Wayne County Clerk Cathy M. Garrett officially denied a campaign challenge in the Democratic primary for Michigan’s 2nd House District, in which one candidate, Frank Liberati, sought to have one of his opponents, Joanna Whaley, disqualified from the ballot over the name by which she would appear.
Specifically, Liberati claimed that Whaley, who is transgender, had violated state campaign law by not listing her deadname on her affidavit of identity submitted to run for office.
Whaley, however, did legally change her name in 2025, as she demonstrated to the county clerk’s office. She also demonstrated that she has been using the name in a “common law” capacity — the name that she generally goes by — since at least May 2022, far longer than the six months that statute requires for candidates to show that they use a certain name.
“Last night, our campaign received important news that Frank Liberati’s challenge to my candidacy, a challenge targeting my legal name change associated with my transition, has been decisively rejected by the county clerk. I am officially confirmed for the August 4th, 2026 primary ballot,” Whaley said in a statement. “This moment is a powerful affirmation of justice, and I am deeply grateful to the supporters nationwide, the Michigan Democratic Party, and the elected leaders who stood with us.”
“It has shown people a contrast right of what I and our campaign have been doing all along, as opposed to trying to be sneaky in the background,” she said in an interview. “We’ve been public and out front with what we’re doing and those are the type of leaders that Downriver wants, that our community wants. They want people who are transparent, who are clear, even if they don’t agree. They love to know what you believe and what you’re working on, and when you surprise people with something like this, it just makes people upset, and it angers them.”
She’s the only candidate, she says, focused on the issues right now.
“This also just shows that they’re not focused on the issues that people are asking for. They’re focused on trying to win on technicalities like Frank is,” Whaley said. “People are done with petty politics. They’re done with it. They want people who can get things done and get things done that they want.”
Whaley also told the Michigan Advance that her campaign cash on hand has nearly tripled, going from around $9,000 to around $25,000, since Liberati’s complaint began garnering public attention, both in the district and around the country.
Following the filing of the initial complaint, which Whaley’s statement called “discriminatory and fraudulent,” Democratic leaders from around the state rallied behind Whaley.
Michigan Democratic Party chair Curtis Hertel said that “Attempts to disqualify candidates for using their legal name betrays the foundational principles of the Democratic Party,” and the Michigan Legislative LGBTQ+ Caucus said that it “serves no purpose but to stoke the flames of transphobia for personal political gain.”
“This really is Frank being disconnected from the Democratic Party for years and not understanding where the Democratic Party is and where it’s going,” Whaley noted in an interview.
The clerk’s office noted that Liberati could appeal the determination in circuit court, and an email from an attorney representing Liberati, shared with the Advance by Whaley, indicates that he may seek to appeal the decision.
Liberati did not respond to a request for comment on the clerk’s determination.
Whaley said that her campaign is waiting to see if Liberati will appeal the decision, adding, “Every day that goes on that we don’t hear anything from Frank about issues or out of the community campaigning, are days that we are suspicious that he’s going to continue trying this, so we’re going to keep our eye on our goals while having an eye at the back of our head.”
