A dispute over access to the upcoming municipal election ballot has led to a federal lawsuit, as several residents claim that failures by local officials have deprived them of their rights as both candidates and voters. The complaint was filed on March 13, 2026 in the United States District Court for the District of New Jersey by Lance T. Lucarelli, his sons Lance II Lucarelli and Dane Lucarelli, against Madelene C. Medina in her official capacity as Municipal Clerk for the City of Bayonne, along with other city and county officials.
According to court documents, Lance T. Lucarelli submitted more than 100 signed petitions on February 26, 2026 in support of his candidacy for Mayor in Bayonne’s non-partisan May election. The suit states that this submission met the legal requirement under New Jersey law for municipalities with more than 50,000 residents. However, Lucarelli alleges that he did not receive written notice or explanation from the clerk regarding any deficiencies in his petitions—a step he says is required by state statute.
The complaint outlines that when nominating petitions are found defective under N.J. Stat. Ann. § 40:45-9, clerks must notify candidates in writing about specific issues so they can attempt to correct them before a set deadline. “The Clerk, however, failed to comply with the requirements…and never provided written notice of her decision regarding the petitions submitted by Plaintiff,” reads one section of the filing. Instead, Lucarelli claims he was handed back some petitions marked as deficient without any formal explanation or guidance on how to proceed.
With no written guidance or opportunity for correction provided by officials, Lucarelli says he attempted to gather additional signatures and resubmitted both returned and new petitions on March 2, 2026—before another statutory deadline—but these were not accepted or considered by the clerk’s office. The suit further notes that no challenges were made by other candidates or residents; all objections originated solely from actions taken by the municipal clerk.
As a result of these actions, Lucarelli was not certified as a candidate and his name was excluded from consideration during the ballot draw process held on March 12, 2026. The plaintiffs argue this exclusion violated their rights under both federal and state law—including those protected by Section 1983 and New Jersey’s Civil Rights Act—by denying equal treatment and meaningful access to participate in elections either as a candidate or voter.
The complaint asserts that “the Clerk acted in an arbitrary, capricious and unreasonable manner,” exceeding her authority under election statutes by conducting detailed signature reviews typically reserved for formal challenges rather than initial petition processing. Plaintiffs also allege that this conduct unfairly favored other candidates at their expense.
With ballots scheduled for printing on March 13 and mail-in ballots set to be distributed beginning March 28 according to state deadlines cited in court documents, plaintiffs argue they face “irreparable harm” if immediate relief is not granted.
To address these alleged violations, plaintiffs request that the court issue an injunction halting all ballot printing related to Bayonne’s Mayoral election until further order is given. They also seek an order requiring Lucarelli’s name be included as a candidate on any printed ballots for mayor unless otherwise determined through proper legal process. Additionally, they ask for attorney’s fees and other equitable relief deemed appropriate by the court.
The case is being handled by attorney Matthew C. Moench of King Moench & Collins LLP on behalf of all plaintiffs under docket number 2:26-cv-02580.
Source: 226cv02580_Lucarelli_v_Medina_Complaint_District_New_Jersey.pdf
