KRISHANTI VIGNARAJAH, * IN THE

Plaintiff, * CIRCUIT COURT

v. * FOR

LARRY HOGAN FOR GOVERNOR, * ANNE ARUNDEL COUNTY

et. al.,
* Civil Action No. C-02-CV-17-002883
Defendants.

* * * * * * * * * * * *
STATE DEFENDANTS MOTION TO DISMISS

Pursuant to Md. Rule 2-322(b)(2), defendants Mary Wagner and Maryland State

Board of Elections (collectively, the State Defendants or Board) move to dismiss this

action for failure to state a justiciable claim. A supporting memorandum and proposed

order are attached.

Respectfully submitted,

BRIAN E. FROSH
Attorney General of Maryland

JULIA DOYLE BERNHARDT

CPF No. 8112010024

/s/ John R. Grimm

________________________
JOHN R. GRIMM
CPF NO. 1112130385
Assistant Attorneys General
200 Saint Paul Place, 20th Floor
Baltimore, Maryland 21202
jgrimm@oag.state.md.us
(410) 576-6339
(410) 576-6955 (facsimile)

November 27, 2017 Attorneys for State Defendants

 RULE 20-201(F) CERTIFICATION

I certify that this submission does not contain any restricted information.

/s/ John R. Grimm

___________________________
John R. Grimm
 CERTIFICATE OF SERVICE

I certify that on this 27th day of November 2017, the foregoing motion and

accompanying memorandum and proposed order were served by first-class mail on the

following:

Larry Hogan for Governor

P.O. Box 6559
Annapolis, Maryland 21404

I certify that on this 27th day of November 2017, the foregoing motion and

accompanying memorandum and proposed order was served electronically by the MDEC

system on, the following:

Andrew D. Herman, Esquire

(Pro hac vice admission pending)
Adam W. Braskich, Esquire
MILLER & CHEVALIER CHARTERED
900 Sixteenth Street, N.W.
Washington, D.C. 20006
aherman@milchev.com
abraskich@milchev.com

Phil Spector, Esquire

MESSING & SPECTOR LLP
1200 Steuart Street, Number 2112
Baltimore, Maryland 21230
ps@messingspector.com

/s/ John R. Grimm

________________________
John R. Grimm
KRISHANTI VIGNARAJAH, * IN THE

Plaintiff, * CIRCUIT COURT

v. * FOR

LARRY HOGAN FOR GOVERNOR, * ANNE ARUNDEL COUNTY

et. al.,
* Civil Action No. C-02-CV-17-002883
Defendants.

* * * * * * * * * * * *
MEMORANDUM IN SUPPORT OF STATE DEFENDANTS
MOTION TO DISMISS

Pursuant to Md. Rule 2-322(b)(2), defendants Mary Wagner and Maryland State

Board of Elections (collectively, the State Defendants or Board), move to dismiss this

action for failure to state a justiciable claim. At this juncture, the Board takes no position

on the merits of plaintiff Krishanti Vignarajahs claim that she is qualified to run for

Governor. But because Ms. Vignarajah does not allege that she is officially a candidate

for Governor, much less that anyone has brought a legal challenge to her candidacy, this

case is not ripe for judicial review.

STANDARD

Dismissal under Rule 2-322(b)(2) is appropriate whenassuming their truththe

facts and all reasonable inferences that can be drawn from those facts fail to afford relief

to the plaintiff, Bobo v. State, 346 Md. 706, 708-09 (1997), including when the complaint

fails to allege a justiciable controversy. 120 W. Fayette St., LLLP v. Baltimore, 413 Md.

309, 356 (2010) (When a complaint fails to allege a justiciable controversy . . . a motion
to dismiss is proper.); Lewis v. Long & Foster Real Estate, Inc., 85 Md. App. 754, 758

(1991) (noting that a Rule 2-322 motion is appropriate when no justiciable controversy

exists).

A declaratory action based on facts that have yet to occur or develop, like this

one, lacks ripeness and should be dismissed for failure to allege a justiciable controversy.

120 W. Fayette St., 413 Md. at 356. The existence of a justiciable controversy is an

absolute prerequisite to the maintenance of a declaratory judgment action. Id. (citing

Boyds Civic Assn v. Montgomery County Council, 309 Md. 683, 689 (1987)) (emphasis

added); see also State v. G&C Gulf, Inc., 442 Md. 716, 720 (2015) (An action for

declaratory judgment is not treated differently than any other suit for purposes of

ripeness.).

ARGUMENT

This declaratory-judgment action asks the Court to resolve a dispute that does not

exist and that may never arise. Ms. Vignarajah alleges that her political opponents and

others have questioned whether she meets both the voter-registration and residency

requirements to run for Governor. But setting aside the fact that Ms. Vignarajah has not

yet filed a certificate of candidacy1which is a prerequisite to running for office,2

1
(See Compl. 16.) As of this filing, it remains true that Ms. Vignarajah has not
filed her certificate of candidacy.
2
Md. Code Ann., Elec. Law 5-301(a)(1)(2).

2
regardless of whether she meets the other qualifications3her complaint does not establish

a credible risk that her opponents, the Board, or anyone else will attempt to bar her from

running for Governor by challenging her qualifications. First, Ms. Vignarajah appears to

allege, as a legal matter, that no one can currently challenge her status as a registered

Maryland voter since 2006. Second, Ms. Vignarajah overlooks that the statute provides an

exclusive means for challenging her residency: a particular court proceeding which she

does not allege is imminent or even likely.

At this stage, Ms. Vignarajahs theory of injury is entirely speculativecontingent

on a chain of events that have not occurred and may never occur. This case is thus a prime

example of an unripe declaratory judgment action filed in anticipation of an event which

may never happen[.] 120 W. Fayette St., 413 Md. at 357. The Court should dismiss this

action as unripe.

I. MS. VIGNARAJAH DOES NOT ALLEGE THAT ANYONE WILL CHALLENGE

HER STATUS AS A REGISTERED MARYLAND VOTER.

Although Ms. Vignarajah alleges that some commenters have questioned whether

she has been a registered Maryland voter for five years (Compl. 26), she does not show

that those questions require judicial resolution.

3
Article II, 5 of the Maryland Constitution provides as follows: A person to be
eligible for the office of Governor or Lieutenant Governor must have attained the age of
thirty years, and must have been a resident and registered voter of the State for five years
next immediately preceding his election. Ms. Vignarajah does not allege that the age
requirement to run for Governor is at issue.

3
 A. Ms. Vignarajah Does Not Allege How Her Voter-Registration Status
Presents a Justiciable Question.

Ms. Vignarajahs own formulation of the issue fatally undermines her argument that

her voter-registration status is under threat. Specifically, Ms. Vignarajah alleges that she

has been registered to vote in Maryland continuously since 2006. And that, she argues, is

all the Constitution requires. (See Compl. 4, 8, 9; Affidavit of Krishanti Vignarajah

16; Exhibit 1.) Because she admits that she is now an active registered voter (Compl.

9), and does not suggest that there is any effort to retroactively remove her from the voter

rolls, she fails to articulate any theory by which her opponents could keep her off the ballot

by challenging her voter registration, and thus any question for the Court to resolve.

Indeed, Ms. Vignarajah appears to treat it as an immutable fact that she satisfies the

voter-registration requirement: she argues that neither Hogan nor Wagner can lawfully

change the fact that she has been a continuously registered voter in Maryland since

2006. (Compl. 71.) Because Ms. Vignarajahs complaint does not even suggest that

her voter registration presents a live issue, any theoretical challenge to her candidacy on

that basis is the epitome of an event that may never happen. This falls far short of the

likeliness required to state a justiciable claim.

B. Media Statements By Ms. Wagner Do Not Create a Justiciable

Controversy.

It is undisputed that the Board has not taken any official action regarding

Ms. Vignarajahs voter registration or announced any intention to do so. Nevertheless, Ms.

4
Vignarajah devotes considerable attention to two vague statements, attributed to defendant

Mary Wagner in the Washington Post, suggesting that the Board would have canceled

Vignarajahs voter registration in Maryland if it had been notified that Vignarajah

registered to vote in Washington, D.C. (Compl. 30). But Ms. Vignarajah cannot create

a justiciable controversy by alleging that the Board would have violated the law if it had

done something it did not do, especially when there is no present suggestion that her voter

registration will be challenged.

Ms. Vignarajah admits, as she must, that the Board did not remove her from the

voter rolls and, in fact, argues that the Board followed the law in not doing so. (Compl.

8.) The non-specific newspaper clippings on which Ms. Vignarajah relies do not and

cannot constitute any official action by the Board, and are not probative of any intent

past or futureby the Board to strike Ms. Vignarajah from the voter rolls. For one thing,

the articles do not even directly quote Ms. Wagner; instead, they both contain the statement

that Ms. Wagner said that the Board would have canceled Vignarajahs voter

registration if D.C. officials had notified the state that she was registered to vote in the

District of Columbia.4 See Josh Hicks, Krishanti Vignarajah Launches Campaign for

Maryland Governor, Wash. Post, Sept. 19, 2017, attached hereto as Exhibit A; Ovetta

4
Ms. Vignarajah does not appear to dispute that moving out-of-state can lead to
removal from the statewide voter registration, if the proper procedures are followed. See
Md. Code Ann., Elec. Law Title 3, subtitle 5. Nothing about the press statements attributed
to Ms. Wagner suggests that the Board would have removed Ms. Vignarajah from the voter
rolls without following the applicable procedures.

5
Wiggins & Josh Hicks, Md. Attorney General Is Asked to Opine on Ex-White House Aides

Eligibility to Run for Governor, Wash. Post, Aug. 11, 2017, attached hereto as Exhibit B.

The articles provide no context for Ms. Wagners alleged statement, no indication of her

actual words, no evidence that the authors were accurately paraphrasing her, and no

indication that Ms. Wagners statements reflected the views of the Board. They therefore

do not demonstrate there will be any challenge to Ms. Vignarajahs status as a registered

Maryland voter. There is thus no basis for the Court to conclude that there is, or will be

any challenge to Ms. Vignarajahs satisfaction of the voter-registration requirement to run

for Governor.

II. NO ONE HAS FORMALLY CHALLENGED MS. VIGNARAJAHS MARYLAND

RESIDENCY.

As with the voter-registration requirement, Ms. Vignarajah does not allege that any

actual challenge to her Maryland residency has occurred, or show that one is likely to occur.

Although Ms. Vignarajah points out both that her opponents have questioned her

eligibility, and that the Board has sought legal advice on that question, she has not alleged

that a legal challenge to her candidacy is imminent, or even likely. Without one, there is

nothing for the Court to decide.

A. Ms. Vignarajah Has Not Alleged That There Is Any Legal Threat
to Her Candidacy.

Although Ms. Vignarajah claims that some people have questioned whether she

meets the residency requirements to run for Governor, and makes the speculative and

6
conclusory allegation that litigation is inevitable (Compl. 75.b), she does not allege any

facts showing that a formal challenge to her qualificationsthe kind that could prevent her

from runninghas occurred, or will occur. Maryland law provides a specific, and narrow,

mechanism to challenge whether a candidate meets the residency requirements to run for

office. See Md. Code Ann., Elec. Law 5-305. Under 5-305, a challenge to a candidates

residency can only be brought by filing a special petition within nine days after a candidate

files her certificate of candidacy.

Ms. Vignarajah alleges only that some people have challenged her qualifications

in the press, not in the courts. But media speculation about Ms. Vignarajahs qualifications

has no effect on her legal ability to run for office, because only a proceeding under 5-305

can actually force her off the ballot on the basis of her residency.5 Ms. Vignarajahs

complaint does not allege that any challenge has been brought, or that there is a credible

risk that one will be brought.6 Even if there is a risk that her political opponents might one

day challenge her candidacy in court, at this point, it is just thata risk. But the mere

possibility of future legal action does not satisfy the ripeness requirements for a

declaratory-judgment action.

5
When a statute provides for a special remedy in a specific type of caselike
5-305 doesthat remedy shall be followed in lieu of a declaratory-judgment action.
Md. Code Ann., Cts. & Jud. Proc. 3-409(b).
6
Indeed, under the statutory scheme, any action to decide Ms. Vignarajahs
qualifications would be premature at least until she files her certificate of candidacy.

7
 The Court of Appeals addressed an analogous situation in G&C Gulf, when it held

that a challenge to a criminal law was not ripe unless there was an actual prosecution under

the statuteor a credible threat of oneagainst the specific party challenging the law. 442

Md. at 731. The statute challenged in G&C Gulf criminalized certain predatory towing

practices. Id. at 719-20. A towing company, whose owner believed the company was in

jeopardy of being prosecuted under the act, sought a declaratory judgment that the statute

was illegal. Id. at 722-24. Even though counsel for Montgomery County stated that the

County was enforcing the law generally, id. at 734-35, the Court of Appeals held that the

challenge was not ripe because the plaintiff was not actually being prosecuted, or subject

to a credible threat of prosecution. Id. at 731 (A litigant must allege and prove that they

have been prosecuted for a crime or that there is a credible threat of prosecution under a

contested statute in order for the issue to constitute a justiciable controversy.).

Here, the mere possibility that someone could challenge Ms. Vignarajahs

qualifications is too speculative to give rise to a justiciable declaratory-judgment action.

Even if Ms. Vignarajah does file a certificate of candidacy, as she alleges she will, there is

far from a credible threat that anyone will file an action challenging her candidacy. See

Pearson v. Leavitt, 189 F. Appx 161, 164 (4th Cir. 2006) (per curiam) (finding

declaratory-judgment action non-justiciable where Appellees have neither threatened nor

taken action against Appellants). Political rhetoric questioning her qualifications (which

costs nothing) is one thing; marshaling the arguments and bearing the expense necessary

8
to mount a colorable challenge in courta challenge Ms. Vignarajah appears confident

cannot succeedis another.7 It is entirely speculative whether Ms. Vignarajahs opponents

are prepared to expend the effort necessary to litigate her qualifications, especially

considering that they will presumably be busy running campaigns against other political

opponents simultaneously.8

Only a court challenge can potentially defeat Ms. Vignarajahs candidacy on the

basis of her residency, and it is purely speculative whether one ever will be brought.

Without any credible likelihood of such an action, this lawsuit is unripe.

B. The Boards Decision to Seek Legal Advice on Ms. Vignarajahs

Residency Has No Bearing on Her Ability to Run for Office.

Finally, Ms. Vignarajah suggests that the Board itself believes her residency is an

issue, because it has sought advice from the Attorney General, and because Ms. Wagner

wrote in an email that it looks like the 5 year residence requirement is going to be an issue

for the upcoming election[.] (Compl. 31, 32.) These actions do not and cannot

constitute a challenge to Ms. Vignarajahs candidacy, because the Board does not make

7
Ms. Vignarajah offers the conclusory statement that judicial resolution . . . is
imminent and inevitable at the request of one candidate or another, (Compl. 15), and a
bald allusion to imminent and inevitable litigation. (Compl. 75.b) But the complaint
does not allege any facts showing that a legal challenge to Ms. Vignarajahs candidacy is
actually forthcoming or likely, as opposed to merely possible.
8
Other than Ms. Vignarajah, there are at least seven other potential Democratic
candidates for the 2018 gubernatorial election. See Maryland Governor Candidates 2018,
Baltimore Sun, available at http://www.baltimoresun.com/news/maryland/politics/bal-
maryland-governor-candidates-2018-20170612-storygallery.html.

9
determinations about candidates eligibility but only verifies that their certificates of

candidacy facially comply with statutory requirements.

Under Maryland election law, the Board shall accept Ms. Vignarajahs certificate

of candidacy as long as she swears under oath that she meets the qualifications for office.

Elec. Law 5-304(e) (providing that the Board shall accept a certificatenot a

candidacythat complies with the law); 5-304(c)(5) (requiring a candidate to state that

she satisfies requirements for candidacy); 5-302(a) (requiring a certificate of candidacy to

be filed under oath). In other words, once Ms. Vignarajah self-certifies that she is eligible

to run for Governor, the Board is not empowered to second-guess that conclusion, or to

conduct an independent evaluation of Ms. Vignarajahs eligibility.9 The only avenue for

challenging Ms. Vignarajahs determination that she is qualified to run for office is a court

proceeding.

The Boards limited role in reviewing candidates qualifications has a long tradition

in Maryland. The Court of Appeals has held that a board of elections is not empowered to

adjudicate whether a candidate is qualified to run for office, as long as her certificate of

candidacy appears proper. Indeed, after examining the certificate of candidacy and

determining that on its face it [is] complete and in order, the Board is under a ministerial

duty to accept said certificate and [has] neither a discretionary power to reject it, nor any

9
Although the Board is authorized to request supporting information to verify the
accuracy of information in a certificate of candidacy, Elec. Law 5-304(c)(6), it does not
independently investigate whether that information is accurate.

10
authority to exercise the judicial function of passing upon the qualifications of the

candidate. Gallagher v. Board of Supervisors of Elections, 219 Md. 192, 208 (1959); see

also Tawney v. Board of Supervisors of Elections of Balt. City, 198 Md. 120 (1951)

(collecting cases). And over thirty years ago, the Attorney Generals Office concluded that

election officials exercise relatively limited authority in determining candidates

qualifications, and that the authority they do exercise is a ministerial function. See

Letter from Assistant Attorney General Jack Schwartz, Chief Counsel, Opinions and

Advice, to Del. Robert H. Kittleman (July 2, 1987), at 1, attached hereto as Exhibit C. In

particular, election officials lack authority to determine other potential questions about

qualifications, and are specifically not empowered to act as an adjudicator . . . [of a]

challenge to the representation by a candidate . . . that he or she has been a citizen of

Maryland for at least five years preceding the election. Id. at 2.

Under governing law, the Board lacks the authority to determine Ms. Vignarajahs

Maryland residency, and the fact that it sought legal advice on certain dimensions of this

question does not mean that there is an imminent risk that the Board will reject Ms.

Vignarajahs candidacy. Because Ms. Vignarajahs complaint does not allege facts that

show any credible threat of a legal challenge to Ms. Vignarajahs candidacy, it does not

justify a judicial declaration about her eligibility.

11
 CONCLUSION

The motion to dismiss should be granted, and the Court should dismiss the

complaint as unripe.

Respectfully submitted,

BRIAN E. FROSH
Attorney General of Maryland

JULIA DOYLE BERNHARDT

CPF No. 8112010024

/s/ John R. Grimm

___________________________
JOHN R. GRIMM
CPF No. 1112130385
Assistant Attorneys General
200 Saint Paul Place, 20th Floor
Baltimore, Maryland 21202
jgrimm@oag.state.md.us
(410) 576-6339
(410) 576-6955 (facsimile)

Attorneys for State Defendants

12
KRISHANTI VIGNARAJAH, * IN THE

Plaintiff, * CIRCUIT COURT

v. * FOR

LARRY HOGAN FOR GOVERNOR, * ANNE ARUNDEL COUNTY

et. al.,
* Civil Action No. C-02-CV-17-002883
Defendants.

* * * * * * * * * * * *
ORDER

Upon consideration of the State Defendants Motion to Dismiss, and any

responses and replies thereto, it is this ____ day of _____________, 201_, by the Circuit

Court for Anne Arundel County, hereby

ORDERED that the motion is GRANTED; and it is further

ORDERED that this matter is DISMISSED WITHOUT PREJUDICE.

________________________
Judge
EXHIBIT A
 Maryland Politics

Krishanti Vignarajah
launches campaign for
Maryland governor
By Josh Hicks September 19

WOODLAWN, Md. Democrat Krishanti Vignarajah, a former policy director for first lady Michelle Obama, officially
launched her campaign for governor Tuesday at the apartment complex outside Baltimore where she lived with her parents
after the family fled Sri Lanka decades ago.

Before anything else, I was an immigrant and proud daughter of schoolteachers, she told an audience of about three dozen,
including her husband, National Wildlife Federation chief executive Collin OMara, and their infant daughter.

She said as governor she would push for mandatory paid family leave for new mothers and fathers and for universal
prekindergarten and make education her top priority.

Vignarajah, 37, has said she is driven to run partly by the retirement early this year of U.S. Sen. Barbara A. Mikulski (D-Md.),
which left all statewide elected offices in Maryland filled by men for the first time in many years.

A graduate of Yale University and Yale Law School, Vignarajah lives in Gaithersburg and worked for Michelle Obama for a
little more than two years after a stint as a senior adviser at the State Department. She previously worked at a New York-based
consulting firm and a Chicago-based law firm and has taught at Georgetown University.

Vignarajah, who was nine months old when her family immigrated to the United States with green cards, announced last
month that she would join the packed field of Democrats vying to challenge the popular incumbent, Gov. Larry Hogan (R), in
2018.

Other declared candidates include Prince Georges County Executive Rushern L. Baker III, former NAACP president Ben
Jealous, Baltimore County Executive Kevin Kamenetz, state Sen. Richard S. Madaleno Jr. (D-Montgomery), entrepreneur Alec
Ross and Baltimore lawyer and former University System of Maryland Board of Regents chair James L. Shea. Policy
consultant Maya Rockeymoore is also weighing a bid.

They say no man can beat Governor Hogan, she said during her announcement. Well, Im no man.
Shortly after Vignarajah said she would run, one of her potential rivals, on the condition of anonymity, raised questions to
news organizations including The Washington Post about her voter registration. A review of records by The Post showed she
was registered in both Maryland and the District in recent years, had lived in both places, and voted in the District from 2010
to 2014 but in Maryland in 2016.

Maryland law requires gubernatorial candidates to have lived and been registered to vote in the state for five years
immediately preceding the election. D.C. law prohibits people from registering to vote when they are registered elsewhere.

The Maryland State Board of Elections has asked Attorney General Brian E. Frosh (D) to weigh in on whether a person who
registered in the state but later voted in another jurisdiction would be considered a registered Maryland voter.

Mary Wagner, voter-registration director for the elections board, said the attorney generals office is unlikely to provide an
answer before Vignarajah files paperwork with the state to enter the race. The filing deadline for the June primary is Feb. 27.

Wagner said the board would have canceled Vignarajahs voter registration if D.C. officials had notified the state that she was
also registered in the District.

Vignarajah did not take questions Tuesday and declined to comment on her eligibility for office.

Read more Maryland politics:

Oops! That measure to let noncitizens vote in College Park actually failed

Emilys List targets Hogan in Md. governors race

At least two Democratic candidates for governor seek progressive mantle

10 Comments

Josh Hicks covers Maryland politics and government. He previously anchored the Posts Federal Eye blog,
focusing on federal accountability and workforce issues. Follow @reporter_hicks
EXHIBIT B
 Maryland Politics

Md. attorney general is asked

to opine on ex-White House
aides eligibility to run for
governor
By Ovetta Wiggins and Josh Hicks August 11

The Maryland State Board of Elections on Friday asked Attorney General Brian E. Frosh (D) to weigh in on whether Krishanti
Vignarajah, a former policy aide for Michelle Obama who entered the governors race this week, is a Maryland registered
voter, which is a requirement for running for governor.

Shortly after Vignarajahs announced her candidacy on Wednesday, questions were raised about whether she is legally eligible
to seek the office. Under the state constitution, a candidate for governor must be at least 30 years old and have been both a
Maryland resident and registered voter for the five years immediately preceding the election.

Vignarajah registered to vote in the District in 2010 and has voted there multiple times, including during the 2010, 2011, 2012
and 2014 election cycles.

According to the Maryland State Board of Elections, Vignarajah also is registered to vote in Maryland. She has voted once in
the state in the 2016 general election since she registered in 2006.

State records show that the Baltimore County Board of Elections sent a request to Vignarajahs Catonsville address in
February 2015 asking her to confirm her registration status. Because she did not reply, she was listed as inactive. If she had
not voted last year, the state would have canceled her registration after the 2020 election.

Vignarajah, 37, did not return a call late Friday seeking comment about the request from the State Board of Elections. Steve
Rabin, a spokesman for her campaign, also did not return a call for comment.

I am legally eligible to run, Vignarajah said earlier in the day on the Kojo Nmandi radio show on WAMU-FM (88.5).
The request from the state board does not mention Vignarajah by name. Instead, it seeks advice on whether a person who
registered in the state but later voted in another jurisdiction would be considered a Maryland registered voter.

The answer could determine whether Vignarajah, the only woman in a crowded field of Democratic candidates, can remain in
the race.

Mary Wagner, voter registration director for the state board, said Friday that the board would have canceled Vignarajahs
voter registration if D.C. officials had notified the state that she had registered to vote in the District.

During the radio interview, Vignarajah refused to say why she registered to vote in the District while also registered in
Maryland.

She said that she had a crash pad in the District while she was working in the Obama administration but that Maryland was
her primary residence.

When Vignarajah was told that she may have violated D.C. law and could be subject to a $10,000 fine for registering in the
District while being registered in another jurisdiction, she said: I think we need to focus on what Im here to talk about, that
is Im running for governor of Maryland. In terms of the requirements to run, I have been a registered voter in Maryland for
far longer than is required to run.

Vignarajah repeated that she was absolutely legally eligible to run for governor.

She said that she consulted legal experts and elected officials to make sure I wasnt throwing my hat in the ring for no good
reason.

The D.C. voter registration form requires applicants to declare their eligibility, including by checking a box and signing their
names to a statement that they do not claim voting residence outside of the District of Columbia. The D.C. Board of
Elections website also notes that registered voters must not claim the right to vote in any other state or territory.

20 Comments

Ovetta Wiggins covers Maryland state politics in Annapolis. Follow @OvettaWashPost

Josh Hicks covers Maryland politics and government. He previously anchored the Posts Federal Eye blog, focusing
on federal accountability and workforce issues. Follow @reporter_hicks
EXHIBIT C
Record Extract
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