>https://www.courtlistener.com/docket/71644146/halvorsen-v-cox/
Introduction
This action targets a racketeering enterprise within Utah, orchestrated by
Defendants, including Gov. Spencer Cox and Lt. Gov. Deidre Henderson, to manipulate Utah’s election laws from 2016 to 2024 by unlawfully certifying candidates who sought nomination through signature-gathering under Utah Code § 20A-9-408, despite URP bylaws prohibiting this method and mandating the delegate-driven convention process under § 20A-9-407, as permitted
by § 20A-9-403(13)(c)’s “either or both” provision. These certifications violated § 20A-9-401(2), which protects URP’s internal procedures, and undermined Utah’s republican form of government (U.S. Const. art. IV, § 4) by nullifying the representative delegate process (e.g., Lyman’s 67.54% vote for governor and Staggs 69.74% vote for U.S. Senate), causing financial,
reputational, and constitutional injuries actionable under18 U.S.C. § 1964 and 42 U.S.C. § § §1983, 1985, and 1986.
The enterprise’s scheme centered on the unauthorized certification of candidates,
such as Defendant Cox, who sought nomination through signature-gathering under Utah Code § 20A-9-408, despite URP bylaws prohibiting this method and mandating nominations solely through the delegate-driven convention process under § 20A-9-407, as permitted by § 20A-9 403(13)(c)’s “either or both” provision. These certifications violated § 20A-9-401(2), fraudulently misrepresenting candidate eligibility and undermining Utah’s republican form of government (U.S. Const. art. IV, § 4) by subverting the representative delegate process, causing
injuries actionable under 18 U.S.C. § 1964 and 42 U.S.C. § § §1983, 1985, and 1986.