Marin v. Secretary of the Commonwealth, 41 A.3d 913

Marin, proceeding pro se, sought declaratory relief and injunctive relief challenging Section 910 of the Pennsylvania Election Code, arguing his privacy rights require him not to disclose his home address on nomination papers.
He alleged that his home address would be disclosed to the public and could subject him to threats, harming his ability to run for office.
Respondents included the Secretary of the Commonwealth, the Department of Community Development's OOR, Terry Mutchler, and the Bureau of Commissions, Elections and Legislation; they filed preliminary objections in the nature of a demurrer.
The court treated the objections as sustaining that the OOR and Mutchler are not proper parties to review the Election Code issue and that Marin lacks standing.
The court also concluded that Marin’s First and Fourteenth Amendment claims fail because there is no Pennsylvania constitutional right to privacy in home addresses, citing Commonwealth v. Duncan.
Ultimately, the petition was dismissed with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are OOR and Mutchler proper parties?	Marin asserts the OOR and Mutchler should resolve the privacy/petition issues.	OOR and Mutchler have no role in administering the Election Code or certifying candidates.	Yes; they are not proper parties; demurrer sustained.
Does Marin have standing to challenge the Election Code?	Marin asserts his rights as a prospective candidate and citizen.	Marin lacks averred Commonwealth citizenship/standing under the Election Code.	No; Marin lacks standing.
Do Marin's First/Fourteenth Amendment claims implicate protected rights?	Privacy in home address protects constitutional rights to avoid disclosure.	There is no Pennsylvania constitutional right to privacy in home addresses.	No protected right; claims fail.

Commonwealth v. Duncan, 572 Pa. 438 (2003) (no constitutional right to privacy in home addresses under PA Constitution; disclosure often required)
Warminster Fiberglass Co., Inc. v. Upper Southampton Township, 939 A.2d 441 (Pa. Cmwlth. 2007) (demurrer standard; accept facts but not conclusions of law; clear legal basis for retention/reversal)