Michigan Election Law (MEL); Michigan Campaign Finance Act (MCFA); Candidate affidavit of identity; MCL 168.558; Mich Admin Code, R 168.2; Late filing fees; Waiver for good cause; MCL 169.215(1)(f); Retroactivity; Mootness; Declaratory judgment; Complaint amendment; Laches; Waiver; Candidate name on ballot; MCL 168.560b

The court held that plaintiff’s claims related to the 2024 election were moot, complaint amendment would have been futile, and defendants were entitled to dismissal of her ballot-access and ballot-name claims. Plaintiff sued county and city election officials after she was disqualified from the 2024 general-election ballot because she owed late filing fees and falsely stated in her affidavit of identity that all fees and fines had been paid. The trial court granted defendants summary disposition. On appeal, the court first held that the 2024-election claims were moot because the election had passed and relief would have “no practical effect.” Although the trial court should have considered amendment, the court held that amendment was futile because plaintiff merely continued to assert that she was entitled to waiver of the same fees. The court next held that Rule 168.2 was not improperly applied retroactively because candidates already had to file truthful affidavits, and the rule imposed new record-checking duties on election officials, not “new legal obligations for candidates.” The court also held that plaintiff failed to establish good cause for waiver because her medical letter did not show inability to file the required paperwork, her treasurer’s death did not excuse years of filings, and a 2017 password issue did not justify waiving fees for other campaigns. Finally, the court held that the claim against the city clerk failed because MCL 168.560b governs how a name appears on the ballot, and plaintiff did not dispute that her name was correct on the 2021 ballot. Affirmed.