State ex rel. Conrath v. LaRose, 2022 Ohio 3594

Background

The Ohio House legislative primary was held August 2, 2022 (moved from May by federal-court order). Rhyan Goodman ran unopposed in the Democratic primary for House District 94.
Goodman informed the Athens County Board of Elections on August 8 that he wished to be removed from the November ballot; the primary result could not be certified until August 13–23.
A Democratic district committee timely (August 15) certified Tanya Conrath as the party’s replacement nominee; Conrath accepted.
The primary result was officially certified on August 19. The Athens County board split on certifying Conrath; Secretary of State LaRose broke the tie on September 13 by voting not to certify her.
Conrath filed for a writ of mandamus to compel respondents to place her name on the November 8, 2022 general-election ballot; the Ohio Supreme Court granted the writ, finding respondents acted in clear disregard of controlling law.

Issues

Issue	Plaintiff's Argument (Conrath)	Defendant's Argument (LaRose/Athens Bd.)	Held
Whether a district committee may fill a party-nomination vacancy when the primary winner withdrew before official certification	Conrath: R.C. 3513.31(B) and this court's precedent (Barth) allow anticipatory nominations so long as certified replacement is filed by deadline; committee’s August 15 nomination was timely and effective once certification occurred	LaRose: R.C. 3513.31(B) requires the withdrawing person to be a certified "party candidate" before a committee may fill the vacancy; because Goodman was not yet certified on Aug 15, the committee lacked authority	Court: Held for Conrath — Barth permits prospective nominations; timely August 15 certification of Conrath became effective when Goodman was later certified, so the committee had authority
Whether Secretary LaRose abused discretion or acted in clear disregard of law by refusing to certify Conrath	Conrath: LaRose failed to follow Barth and the statutes as construed with precedent; his interpretation produced an absurdity that thwarted R.C. 3513.31(B)’s purpose of enabling replacement nominees	LaRose: Applied plain statutory language and definition of "party candidate" (R.C. 3501.01(K)); substitution before certification is unauthorized	Court: Held LaRose acted in clear disregard of law and caselaw (Barth); his contrary interpretation created an avoidable legal absurdity
Whether mandamus is appropriate relief to place Conrath on the ballot	Conrath: Mandamus is appropriate because she has a clear legal right, respondents have a clear legal duty, and no adequate remedy exists given election timelines	Respondents: Deny duty; argue statutory prerequisites unmet and administrative discretion allowed	Court: Granted mandamus — relator established right, duty, and lack of adequate remedy; ordered respondents to place Conrath on the ballot

Key Cases Cited

State ex rel. Barth v. Hamilton Cty. Bd. of Elections, 65 Ohio St.3d 219 (permitting anticipatory party nominations)
State ex rel. Husted v. Brunner, 123 Ohio St.3d 288 (tiebreaking authority and mandamus standard in election contexts)
State ex rel. Law v. Trumbull Cty. Bd. of Elections, 157 Ohio St.3d 280 (elements for mandamus)
State ex rel. Finkbeiner v. Lucas Cty. Bd. of Elections, 122 Ohio St.3d 462 (timing/adequacy of remedies in expedited election cases)
State ex rel. Clay v. Cuyahoga Cty. Med. Examiner’s Office, 152 Ohio St.3d 163 (avoid construing statutes to produce absurd results)
State ex rel. Herman v. Klopfleisch, 72 Ohio St.3d 581 (mandamus in election-administration disputes)
State ex rel. Norman v. Viebranz, 19 Ohio St.3d 146 (prospective appointments valid unless appointing authority expires)
State v. Craig, 159 Ohio St.3d 398 (premature filings can become effective upon occurrence of the triggering event)