On October 1, the Michigan Secretary of State filed this brief in Gelineau v Ruth Johnson, the Libertarian Party ballot access case. The brief asserts in the beginning that the idea that straight-ticket votes for the Libertarian Party should be counted for the party’s presidential elector candidates is completely unprecedented, but makes no further arguments against the idea. One can observe that Michigan’s action, barring a presidential candidate of one party from the ballot in the basis that he or she had run in the presidential primary of another party, is also completely unprecedented and has never before happened in any state in U.S. history.