Petition seeking to recall the Governor; Const. 1963, art. 2, § 8; MCL 168.951(1); Submission of the petition to the Board of State Canvassers; MCL 168.951a(2); The Board’s duty to determine whether the petition’s language is clear & factual; MCL 168.951a(3); Standard of review for clarity; Donigan v Oakland Cnty Election Comm’n; Form; MCL 168.951a(1)(e); List of reasons for recall; MCL 168.951a(1)(c) & (3)

Holding that appellee-Board of State Canvassers did not err by certifying the petition of appellee-Baase, who sought approval of a petition to recall appellant-Governor, the court affirmed. Baase submitted a recall petition for the Board to determine whether its language was clear and factual. At the hearing, appellant argued that the petition was not sufficiently clear because it “did not identify appellant in the petition’s reasons section, it contained a long run-on sentence, and its descriptions of the orders were vague, ambiguous, and did not include the exceptions or exemptions in the executive orders.” The Board determined that the petition factually and clearly stated the reasons for recall. On appeal, the court rejected appellant’s argument that “the Board applied an incorrect standard by giving Baase’s petition the benefit of the doubt when it determined whether the reasons for the recall were sufficiently clear.” It noted that the Board’s “apparent acceptance of a Board member’s opinion that the Board ‘should give the benefit of the doubt to [Baase],’ and that the voters would be able to understand the petition because it was ‘factually clear,’ was not the application of an incorrect standard.” It also rejected her claim that the petition was not sufficiently clear because it did not separately identify her “as the official to be recalled in the reasons area of the petition, and that the Board exceeded its power of review by considering the” heading. The court concluded that the “Board did not err by considering the entire form when approving the petition.” The court further noted that, even if Baase’s petition was ungrammatical, “the law does not require a petition to be drafted with perfect grammar; the law only requires the petition to be sufficiently clear.” The Board did not err by declining to reject the petition “on the basis that its technical execution was not perfect.” Finally, the court rejected her argument that the petition misrepresented the executive orders because the summary statements did not describe their exceptions and exemptions. “MCL 168.951a(1)(c) does not apply to the executive order descriptions because they are not legislation.” Moreover, while Baase’s summaries did “not include all possible exceptions and exemptions, his descriptions were not false or misleading.”