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Facts

  • Anastacia Golden Morper sought preprimary designation as a candidate for the United States Representative from New Mexico's Third Congressional District in the 2020 Republican Party Pre-Primary Convention. She filed forty-nine nominating petitions along with her declaration of candidacy but was required to obtain at least 463 valid signatures. The Secretary of State invalidated forty-four of Morper's petitions for omitting the heading "2020 PRIMARY NOMINATING PETITION," deeming it critical information required by law, thus invalidating over seven hundred signatures and leaving Morper with insufficient signatures to qualify as a candidate. Morper appealed the Secretary's decision to the district court, which upheld the Secretary's decision (paras 1-2, 4-7).

Procedural History

  • District Court of Santa Fe County: Upheld the Secretary of State's decision to invalidate Morper's nominating petitions for not including the heading "2020 PRIMARY NOMINATING PETITION" (para 11).

Parties' Submissions

  • Petitioners-Appellants: Argued that the Secretary of State was not authorized to invalidate Morper's nominating petitions simply because they did not include the heading "2020 PRIMARY NOMINATING PETITION." They maintained that Morper's petitions conformed to the statutory form and that the signatures on the invalidated petitions should have been counted (paras 8-9).
  • Respondent-Appellee (Secretary of State): Asserted that she is bound by the Legislature's mandate regarding the form of the nominating petition and argued that she has the authority to prescribe the form of the nominating petition, including the heading, as part of her duties to approve forms and procedures used in elections (para 10).

Legal Issues

  • Whether the Secretary of State has the discretion to invalidate nominating petitions that do not include the heading "2020 PRIMARY NOMINATING PETITION," a requirement not explicitly stated in the statute (paras 2, 12-26).

Disposition

  • The Supreme Court of the State of New Mexico reversed the district court's judgment, ordered the district court to vacate its order, and directed the Secretary of State to certify Morper’s candidacy (para 3).

Reasons

  • The Supreme Court, per Justice Thomson, concluded that the Secretary of State improperly invalidated Morper's nominating petitions for omitting the heading "2020 PRIMARY NOMINATING PETITION." The Court found that the statutory form prescribed by the Legislature did not specifically require this heading. It determined that all necessary information as required by law was included in Morper's petitions, and the omission of the heading should not be fatal to her candidacy. The Court emphasized the importance of protecting the right of New Mexico citizens to vote for the candidate of their choice and concluded that the Legislature did not delegate the power to the Secretary to invalidate nominating petitions that conform with the statutory requirements, even if they omitted the heading added by the Secretary. The Court's decision was based on statutory construction and the limits of the Secretary’s statutory authority to approve forms and procedures used in elections (paras 12-26).
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