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Author Sloan v. Rudiano - Petition for Certiorari
Sam Sloan

2004-11-01, 12:45 am

IN THE SUPREME COURT OF THE UNITED STATES

OCTOBER TERM 2004

____________________

SAMUEL H. SLOAN - PETITIONER

vs.

DIANE HASLETT RUDIANO, GLADYS PEMBERTON, AARON
MASLOW, HY SINGER, KING'S COUNTY REPUBLICAN PARTY,
ISABELLA JEFFERSON, BROOKLYN REPUBLICANS UNITED
FOR NEW LEADERSHIP, NEW YORK REPUBLICAN STATE
COMMITTEE, SANDY TREADWELL, PETER S. KOSINSKI, and
CAROL BERMAN, NEIL W. KELLERHER, HELENA MOSES
DONOHUE and EVELYN J. ACQUILA, Commissioners of Elections,
Constituting the New York State Board of Elections, and New York
City Commissioners of Elections NERO GRAHAM, FREDERIC M.
UMANE, WEYMAN A. CAREY, MICHAEL J. CILMI, MARK B.
HERMAN, DOUGLAS A. KELLNER, TERRENCE C. O'CONNOR,
NANCY MOTTOLA-SCHACHER, STEPHAN H. WEINER,

- RESPONDENTS -

____________________

ON PETITION FOR A WRIT OF CERTIORARI TO THE UNITED STATES COURT OF
APPEALS FOR THE SECOND CIRCUIT
____________________

PETITION FOR A WRIT OF CERTIORARI
____________________

Samuel H. Sloan
920 Belmont Avenue
Brooklyn NY 11208
(718) 327-3669

E-Mail: samsloan@samsloan.com

Web Address: http://www.samsloan.com/candidates.htm

QUESTIONS PRESENTED

1. To what extent may state governments set requirements for US
Congress beyond those enumerated in the Constitution, which are only
that the person must be 25 years old and have been a citizen for seven
years and reside in the state?

2. Under what circumstances may a state or city or county Board of
Elections kick a candidate for US Congress off the ballot, as has
happened here?

Petitioner is a Candidate for Election to the United States Congress
for the Tenth Congressional District of New York. The incumbent is
Edolphus Towns, a Democrat, who has not faced a Republican Opponent
for 14 years since 1990. Petitioner was approved as a Republican Party
Candidate at a meeting of the Executive Committee of the Kings County
Republican Party in Brooklyn on May 5, 2004. Subsequently, Diane
Rudiano, who is both secretary of the Kings County Republican Party
and Chief Clerk of the Kings County Board of Elections took a
disliking to the petitioner and decided that she did not want his name
on the ballot. She has ever since conducted a campaign against
petitioner, using her full powers as both an election official and a
party official. After substituting several alternate candidates and
kicking petitioner off the ballot, she recently settled on Harvey
Clarke, who, it has recently been discovered, is not eligible to serve
in Congress because he only became a citizen in June, 2004 and has not
been a citizen for Seven Years as is required by Article I Section 2
of the US Constitution.

An Emergency Hearing is required on this matter because the
Election will be held on November 2, 2004, which is only five days
from today.

In New York State, perhaps more than any other state, the
candidates are controlled by the party officials. Almost all elections
are uncontested. In addition, as this case demonstrates, the rules
and procedures are completely ignored. Petitioner maintains that the
entire procedure is unconstitutional. This case has demonstrated that
it is not merely difficult but impossible to run against a party
machine controlled by a handful of officials in New York State.
Petitioner requests review of the entire election procedure, for
reasons more fully explained in the attached motions which were filed
in the US District Court and in the US Court of Appeals.

JURISDICTION

This case was brought under 42 USC 1983. On October 28, 2004, the
United States Court of Appeals for the Second Circuit denied
Petitionerfs Emergency Motion for a Preliminary and Permanent
Injunction restoring Samuel H. Sloan to the ballot and removing Harvey
Clarke from the ballot. See Sloan v. Rudiano 04-5595-CV. The same
motion was previously denied by Judge David G. Trager of the United
States District Court for the Eastern District of New York. Petitioner
has 90 days from October 28, 2004 to file this petition. There are no
reported decisions.

STATEMENT OF THE CASE

This is a proceeding against the Republican Party, its Chairman, Hy
Singer, and First Vice-Chairman, Diane Haslett-Rudiano, and others
associated with them and against the New York State Board of Elections
and the New York City Board of Elections.

The issue concerns the primary and general elections for United States
Congress from the Tenth Congressional District of New York. The
General Election is set for November 2, 2004.

POINT I

PETITIONER HAS A VALID-WILSON PAKULA, WHICH RESPONDENTS REFUSED TO
FILE IN VIOLATION ELECTION LAW, OF THE RIGHTS OF PETITIONER AND OF THE
RIGHTS OF THE VOTERS

On or about July 8, 2004, the district court held a hearing by
telephone conference call. Mr. Theodore Alatsas, the new attorney for
the Kingfs County Republican Party, was on the line and argued that
under the case of Montano v. Lefkowitz, 575 F.2d 378 (2d Cir. 1978)
the Wilson-Pakula granted to Petitioner by the Executive Committee of
the Kinges County Republican Party on May 5, 2004 was invalid.
However, this court after hearing argument on this issue rejected the
contention of Mr. Alatsas and ruled that provided that Petitioner can
prove at a hearing that a majority of the residents of the Tenth
Congressional District on that committee voted in his favor,
Petitioner is entitled to the Wilson-Pakula.

Since then, Mr. Alatsas has defied the order of this court and is in
contempt of court because he has continued to argue before the Board
of Elections, before the New York State Supreme Court and before the
Appellate Division Second Department of the State Supreme Court that
under Montano v. Lefkowitz, 575 F.2d 378 (2d Cir. 1978) Petitioner
does not have a valid Wilson-Pakula. In addition, Mr. Alatsas has
failed and refused to file the Wilson-Pakula with the New York City
Board of Elections and Petitioner has been kicked off the ballot. In
all this time, Mr. Alatsas has never informed these courts and that
body of the contrary ruling by this court.

Mr. Alatsas is clearly wrong on the law. Montano v. Lefkowitz
presented almost the opposite situation. In that case, a Wilson Pakula
was not involved because Wilson-Pakulas did not exist back then.
There, the Executive Committee of the Bronx County Republican Party
appointed a candidate to fill a vacancy. However, the vacancy was in a
predominantly Black Congressional District. Most of the committee
members who voted resided outside the district and were White. A Group
of Black voters petitioned the court to invalidate the choice made by
the White guys as to who would represent the Black Congressional
District.

In the case presented here, however, Petitioner is the outsider and
the respondents are the insiders. They nominated Petitioner as their
candidate. Subsequently, they changed their minds. Now, they do not
want Petitioner any more. However, they did not re-vote the issue,
because they realize that Petitioner has substantial support within
the party and would win a revote, so they seek to invalidate the
election of him by claiming that they did not follow their own rules.

Their contention is that some of the people at the Executive Committee
meeting who voted for Petitioner do not reside in his Congressional
District and therefore the vote was invalid. However, this court ruled
that provided Petitioner can establish at a hearing that even
excluding all those votes by non-residents of the Tenth Congressional
District he still has a majority, then he wins anyway. Since the
number of votes against him was very small and the vote in his favor
was overwhelming, he is confident he can prevail on this issue. The
Republicans are not even disputing this point.

More than that, the only person that anybody can remember voting
against him on this issue was Marianna Blume, but Marianna Blume
herself is not a resident of the Tenth Congressional District. She
lives at 1661 11th Avenue, which is in the 11th Congressional
District, which is Major Owens District. Marianna Blume is also
fraudulently representing the 58th Assembly District, because she
resides in the 44th Assembly District and District Leaders are
required to reside in the district they represent.

It is established law that the State Governments may not set
requirements for US Congress beyond those enumerated in the
Constitution, which are only that the person must be 25 years old and
reside in the state. For example, the states may not require residence
in the Congressional District nor may they require length of
residence, for example. This was decided in Campbell v. Davidson,
United States Court of Appeals for the Tenth Circuit (1999)
http://www.kscourts.org/ca10/cases/2000/11/99-1257.htm .

New York Election Law is biased in favor of the Democrats. This is not
surprising because the Democrats have traditionally controlled the
state government. In order to get on the primary ballot for Congress,
one must get signatures of 5% of the electorate, up to a maximum of
3500 signatures. The Tenth Congressional District has the following
numbers of registered voters: Republican 17636, Democratic 251608,
Independence 5678, Conservative 849, Working Families 714, Blank
38,853. Total registered voters 318,387. Thus, the Republicans must
get 5% of the Republican signatures, which is 882 signatures. If the
Democrats were required to get 5% of the Democrat signatures, they
would have to get 12,081 signatures which they would never be able to
do. Instead, they only have to get 3500 signatures. As a result of
this bias in the law, the Democrats have had a candidate on the ballot
every election year, but the Republicans have not had a candidate on
the ballot for Tenth Congressional District since 1990, when Barry
Ford tried and lost. As a result, the incumbent, Ed Towns, has been in
uncontested Congressional races for the last 14 years.

The Election Law also discriminates against residents of Brooklyn. The
reason for this is that almost everybody who lives in Brooklyn works
in Manhattan. For this reason, it is much harder to find Brooklyn
voters to sign, as compared to Manhattan and other areas on New York
State where most people live and work in the same place. The combined
result of this is that there is only one elected official in all of
Brooklyn who is a Republican. The rest are all Democrats.

This year alone, a large number of Republican candidates in Brooklyn
have been kicked off the ballot by the New York City Board of
Elections, in many cases because of "Cover Sheet Errors". These Cover
Sheet Errors are being blamed on Theodore Alatsas, Counsel for the
Republican Party. If an attorney specializing in Election Law makes
mistakes which keeps his clients off the ballot, what chance do the
rest of us have?

If the Republicans are finding it difficult, independent non-enrolled
voters are finding it impossible. The petitioner here, Samuel H.
Sloan, was nominated by the Libertarian Party as a candidate for the
Tenth Congressional District, but gave up because of the
impossible-to-meet 3500 signature requirement.

In this year alone, none of the others who tried have succeeded, and
they all had substantially greater resources than Petitioner had. On
Tuesday, September 7, 2004, the New York City Board of Elections
kicked off the ballot Paul Rodriguez who was the candidate for the
School Choice Party for the 12th Congressional District (He is also
the Republican Party candidate for that District) and it kicked off
Peter Hort who was the Progressive Party Candidate for the 8th
Congressional District (He is also the Republican Party candidate for
that District) .

Commissioner Terrance OfConnor, who is a Democratic Party
Representative on the Board of Elections, moved that the Board of
Election refer these matters to the NYC Department of Investigations
for criminal prosecution of Mr. Hort and Mr. Rodriguez, but these
motions failed by a 4-4-1 tie vote.

At a previous hearing by the Board of Elections, John Daniel, the
Republican Party Candidate for the 11th Congressional District, was
kicked off the ballot. According to an article in the Brooklyn Heights
Courier, a neighborhood newspaper, this has been blamed on cover sheet
errors committed by Theodore Alatsas, the attorney appearing in this
case, who replaced Aaron Maslow, who was forced to resign as Chairman
and is now said to be resigning from the Republican Party altogether.

The conclusion is that New York State Election Law is unconstitutional
as applied, since it makes it impossibly difficult for candidates to
get on the Congressional Ballot.

In the case presented here, Petitioner collected signatures and was
put on the ballot. Then, the Kings County Republican Party filed
general objections and then specific objections with the New York City
Board of Elections. At a hearing on Wednesday, August 4, 2004, the New
York City Board of Elections kicked Petitioner off the ballot.
Petitioner then filed a petition to validate with the Kingfs County
Supreme Court on August 9, 2004. An order to show cause was signed and
given to Petitioner by the Clerkfs Office at 4:55 PM that day. This
order to show cause required Petitioner to serve the respondents to
that proceeding by Midnight that night, which Petitioner did with
great difficulty. However, at the hearing the following morning, Judge
Joseph Levine summarily dismissed the petition on the ground that
Petitioner had failed to file affidavits of service by 9:30 AM. He did
not only dismiss Petitioner's petition, but he dismissed all but one
of the other 42 petitions pending on that date on substantially the
same grounds. In each case, Judge Joseph Levine was nit-picking
affidavits of service, even though the opposing parties were present
in the courtroom and had made no such objection. (Several of these
summary dismissals have since been reversed by the Appellate
Division). Petitioner then petitioned for a rehearing. Petitioner's
rehearing was granted but upon rehearing was denied on the ground that
Petitioner had served the attorneys involved myself and not through a
process server.

Judge Joseph Levine is a Democrat who says that he served for 35 years
in the New York State Assembly. Almost all of the candidates he kicked
off the ballot on affidavit of service grounds were not Democrats or
were Democrats who had not been endorsed by Tammany Hall and the
Democrat Party Machine. Altogether, 42 candidates were kicked off the
ballot by Judge Levine. These include State candidates, not merely
Congressional Candidates. Petitioner submits that the due process of
law rights of himself and all of these other candidates were violated
by Judge Levine, since nobody could meet his strange and bizarre
"affidavit of service" requirements. For example, Judge Levine
dismissed petitions because the affidavit of service failed to note
the eye color or the hair color of the person served. He also allowed
arguments from attorneys who refused to reveal the names of the
clients they were representing.

Petitioner appealed these two decisions by Judge Joseph Levine.
Fortunately, these election cases are put on an exceptionally fast
track and are heard almost immediately. Petitioner's appeal was heard
by the Appellate Division Second Department and the decision of the
State Supreme Court was affirmed on the ground that Petitioner had
served the papers himself. (That court made no mention of the reason
given for the first decision, which was Petitioner's failure to file
affidavits of service before 9:30 AM.)

Petitioner then filed a petition for leave to appeal with the New York
Court of Appeals. Petitioner went to Albany to argue Petitioner's
petition on "Election Day", which is the only day of the year when the
New York Court of Appeals hears oral argument on petitions for leave
to appeal. Petitioner's petition for leave to appeal was denied, along
with all of the other approximately 15 petitions argued by various
attorneys on that day.

Feeling that there was substantial error, Petitioner filed a motion to
reargue in the New York Appellate Division Second Department. This
motion for reargument was denied on September 8, 2004.

Throughout all this time, Petitioner felt that Petitioner would really
win in the State Court System and Petitioner would not have to come
back to this federal court for relief. Petitioner can now see that
Petitioner was wrong. Petitioner have exhausted Petitioner's remedies
in the State Court system, thereby satisfying the "exhaustion
requirement".

Petitioner believes that the reason Petitioner cannot win in state
court in spite of having winning arguments on the merits is that the
judges of that court were elected through exactly the same system that
Petitioner is challenging. Perhaps it is too much to expect them to
put themselves out of a job. (Most of the other cases filed in State
Supreme Court before Judge Joseph Levine concerned challenges to
nominees to the Judicial Conference.)

POINT II

THE ACTUAL OBJECTORS TO THE PETITIONER ARE THE CHAIRMEN OF A PARTY
COMMITTEE, WHO ARE BARRED BY STATUTE FROM OBJECTING.

It is completely clear that the New York State Law specifically
prohibits the Chairman of a Party Committee, any party, even a
different party, from objecting to a petition when that objection
would result in a primary election being cancelled.

Election Law Section 16-102 states:

S 16-102. Proceedings as to designations and nominations, primary
elections, etc. 1. The nomination or designation of any candidate for
any public office or party position or any independent nomination, or
the holding of an uncontested primary election, by reason of a
petition for an opportunity to ballot having been filed, or the
election of any person to any party position may be contested in a
proceeding instituted in the supreme court by any aggrieved candidate,
or by the chairman of any party committee or by a person who shall
have filed objections, as provided in this chapter, except that the
chairman of a party committee may not bring a proceeding with respect
to a designation or the holding of an otherwise uncontested primary.

The operative words in the above paragraph are: "except that the
chairman of a party committee may not bring a proceeding with respect
to a designation or the holding of an otherwise uncontested primary."

In Soda v. Dahlke, decided August 18, 2004,
http://www.courts.state.ny.us/repor.../2004_06380.htm ,
the Appellate Division - Fourth Department ruled that the Chairman of
the Democratic Party could not object to a petition with respect to a
candidate in the Republican Party.

In each of Petitionerfs cases the objector was not an opposing
candidate, since there was no opposing candidate except for Ed Towns
who did not object, but rather the Chairman of the party through the
Party Counsel. Mr. Theodore Alatsas representing the Republican Party
objected to the Republican Party petition and Mr. Gary Sinawski
representing the King's County Republican Party objected to the
Republican Party Petition.

In the case presented here, the nominal objector did not appear. Only
the General Counsel to the Kings County Republican Party appeared. Who
paid the fees of this attorney? Did the nominal objector pay? I doubt
it, since the nominal objector did not come to the hearing. If the
Republican Party paid, this may constitute a criminal offense of
misuse of party funds.

The nominal objector was just a front. He is not a candidate and has
no reason to object. However, the Chairman wants to keep control of
his party by making sure that only the persons he designates gets on
the ballot and no primary election is held. It is precisely because
the Chairman of a Party would want to keep the party under his
personal control to the exclusion of the voters and the other members
of his party that New York State Law prohibits the Chairman of any
Party Committee from objecting to a Petition, if the result is that
there is no primary election. The relevant case law is: Davis v.
Dutchess County Board of Elections 153 AD 2d 716, 544 NYS 2d 683 (1989
2d Dept.), Matter of Crawley v Board of Elections of County of
Rensselaer, 218 AD2d 914, 915, lv denied 86 NY2d 704; Matter of
Maltese v Anderson, 264 AD2d 457; Matter of Grogan v Conservative
Party of N.Y. State, 77 AD2d 736, 736-737), Soda v. Dahlke, decided
August 18, 2004,
http://www.courts.state.ny.us/repor.../2004_06380.htm .
In short, the actual objector is the Party Chairman. The Party
Chairman and his counsel have committed a fraud on the other members
of his party, on the Board of Elections and ultimately on the voters
by putting up this front person to play the role of objector, when the
Chairman, who is barred from this activity, is the real objector.

POINT III

PETITIONERS CONSTITUTIONAL RIGHTS HAVE BEEN VIOLATED AND NEW YORK
STATE ELECTION LAW AS APPLIED IN THIS CASE IS UNCONSTITUTIONAL

Attached to the Petition as Exhibit A is the official candidates list
printed out from the Board of Elections website last month. Please
note that under Tenth Congressional District appears the name of Sam
Sloan as a candidate for the Republican Party and the Republican
Party. Also, note that an OTB candidate appears for the Conservative
Party and the Working Families Party. (An OTB candidate is essentially
a write-in candidate).

Now compare that with the current Candidates List on the Board of
Elections website at
http://vote.nyc.ny.us/pdf/documents...ndidacyList.pdf
.. It can be seen that the name of Sam Sloan has disappeared and one of
the two OTB Candidates has disappeared. (Also, note that the
Republican Party no longer has a candidate for the 11th Congressional
District just below it).

The Courier Life Chain of Newspapers which includes the Brooklyn
Heights Courier and Flatbush Life has followed Petitioner's efforts to
get on the ballot and has mentioned Petitioner's name almost every
week. These weekly articles can be seen at
http://www.lidbrooklyn.org/bp.htm . (Look at the list at the bottom of
that website).

These articles state that Petitioner's case has proven that it is
impossible, not merely difficult but IMPOSSIBLE, for a candidate not
supported by the major parties to get on the Congressional Ballot.
This raises a constitutional question because the state clearly is not
allowed to impose requirements so difficult as to make it impossible
to get on the ballot.

It is noteworthy that the local press has commented on this situation.
For example, Flatbush Life for August 23, 2004, page 10 states:

"Sloanfs effort was an example of how impossible it can be for a
non-lawyer to run for office and navigate the legal system on his
own."

Similarly, an article dated July 19, 2004 appearing in Bay News, page
10 and at http://www.lidbrooklyn.org/bp.htm states the following:

"A federal judge said he was inclined to agree with Sam Sloan's
argument that Sloan received a valid Wilson-Pakula from the Republican
Party, qualifying him to seek ballot access on the Republican line.
Unfortunately for Sloan, the case was heard just a week before the
petition deadline, leaving him with the impossible task of getting
valid signatures from 886 registered Republicans in the 11th
Congressional District by midnight on July 15."

Please note the repeated use of the word IMPOSSIBLE to describe
Petitionerfs situation. This raises issues of Constitutional
proportions.

It has been established in decisions by the federal courts that the
states may not add additional requirements to the qualifications for
United States Congress beyond those enumerated in the Constitution,
which are only that the person must be 25 years old and reside in the
state. This was decided in Campbell v. Davidson, United States Court
of Appeals for the Tenth Circuit (1999)
http://www.kscourts.org/ca10/cases/2000/11/99-1257.htm . Since April,
Petitioner has worked full time, 14 hours a day, days a week, trying
to get on the ballot, and knowing that he will win election if he ever
does get on the ballot.

Petitioner has exhausted his state remedies and still cannot get on
the ballot.

Without repeating the arguments above, it is obvious that petitioners
Constitutional Rights have been violated and his due process rights
have been violated. More importantly, THE RIGHTS OF THE VOTERS HAVE
BEEN VIOLATED, because the result of this will be an uncontested
election and there has been no contested election for the Tenth
Congressional District since 1990.

CONCLUSION

For all of the reasons set forth above, this writ must be granted and
this court must issue a temporary restraining order and a preliminary
and permanent injunction granting the following:

1. A preliminary and permanent injunction requiring that the name of
the Petitioner be placed on the ballot as a candidate for Congress for
the Tenth Congressional District.

2. A preliminary and permanent injunction requiring that the name of
the Petitioner be placed on the ballot in the General Election in
November as a candidate for Congress from the 10th Congressional
District.

3. An Order declaring valid, proper and legally effective the
designating petitions heretofore filed in the office of the Board of
Elections of the City of New York designating the petitioner herein,
Samuel H. Sloan, as a candidate in the Republican to be held on
September 14, 2004 for election to the Office of Congressman in the
United States Congress representing the 10th Congressional District of
Brooklyn New York; and

4. An Order directing, requiring and commanding the Board of Elections
in the City of New York to place and print the name of the petitioner
herein on the ballot as a candidate for election to the United States
Congress from the Tenth Congressional District in the Republican to be
held on September 14, 2004; and

5. An order enjoining and restraining the said Board of Elections in
the City of New York from printing, issuing or distributing for use
during said Election in the Tenth Congressional District any official
ballot upon which the name of the petitioner does not appear as a
candidate for election to the United States Congress.

6. Such other and further relief as may be just and equitable.

Dated: October 28, 2004

Respectfully
Submitted,

Samuel H. Sloan

Paul Rubin

2004-11-01, 12:45 am

sloan@ishipress.com (Sam Sloan) writes:
quote:

> It is established law that the State Governments may not set
> requirements for US Congress beyond those enumerated in the
> Constitution, which are only that the person must be 25 years old and
> reside in the state.


Whoops. I guess that new-citizen guy is eligible after all.
Sam Sloan

2004-11-01, 6:45 am

On 31 Oct 2004 19:47:31 -0800, Paul Rubin
<http://phr.cx@NOSPAM.invalid> wrote:
quote:

>sloan@ishipress.com (Sam Sloan) writes:
>
>Whoops. I guess that new-citizen guy is eligible after all.


Thank you for pointing out this error. I did not proof-read it
carefully enough. Article I Section 2 of the US Constitution states:

Article I

Section 1. All legislative powers herein granted shall be vested in a
Congress of the United States, which shall consist of a Senate and
House of Representatives.

Section 2. The House of Representatives shall be composed of members
chosen every second year by the people of the several states, and the
electors in each state shall have the qualifications requisite for
electors of the most numerous branch of the state legislature.

No person shall be a Representative who shall not have attained to the
age of twenty five years, and been seven years a citizen of the United
States, and who shall not, when elected, be an inhabitant of that
state in which he shall be chosen.
StanB

2004-11-01, 9:45 am


"Sam Sloan" <sloan@ishipress.com> wrote in message
news:4185e6df.10161000@ca.news.verio.net...
quote:

> Thank you for pointing out this error. I did not proof-read it
> carefully enough.


A common theme in your so-called writings.


R.P. Warren

2004-11-02, 12:46 am

sloan@ishipress.com (Sam Sloan) wrote in message news:<4185e6df.10161000@ca.news.verio.net>...
quote:

> I did not proof-read it carefully enough. >


True. Another erratum:

'For example, the states may not require residence in the
Congressional District nor may they require length of residence, for
example.'

Two 'for examples' is redundant. You should delete one or the other.
Or you might just give up the whole quixotic idea and quit filling up
this newsgroup like it was your personal litterbox.
Paul Rubin

2004-11-04, 5:47 pm

sloan@ishipress.com (Sam Sloan) writes:
quote:

> It is established law that the State Governments may not set
> requirements for US Congress beyond those enumerated in the
> Constitution, which are only that the person must be 25 years old and
> reside in the state.


Whoops. I guess that new-citizen guy is eligible after all.
StanB

2004-11-04, 5:47 pm


"Sam Sloan" <sloan@ishipress.com> wrote in message
news:4185e6df.10161000@ca.news.verio.net...
quote:

> Thank you for pointing out this error. I did not proof-read it
> carefully enough.


A common theme in your so-called writings.


R.P. Warren

2004-11-04, 5:47 pm

sloan@ishipress.com (Sam Sloan) wrote in message news:<4185e6df.10161000@ca.news.verio.net>...
quote:

> I did not proof-read it carefully enough. >


True. Another erratum:

'For example, the states may not require residence in the
Congressional District nor may they require length of residence, for
example.'

Two 'for examples' is redundant. You should delete one or the other.
Or you might just give up the whole quixotic idea and quit filling up
this newsgroup like it was your personal litterbox.
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