy because

he “could not ‘properly verif[y]’ the material needed for

qualification.” Resp. Br. at 3 (alteration in original) (quoting

§ 99.061(7)(c), Fla. Stat.). This unmistakably suggests that the

statute authorizes the Secretary to determine the accuracy of the

qualifying papers. But the statute uses the term “verified” in a

technical sense denoting documents that are sworn or affirmed with

the requisite legal formalities. And under the statute qualifying

documents are thus “verified” by the candidate—not by the

Secretary. In a strikingly disingenuous argument, the Secretary

flips the meaning of the term to a different sense in support of an

- 22 -
argument that is directly contradicted by the statutory text. In

doing so, the Secretary says not a word acknowledging that the

statute expressly prohibits the Secretary from determining “whether

the contents of the qualifying papers are accurate.” § 99.061(7)(c),

Fla. Stat. This is not the sort of argument that any litigant—much

less an officer of the state of Florida—should present in any court.

The Secretary’s position on the meaning of section 4 is also

meritless. As is evident from the majority’s analysis, section 4’s

term limit of eight consecutive years can apply only to a person who

seeks to appear on the ballot for reelection to an office that the

person currently holds or would currently hold but for resignation.

Section 4’s identification of “the current term of office” of persons

subject to its operation defeats the argument that a person who has

left an office (other than by resignation) is subject to the term limits

restriction based on previous service in that office. Absent

resignation, a person who is no longer in the office for which

election is sought has no “current term of office” and thus cannot

come within section 4’s scope.

The provision therefore contemplates disqualification of a

person who—at the time of placement on the ballot—holds the office

- 23 -
sought (or would hold it but for resignation) and who “by the end of

the current term of office” “will have served (or, but for resignation,

would have served) in that office for eight consecutive years”—that

is, for a continuous, uninterrupted eight-year period terminating at

the end of the current term. Since Representative Mayfield has no

“current term of office” in the Florida Senate, section 4 does not

prevent her appearance on the ballot for the Senate District 19

special election. Under the terms of section 4, Representative

Mayfield’s prior service in the Florida Senate—which concluded in

2024—is irrelevant.

A constitutional provision certainly could be fashioned to

impose a lifetime limit on service in a particular office. See, e.g.,

Amend. XXII, U.S. Const. (“No person shall be elected to the office of

the President more than twice, and no person who has held the

office of President, or acted as President, for more than two years of

a term to which some other person was elected President shall be

elected to the office of the President more than once.”). Similarly, a

constitutional provision could be framed to impose a specific period

of ineligibility to seek reelection after service of defined duration in a

- 24 -
particular office has been completed. But neither sort of provision

is in the text adopted by the people of Florida.

LABARGA, J., concurs.

FRANCIS, J., concurring.

I concur fully that Mayfield is entitled to mandamus

relief. But I write separately because I would accept the Secretary’s

invitation to recede from Whiley v. Scott, 79 So. 3d 702 (Fla. 2011),

and dismiss the petition for the writ of quo warranto for lack of

standing.

Original Proceeding – Quo Warranto & Mandamus

Ricardo A. Reyes, Sacha A. Boegem, and Anthony Quintana of
Tobin Reyes PLLC, Boca Raton, Florida,

for Petitioner

Frank Mari of Tessitore Mari, PLLC, Lake Mary, Florida,

for Respondent Tim Bobanic, in his official capacity as the
Supervisor of Elections for Brevard County, Florida

Mohammad O. Jazil, Michael Beato, and Randall M. Raban of
Holtzman Vogel Baran Torchinsky & Josefiak PLLC, Tallahassee,
Florida; and Bradley R. McVay, Deputy Secretary of State for Legal
Affairs and Election Integrity, Joseph S. Van de Bogart, General
Counsel, and Ashley Davis, Chief Deputy General Counsel, Florida
Department of State, Tallahassee, Florida,

for Respondents Cord Byrd, in his official capacity as Florida
Secretary of State, and Maria Matthews, in her official capacity
as Director of Florida Division of Elections

- 25 -