Ruiz v. Saez, 68 N.Y.2d 154 (1986)

The cover sheet of an election designating petition must clearly state the number of signatures for each candidate with respect to the particular office, providing sufficient notice and information to facilitate the discovery of fraud and irregularity; a single block of data for multiple candidates is insufficient.

Summary

This case addresses the requirements for data concerning signatures on election petitions, specifically focusing on the information provided on the cover sheet. The Court of Appeals held that cover sheets must clearly state the number of signatures for each candidate for each office to satisfy the statutory requirement for notice and informational purposes. The court distinguished between situations where a single individual runs for multiple offices and where multiple candidates run for different offices, finding that a joint data block is insufficient when applied to multiple candidates for different offices because it impedes the process of verifying the petitions’ validity.

Facts

Several proceedings were consolidated concerning petitions for public office and party positions on the Democratic primary ballot. In Ruiz v. Saez, cover sheets for some volumes listed data showing volume number, pages, and signatures for each candidate for Senate, Assembly, and Civil Court. However, Volume 64 listed only one block of data for the Assembly candidate and 20 other candidates. Similarly, volumes 59, 60, and 61 had a single block of data for 10 candidates for party positions. In Matter of Potter v. Dudek, a joint petition designated Burns and Dudek as candidates for County Court Judge and Family Court Judge, respectively. The cover sheet stated the petition contained