Ohio Supreme Court keeps Stidham and Manning on November ballot
The Supreme Court of Ohio denied two challenges to Republican candidates’ ballot placements, leaving Caleb Stidham in the Ohio House District 89 race and Nathan Manning on the ballot for an unexpired Ninth District Court of Appeals term. The rulings concern those two candidacies ahead of the Nov. 3, 2026, general election.
The court decided State ex rel. Koebel v. Erie County Board of Elections on Oct. 8 and announced it the next day. In State ex rel. Derrig v. LaRose, it issued its decision Oct. 9. Both cases were original actions seeking writs of mandamus, a remedy the court denied in each.
Stidham challenge rejected over delay
Stidham became the Republican replacement nominee for House District 89 after D.J. Swearingen, who won the party primary, withdrew. The party district committee selected Stidham at a meeting held behind closed doors on Aug. 10, 2026. The Erie County Board of Elections split 2-2 on whether to certify him, and Secretary of State Frank LaRose broke the tie in Stidham’s favor on Aug. 20.
Carl Koebel, an elector in the district, filed his challenge on Sept. 14, 25 days after LaRose’s decision. Koebel argued that the committee’s closed meeting violated Ohio’s Open Meetings Act and asked the court to remove Stidham or require an investigation.
The court denied Koebel’s request under the legal doctrine of laches, finding that he had waited unreasonably and that the delay prejudiced election officials. Its opinion noted that Erie County had sent 33 overseas and absent-uniformed-services ballots on Sept. 18 and relied on election-administration timing in assessing prejudice.
The controlling opinion did not decide whether the Open Meetings Act required the party committee meeting to be open. Chief Justice Sharon Kennedy separately said she would conclude that the statute governing replacement nominations did not require an open meeting. That separate view was not the court’s controlling resolution of Koebel’s claim.
Manning’s earlier nomination did not bar selection
Manning had won the Republican primary nomination for Ohio House District 52, then withdrew from that race. A Republican district committee later selected him as its candidate for an unexpired Ninth District appellate-court term. Manning was serving as an appointed judge until a successor is elected.
The Summit County Board of Elections split 2-2 over whether to remove Manning from the appellate-court ballot, and LaRose broke the tie in Manning’s favor. Mark Derrig challenged that placement, arguing that Ohio Revised Code 3513.31(I) barred the selection because Manning had already been nominated for a different office.
The court rejected Derrig’s interpretation, holding that Manning’s earlier nomination for state representative did not prevent the party committee from selecting him for the remaining appellate-court term. It denied the writ on the statutory merits. The two decisions leave both candidates on the ballot for Ohio’s Nov. 3, 2026, general election; they do not establish a general rule validating all party replacement nominations.
The opinions also included differing views on standing. Justice Patrick DeWine, joined by Justices Joseph Deters and Daniel Hawkins, would have denied relief because they considered the challengers to lack standing. Other justices disagreed with that position.
Sources
- State ex rel. Koebel v. Erie Cty. Bd. of Elections, Slip Opinion No. 2026-Ohio-3999, Supreme Court of Ohio
- State ex rel. Derrig v. LaRose, Slip Opinion No. 2026-Ohio-3989, Supreme Court of Ohio
- Candidates for Appeals Court, State Representative Can Remain on Ballot, Court News Ohio, Supreme Court of Ohio Office of Public Information
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