Michigan Fair Elections Institute Releases PIME’s Comprehensive Analysis of SOS Rule Set 15. PIME Urges Public Participation at Dec. 12 Hearing.
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FOR IMMEDIATE RELEASE
December 8, 2025
Contact: Melanie Nivelt
248.425.8896
LANSING, Mich. — December 08, 2025 — Michigan Fair Elections Institute (MFEI) today announced the release of a groundbreaking 84-page legal analysis by Pure Integrity Michigan Elections (PIME) exposing critical flaws in the Michigan Secretary of State’s Rule Set 2025-15 ST on Election Challengers and Poll Watchers. The report details how the rules exceed statutory authority, violate constitutional protections, and systematically dismantle citizen and clerk oversight—potentially in violation of state and federal laws. Rule Set 15’s twenty (20) subrules change the way the secretary of state’s office will administer Michigan’s elections—all while Secretary Jocelyn Benson is campaigning for governor in the 2026 election.
“Michigan’s election integrity is under attack from within,” said Patrice Johnson, PIME chairperson and lead author of the analysis. “In mandating state-run training and state-controlled materials, plus vague challenger ejection standards, the secretary of state’s office is usurping control of elections from the legislature. These rules go far beyond administering the laws. They’re creating legally unauthorized mandates and weaponizing the secretary of state’s office to silence citizen and clerk oversight.”
Republican lawmakers voiced support for the findings in PIME’s report. “Secretary Benson’s administrative actions raise serious concerns about conflicts of interest and overreach,” Rep. Rachelle Smit (R-Martin) told MFEI. “These rules create a chilling effect on volunteer challengers, who are essential to fair elections.” Smit serves as House Speaker Pro Tempore and Chair of the Election Integrity Committee.
State Representative Gina Johnsen (R-Portland) agreed. “As a member of the Joint Committee on Administrative Rules, I have heard hours of testimony and first-hand accounts that people are losing trust in the election system. The integrity of our elections is too important to ignore these concerns.”
“Michigan voters deserve transparent, accountable elections, but Secretary of State Jocelyn Benson is implementing three administrative rule sets that systematically dismantle election integrity safeguards — and the Legislature cannot stop these changes,” Smit wrote in a Detroit News op-ed on November 13, 2025.
Senate Minority leader, Aric Nesbitt (R-District 20) weighed in. “Volunteer challengers have long helped ensure security and transparency in the election process. Jocelyn Benson is attempting to silence them through backdoor bureaucratic rule changes.”
Smit said, “Without robust oversight, Michigan risks repeating past irregularities that now require federal intervention and have eroded public trust.” Rep. Smit was among more than 20 legislators who signed a letter to the U.S. Department of Justice on Nov. 13, formally requesting the DOJ “deploy official election monitors and provide comprehensive oversight for Michigan’s 2026 primary and general elections.”
PIME’s report cited potential First Amendment infringements on free speech and the right of association, conflicts with Michigan Election Law (MCL 168.727-734) and breaches of the federal Administrative Procedure Act (APA). The Michigan Administrative Procedures Act, codified in MCL 24.201 through MCL 24.326, establishes mandatory procedures for state agencies promulgating rules.
Rule Set 15 must not be viewed in isolation, due to the integral role it plays in a coordinated three-stage attack on election oversight. Rule Set 15, together with Rule Sets 13 and 14, will eliminate meaningful election oversight at every phase of the electoral process.
Rather than good-faith election administration in response to documented problems, this coordinated pattern suggests weaponization of administrative power implemented while the Secretary campaigns for Governor. The systematic nature across all three stages (before, during, after) suggests a deliberate strategy to eliminate accountability mechanisms at every phase of the electoral process:
Stage | Rule Set | How Oversight Is Eliminated | Status |
Before Election | Rule 13: Voter Registration Cancellation, Challenge, and Correction | Cannot challenge ineligible voter registrations. $2,300 fees per challenge. Impossible “personal knowledge” standards. Illegal protected class for overseas voters. | Pending |
During Election | Rule 15: Election Challengers and Poll Watchers | Cannot effectively observe or challenge voting. Mandatory state training barriers. Liaison gatekeeping. Restricted challenge grounds. Vague and legally unauthorized ejection/expulsion standards. | Pending |
After Election | Rule 14: Use of Electronic Pollbook | Cannot investigate or audit. Critical records destroyed after 7 days, violating 52 USC 20701‘s 22-month requirement. | Effective Oct 23, 2025 |
The report also cites potential breaches of federal statutes like the National Voter
Registration Act (NVRA) and Help America Vote Act (HAVA).
In follow up to its report, PIME is urging Michigan residents to attend the public hearing on Rule Set 15 scheduled for December 12, 2025, at 10:00 AM at the Bureau of Elections offices in Lansing. Written comments are due by 5:00 PM that day. The analysis is available in Michigan Fair Elections free public library at https://www.mifairelections.org/library. PIME is calling for immediate withdrawal of the rules, and it is requesting federal intervention and judicial review.
Michigan Fair Elections Institute (MFEI) and Pure Integrity Michigan Elections (PIME) are affiliated sister organizations. Both are nonpartisan nonprofit organizations dedicated to the one mission: To restore transparent, secure, and fair elections in Michigan. MFEI is a charitable educational organization, IRS 501(c)(3). PIME is a community organizing a 501(c)(4).
For more information or interviews, contact: Melanie Nivelt, 248.425.8896, Email: Melanierepresents@gmail.com
