Administrative rule challenge; MI Admin Code R 169.28 & 168.314; Exhaustion of administrative remedies; MCL 24.264; Warren Consol Sch Dist v School Dist of Hazel Park; Laches; Election-related civil action; MCL 691.1031; Unclean hands; Candidate affidavit of identity (AOI); False statements; MCL 168.558(4); Michigan Campaign Finance Act (MCFA); Campaign statements; MCL 169.233(1)(c); MCL 169.235(1); Committee dissolution statement; MCL 169.224(7); Late filing fees; MCL 169.233(7); MI Admin Code R 169.4; Mandamus; Declaratory relief

The court held that the Court of Claims properly dismissed plaintiff’s administrative-rule challenges for failure to exhaust administrative remedies and laches, and properly rejected his claim that the nonparty-candidate’s (M) AOI contained false statements. Plaintiff challenged M’s eligibility to appear on the November 2026 ballot, asserting her AOI was false because of unresolved campaign-finance statements and late fees from a prior judicial campaign. The Court of Claims granted summary disposition to defendant. On appeal, the court first held that plaintiff failed to exhaust administrative remedies as to his challenges to two administrative rules, Rule 169.28 and Rule 168.314, because MCL 24.264 requires a party to “first” request a declaratory ruling from the agency, and plaintiff’s same-day demand for a ruling within hours did not show the agency failed to act “expeditiously.” The court also held that laches barred those claims because plaintiff recognized the emergency election deadlines but delayed adding new claims, which “nullif[ied] work already performed at public expense” and left the courts little time for review. As to the AOI, the court held that M’s campaign-statement certification was accurate when signed because she had filed late reports before executing the AOI, and the MCFA does not bar late filing. It also held that M’s late-fee certification was accurate because although the underlying late filings had occurred, the fee had not yet been assessed, and she therefore had not yet been “commanded or compelled to pay” it. Affirmed.