The Supreme Court on Thursday blocked a self-described progressive from appearing on Ohio’s Republican primary ballot after election officials caught him publicly admitting he was running as a Republican to deceive conservative voters.
Samuel Ronan, a former Democratic state and national candidate, filed to run against GOP incumbent Rep. Mike Carey in Ohio’s 15th Congressional District. To get on the ballot, he signed a declaration of candidacy under penalty of election falsification, swearing he was a member of the Republican Party.
Court documents show Ronan was caught on social media and in interviews admitting his campaign was part of a deliberate strategy to run Democrats as Republicans in “deep red districts” to “get a foot in the door.” A Republican voter, Mark Schare, filed a formal protest with the Franklin County Board of Elections, presenting the posts and interviews as evidence.
After the election board split along party lines, Ohio Secretary of State Frank LaRose stepped in and removed Ronan from the ballot. LaRose said the move was about “the integrity of the electoral process.”
Ronan sued in federal court, claiming his First Amendment rights were violated because the state used his own public statements against him. Chief U.S. District Judge Sarah D. Morrison rejected that argument in full.
“It cannot be the case that a State must allow a candidate on a partisan ballot even if he lied about his party affiliation simply because the First Amendment is implicated,” Morrison wrote.
Morrison noted that while Ohio allows candidates to legally change their party affiliation, election officials are not required to ignore sworn declarations that directly contradict a candidate’s own public admissions. The court found the state has a “substantial interest” in preventing candidates from fraudulently claiming party membership they don’t actually hold.
Ronan had tried comparing himself to politicians like Ronald Reagan and Donald Trump, who changed parties over the course of their careers. Morrison dismissed the comparison, noting those figures changed their affiliations and stood by them. Ronan admitted his registration was a tactical deception.
After losing in district court, Ronan went to the Supreme Court on Monday asking for emergency intervention before early voting began. Justice Brett Kavanaugh referred the application to the full court. The court denied it without explanation Thursday.
Carey, the Republican incumbent Ronan was targeting, has represented Ohio’s 15th District since winning a special election in 2021. The district covers much of central and southwestern Ohio, including parts of Columbus’s suburbs, and backed Trump by double digits in both 2020 and 2024.
