Debbie Mayfield v. Secretary, Florida Department of State, et al.

The Florida Supreme Court granted mandamus relief compelling the Secretary of State to place Debbie Mayfield on the special election ballot for Senate District 19, holding that the Secretary's review of candidate qualifying papers is a purely ministerial function limited to facial completeness under section 99.061(7)(c) and cannot extend to assessing a candidate's constitutional eligibility—such as compliance with term limits under Article VI, Section 4. The court reaffirmed nearly a century of precedent establishing that no discretion is vested in the Secretary when a candidate meets the statutory qualification requirements, and that mandamus is the proper remedy when the Secretary refuses to perform that nondiscretionary duty. Civil and administrative practitioners should note the court's rigorous application of the ministerial/discretionary distinction and its confirmation that a clear statutory limitation on an agency's scope of review cannot be expanded by the agency through implication or interpretive assertion.

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