The Central Argument of this brief :
"The right of local community self-government is a fundamental, political right of people, a right to govern their local communities.2 It is a right held individually, and exercised collectively, by all eligible electors of a local government. As the right is fundamental, government may not infringe it. . ."
In this brief, our lawyers argue that the duties of the counties' Boards of Elections and the Secretary of State are to certify that the circulated petitions have met all the legal requirements for a citizen initiative petition--- sufficient valid signatures were collected, the petitions were assembled as require by law, and followed the required formats, etc.
Instead, the Boards of Election delved deep into the content of the actual charter proposed and critized numerous minor details, even though the Ohio Supreme Court ruled last year they had no authority to rule on the legality or constitutionality of any county charter proposed.
The brief also presents a detailed history of the rights of local self government in the formulation of our democracy.