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Griswold v. Ferrigno Warren.

2020 CO 34. No. 20SA140. Election Law.

May 4, 2020


In this expedited appeal under CRS § 1-1-113(3), the Supreme Court addressed whether the Colorado Secretary of State (the Secretary) properly declined to place Ferrigno Warren on the 2020 Democratic primary ballot for the office of US Senate after she was unable to collect 1,500 signatures in six of seven congressional districts.

The Court concluded that the district court erred when it found that Ferrigno Warren substantially complied with the minimum signature requirements outlined in CRS § 1-4-801(2)(c)(II) because she made a good faith effort to collect signatures during the outbreak of the COVID-19 pandemic. While substantial compliance is the standard for technical deficiencies in the election law context, the Election Code’s minimum-signature mandate requires strict compliance.

Because Ferrigno Warren did not meet the threshold signature requirement, the Secretary properly declined to place her on the ballot. Accordingly, the district court’s order was reversed.

Official Colorado Supreme Court proceedings can be found at the Colorado Supreme Court website.

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