CASE STUDIES IN EMERGENCY ELECTION LITIGATION

Federal Judicial Center 9/14/2023 1

Including on the Ballot 

Nominees of a Fractured Minor Party 

Watson v. Miller 

(Paul V. Gadola, E.D. Mich. 4:00-cv-40336) 

Supporters of a minor party’s presidential nominee filed a federal 

complaint to require the state’s secretary of state to include the 

nominee on the general-election ballot after being denied such relief by the state’s supreme court. Two rival factions of the party had 

put forward separate nominees. The federal district judge ruled that 

the plaintiffs had not established a clear right to the requested relief, 

and an appeal was dismissed by stipulation. 

Subject: Getting on the ballot. Topics: Getting on the ballot; 

party procedures; interlocutory appeal; matters for state courts. 

Because two competing factions of the Reform Party named different presidential nominees in 2000, Michigan’s secretary of state decided not to include the Reform Party on the November 7, 2000, ballot.1

 Two voters supporting the nomination of Pat Buchanan filed a federal complaint in the 

Eastern District of Michigan late in the afternoon of Friday, September 15, 

2000, challenging the secretary’s decision.2 With their complaint, the plaintiffs filed a motion for a preliminary injunction.3

The court assigned the case to Judge Paul V. Gadola, who was out of state 

on that day, but who returned on Sunday and held a hearing first thing 

Monday morning.4

The federal complaint was filed on the day that Michigan’s supreme 

court denied relief to the Buchanan campaign.5

 The campaign sought a writ 

of mandamus in Michigan’s circuit court and failed to prevail in an appeal 

from denial of that relief.6 As a result of decisions by Michigan’s secretary of 

state and Michigan’s courts, Buchanan’s rival for the Reform Party nomination would appear on Michigan’s ballot, because the rival was also nominated by the Natural Law Party.7

1. See Transcript at 5–7, Watson v. Miller, No. 4:00-cv-40336 (E.D. Mich. Sept. 18, 2000, 

filed Sept. 19, 2000), D.E. 9; see also Amy Franklin, Buchanan Camp Works for Spot on State 

Ballot, Grand Rapids Press, Sept. 1, 2000, at C4. 

2. Docket Sheet, Watson, No. 4:00-cv-40336 (E.D. Mich. Sept. 15, 2000) [hereinafter E.D. 

Mich. Docket Sheet] (D.E. 1); see Transcript, supra note 1, at 4–5, 14–15. 

3. E.D. Mich. Docket Sheet, supra note 2 (D.E. 2); see Transcript, supra note 1, at 15. 

4. Transcript, supra note 1, at 1–4, 15 (noting that the proceeding began at 8:45 a.m.). 

Judge Gadola died on December 26, 2014. Federal Judicial Center Biographical Directory 

of Article III Federal Judges, www.fjc.gov/history/judges. 

5. Buchanan v. Sec’y of State, 463 Mich. 867, 616 N.W.2d 162 (2000); see Transcript, supra note 1, at 10; see also Amy Franklin, Justices Block Reform Candidates, Grand Rapids 

Press, Sept. 16, 2000, at A6. 

6. Buchanan, 463 Mich. at 867, 616 N.W.2d at 162 (Justice Stephen Markman, concurring); see Transcript, supra note 1, at 7–9. 

7. See Transcript, supra note 1, at 8. 
Including on the Ballot Nominees of a Fractured Minor Party 

2 Federal Judicial Center 9/14/2023 

After a hearing recess of fourteen minutes, Judge Gadola denied the 

plaintiffs relief.8

 He saw their requested relief as a writ of mandamus, with a 

stricter standard than a preliminary injunction’s.9 Under either standard, 

however, Judge Gadola found that the plaintiffs had not shown a clear entitlement to place Buchanan on the ballot as the Reform Party’s candidate.10

An appeal was dismissed by stipulation on November 2.11

8. Id. at 72, 89. 

9. Id. at 77, 87–88. 

10. Id. at 83–84, 88, 97. 

11. Docket Sheet, Watson v. Miller, No. 00-2076 (6th Cir. Sept. 20, 2000) (D.E. 25).