Foster Camp Files Election Complaint Against Ayala

Mary-Jane Foster’s Campaign Manager Jason Bartlett has filed a complaint with the State Elections Enforcement Commission against Democratic Registrar of Voters Santa Ayala for her refusal to certify Foster for a September 13 Democratic primary for mayor. See complaint:

This complaint is regarding the Bridgeport’s Democratic Registrar of Voters, Santa I. Ayala, refusal to certify the primary petitions filed by Mary-Jane Foster to appear on the primary ballot scheduled for September 13, 2109 as a primary candidate for the office of Mayor of the City of Bridgeport. Despite the fact that 248 pages of primary petitions containing in excess of 3500 Democratic signatures were timely filed with the Democratic Registrar by Mary-Jane Foster’s campaign, Santa I. Ayala has refused to certify the signatures and has rejected the petitions. As a result Santa I. Ayala has stopped Mary Jane Foster from appearing on a primary ballot challenging the endorsed candidate for mayor. As set forth below, Santa I. Ayala’s actions are contrary to law and in violation Mary-Jane Foster’s constitutional rights. Moreover, Santa I. Ayala’s refusal is based upon a technical claim that she has admitted that she knew existed when she issued the petitions, but failed to advise Mary-Jane Foster campaign. Such failure to advise the campaign of a technical defect in the petitions that Santa I. Ayala issued is both negligent and deceptive and is contrary to her duties as Registrar of Voters.


1. Mary-Jane Foster is an announced candidate for mayor of the City of Bridgeport.

2. On or about July 28, 2011, Jason Bartlett, the campaign manager for the Mary-Jane Foster campaign, requested from Santa I. Ayala, as the Democratic Registrar of Voters for the City of Bridgeport, petitions for a slate of candidates, including Mary-Jane Foster as candidate for Mayor of the City of Bridgeport, two City Sheriffs, a Town Clerk, a City Clerk, and four individuals as candidates for the Board of Education.

3. Santa I. Ayala was informed verbally by Jason Bartlett that the application for the petition included a Board of Education slate of candidates.

4. Santa I. Ayala indicated that Secretary of the State advised her that there is no Bridgeport Board of Education.

5. Jason Bartlett asked for this in writing and Santa I. Ayala indicated that she would obtain a written ruling from the Secretary of the State’s office.

6. Notwithstanding the matter of the Board of Education’s existence, Jason Bartlett submitted an application for a slate of candidates for Mary-Jane Foster and asked Santa I. Ayala to review the application and to offer guidance as to whether it was acceptable. Jason Bartlett indicated the campaign’s willingness to revise the application if needed.

7. Santa I. Ayala took some time to review the application and indicated it was acceptable.

8. After seeking consultation from others, Santa I. Ayala agreed to include the names of the candidates for the Bridgeport Board of Education on the petitions and prepared the petitions for the Mary-Jane Foster slate.

9. Initially, Santa I. Ayala issued the primary petitions with only three candidates on the petition for the Board of Education.

10. After Jason Bartlett left the Registrar’s office and returned to the campaign headquarters, he realized that one of the Board of Education candidates was left off the petition. Jason Bartlett called Santa I. Ayala and asked why only three candidates appeared on the petition.

11. Santa I. Ayala indicated that it was a clerical error and immediately went to her office to prepare new petitions with all four Board of Education candidates on the petitions. Santa I. Ayala then called Mr. Bartlett back and asked that he return all copies of the petition with the three Board of Education candidates listed. The campaign staff returned all the petitions, except for one, as requested and picked up the corrected petition with the four Board of Education candidates listed.

12. The Mary-Jane Foster campaign began collecting signatures on the petitions on or about July 29, 2011.

13. On or about August 5, 2011, a representative of Mary-Jane Foster attempted to speak with Santa I. Ayala and attempted to deliver a letter asking whether the Registrar would accept properly signed petitions for the campaign.

14. Santa I. Ayala refused to speak with Mary-Jane Foster’s campaign representative on advice of counsel, as the Registrar was a party to another lawsuit involving candidates on the Foster petitions. See footnote 2 above.

15. On or before August 10, 2011, the Mary-Jane Foster campaign filed with the Democratic Registrar of Voters office 248 pages of primary petitions containing in excess of 3,500 Democratic signatures supporting the candidacy of Mary-Jane Foster.

16. Santa I. Ayala confirmed that only 2,110 signatures were needed to qualify Mary-Jane Foster as a primary candidate. Moreover, Santa I. Ayala stated that she validated 2,374 signatures and that “[i]t would appear that [the Foster petitions] have sufficient signatures to run a primary for September, 13, 2011.”

17. Pursuant to Conn. Gen. Stat. § 9-412, the Registrar of Voters is required to certify the signatures on said petitions within seven days of receipt of the petitions.

18. Santa I. Ayala has failed to certify said signatures in accordance with Conn. Gen. Stat. section 9-412 in violation of her statutory duty to do so.

19. On or about August 20, 2011 (more than 10 days after the filing of the petitions), Santa I. Ayala sent a letter to the Mary-Jane Foster campaign stating that:

a. I have no choice but to reject the petitions to appear on the primary ballot submitted by the Mary-Jane Foster slate for the Democratic Primary Election scheduled to take place on September 13, 2011 … The consent forms submitted to my office and hence the petitions issued and circulated contain (4) names as proposed candidates for seats on the Bridgeport Board of Education. Pursuant to the City of Bridgeport charter, the maximum number of candidates that could be nominated by any one political party for those positions would have been (3).

20. The Bridgeport City Charter, chapter 15, provides that the Bridgeport Board of Education shall be comprised of 9 members, serving 4 year terms. Moreover, chapter 15 of the City Charter provides, in pertinent part, that only three (3) Board of Education candidates from the same party may run in the general election that is held in November. The Charter makes no reference to any primary elections.

21. In a Connecticut Post newspaper article dated August 24, 2011, Santa I. Ayala acknowledged that she knew even before the petitions were circulated that they were flawed, yet despite knowing the problem existed, she intentionally and deceptively failed to advise the Mary-Jane Foster campaign. Such failure to advise the Mary-Jane Foster campaign, when she knew the petition that she prepared was defective, is a violation of her duties as Registrar of Voters to administer a fair and impartial election process.

22. As a result of the negligent and deceptive actions of Santa I. Ayala in failing to disclose the alleged defective petitions when she issued them, Mary-Jane Foster is being deprived of her right to run for elected office.

23. Conn. Gen. Stat. §. 9-167a (b) and (c) provides the appropriate remedy in the event that a political party nominates an excessive number of candidates for boards, commissions, legislative bodies, committees or similar bodies of the state or any of its subdivisions.

24. Conn. Gen. Stat. Sec. § 9-410(a) provides that “… any one primary petition may propose as many candidates for different office or positions as there are nominations to be made, or positions to be filled.” (Emphasis added).

25. Pursuant to the Minority Representation Statute, C.G.S. §9-167(a) (1), a Board of Education membership of 9 would allow to a maximum of six (6) members from any party.

26. Irrespective of the State’s takeover of the Bridgeport Board of Education on or about July 6, 2011, there was a significant probability that at least 4 Democratic nominees would have been eligible to run for the Board of Education in the general election in November 2011 should there be a judicial finding that the State’s takeover of the Bridgeport Board of Education was improper.

27. Accordingly, the entire basis for the defendant Registrar’s rejection of the subject primary petitions–that only three (3) nominees for the Board of Education could have been placed on the general election ballot in November 2011 — was totally misplaced and clearly erroneous.

I respectfully submit this complaint to the State Elections Enforcement Commission for further investigation and action, if appropriate.


Jason Bartlett



  1. She is like Santa, once a year you have a job to do. Some preparation is required. To blatantly sabotage a candidate is unconscionable. I want to be there when she leaves in a pair of handcuffs. She did this just to float Finch’s sinking ship. She is the dance band on the Titanic, good luck.

  2. Paul Ganim, brother of DISGRACED former mayor Joseph Ganim, ought to be called before the Connecticut Bar Association’s disciplinary committee. He advised Santa Ayala as her “personal” attorney. If he advised her to reject the petitions on this flimsy technicality it would appear he was serving someone else’s interests, not his client’s.

  3. The registered voters of Bridgeport ought to file a class-action lawsuit against Santa Ayala, Mario Testa, Bill Finch, Paul Ganim, et al, for conspiring to deny us our civil rights.

    Just putting it out there.


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