Judicial candidate; Nominating petitions; Signature requirement; MCL 168.544f; Secretary of State review; MCL 168.552(6) & (13); Laches; Election-related civil action; MCL 691.1031; Relation back; MCR 2.118(D); Unclean hands; Declaratory judgment; Mandamus; Clear legal duty; Drissman v Michigan Dep’t of State; Davis v Wayne Cnty Election Comm’n; Kennedy v Secretary of State; Evidentiary hearing & limited discovery

The court held that the Court of Claims properly applied laches to plaintiffs’ newly added claims and properly dismissed their remaining declaratory-judgment and mandamus claims under MCR 2.116(C)(8). Plaintiff-Leggs sought certification as a nonincumbent Wayne Probate Court judicial candidate, but the county clerk determined her nominating petitions contained only 3,661 valid signatures, short of the 4,000 required. Defendant-SOS declined to process her appeal because even rehabilitating the 162 challenged signatures she identified would leave her with only 3,823 valid signatures. Plaintiffs then filed an expedited Court of Claims action and later amended the complaint to add new claims after the SOS had already moved for summary disposition. On appeal, the court first held that laches barred the newly added rulemaking and due process claims. It reasoned that, in an election case, “a delay of 17 days in asserting new claims can result in extreme prejudice,” particularly where plaintiffs’ amendment mooted work already performed by the SOS and compressed review before ballot deadlines. The court rejected plaintiffs’ unclean-hands argument because “‘equity does not require complete blamelessness’” and plaintiffs failed to show bad faith by the SOS. The court next held that plaintiffs were not entitled to declaratory relief because they identified no statute requiring the SOS to conduct the specific form of review they demanded. It likewise held that mandamus was unavailable because plaintiffs cited “no statutory authority” imposing a clear legal duty to conduct a full signature review or direct the clerk to certify Leggs. Finally, because the claims failed as a matter of law, the Court of Claims properly denied an evidentiary hearing and limited discovery. Affirmed.