TALLAHASSEE, Fla. – The Florida Supreme Court on Thursday backed Rep. Debbie Mayfield in her bid to run in a special election for a Senate seat, ruling that state elections officials wrongly blocked her from appearing on the ballot.
The unanimous opinion said Mayfield’s candidacy in Brevard County’s Senate District 19 would not violate term limits in the state Constitution. Also, it said Secretary of State Cord Byrd overstepped his “ministerial” role of determining whether Mayfield properly qualified for the ballot.
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The opinion said the court was “confident that the secretary will promptly comply with this opinion no later than 3 p.m. on Friday.”
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Mayfield issued the following statement to News 6 Thursday evening:
“Today the Florida Supreme Court preserved democracy and will allow Brevard County voters the right to choose their next State Senator. I’m grateful that my name will be on the ballot and I will work hard to earn the support of our community. I’m committed to fighting alongside President Trump and our Republican leaders to advance the America First agenda.”
State Rep. Debbie Mayfield, R-Brevard County
The case centered on the state’s term-limits law and how it applied to Mayfield, who is trying to return to a Senate seat she left in November after serving eight years. Mayfield, R-Melbourne, was elected to the House in November but then decided to seek the Senate seat after Sen. Randy Fine, R-Brevard County, submitted his resignation to run in a special election for a congressional seat.
The state Division of Elections, which is under Byrd, said Mayfield could not run for the Senate because she would violate the eight-year term limits law if elected. But the Supreme Court’s main opinion, written by Justice Jamie Grosshans, said “we reject the Secretary’s interpretation of the governing constitutional provision.”
That part of the Constitution says, “No person may appear on the ballot for re-election” to offices such as senator “if, by the end of the current term of office, the person will have served (or, but for resignation, would have served) in that office for eight consecutive years.”
Grosshans wrote that Byrd’s interpretation “severs the phrase ‘consecutive years’ from the rest of the provision, leading him to conclude that, if successful in the upcoming election, Mayfield ‘will have served’ in SD 19 for 12 consecutive years. This interpretation fails to consider the words in context.”
“Contrary to the secretary’s position, even if Mayfield returns to the Senate, she would not have served as a senator for more than eight consecutive years, for purposes of article VI, section 4 (the part of the Constitution),” the main opinion said. “Mayfield experienced a break in service when her Senate term ended in November 2024. The conclusion of that term, after which Mayfield left the office of senator, brought an end to a period of ‘consecutive’ years of service. And if Mayfield were to win election to SD 19 in the upcoming special election, that will restart the clock on the calculation of her ‘consecutive’ years of service.”
Similarly, in a concurring opinion, Justice Charles Canady wrote that since “Mayfield has no ‘current term of office’ in the Florida Senate, section 4 does not prevent her appearance on the ballot for the Senate District 19 special election. Under the terms of section 4, Representative Mayfield’s prior service in the Florida Senate — which concluded in 2024 — is irrelevant.”
“A constitutional provision certainly could be fashioned to impose a lifetime limit on service in a particular office. … Similarly, a constitutional provision could be framed to impose a specific period of ineligibility to seek reelection after service of defined duration in a particular office has been completed. But neither sort of provision is in the (constitutional) text adopted by the people of Florida,” wrote Canady, who was joined in the concurring opinion by Justice Jorge Labarga.
Justices also said Byrd’s role in qualifying candidates is ministerial in determining such things as whether paperwork has been properly submitted. The main opinion pointed to a 1928 Supreme Court ruling, which found that the secretary of state did not have “discretion in determining whether a candidate was eligible to be placed on the ballot.”
“Consistent with that precedent, we find that the Department of State has an indisputable legal duty (ministerial in nature) to notify the (county) supervisor of elections of all candidates that have qualified pursuant to statute,” Grosshans wrote. “And a duly qualified candidate has a right to be placed on the ballot.”
Mayfield filed a petition Feb. 6 at the Supreme Court and sought emergency action because vote-by-mail ballots for the special primary election are required to start going to military and overseas voters by the end of this week. The primary is scheduled April 1.
The qualifying period for the special election ended Feb. 4. State Division of Elections Director Maria Matthews on Feb. 5 wrote a memo to Mayfield that said, “Upon review and consultation with counsel regarding your candidacy for state Senate District 19, the Division of Elections has determined that your name cannot appear on the special election ballot, as it violates article VI, section 4 of the Florida Constitution.”
In a filing this week at the Supreme Court, lawyers for Byrd and Matthews contended that Mayfield was “constitutionally ineligible” and that Byrd, the state’s chief elections officer, was not required to “suspend common sense or common knowledge” to qualify her for the ballot.
“It’s for much the same reason that the secretary can’t certify the King of England (a non-U.S. citizen) or a notorious serial killer (a convicted felon) for inclusion on a ballot with the hope that a political opponent (if there is one) will file a challenge,” the filing said.
Three other Republicans — Marcie Adkins, Mark Lightner III and Tim Thomas — and Democrat Vance Ahrens qualified to run in the Senate special election, according to the state Division of Elections website. The special general election will be held June 10.
In anticipation of running for the Senate seat, Mayfield submitted her resignation from the House, effective June 9.
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