Cynthia Johnson v. Denise Wilkerson

CourtSupreme Court of New Jersey
DecidedOctober 27, 2025
DocketS-10-25
StatusPublished

This text of Cynthia Johnson v. Denise Wilkerson (Cynthia Johnson v. Denise Wilkerson) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cynthia Johnson v. Denise Wilkerson, (N.J. 2025).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Cynthia Johnson v. Denise Wilkerson (S-10-25) (091201)

Decided by Order September 19, 2025 -- Opinion Filed October 27, 2025

RABNER, C.J., writing for a unanimous Court.

This matter involves an election dispute. The Court resolved the dispute through a September 19 order affirming the judgment of the Appellate Division. ___ N.J. ___ (2025). The Court’s opinion explains the reasons for that decision.

On June 10, 2025, Denise Wilkerson won the Democratic primary for a council seat in the Borough of Roselle by three votes over Cynthia Johnson, the other Democratic candidate. Johnson requested a recount and a recheck on June 25. On July 10, the trial court denied the request for a recount but allowed for a recheck. After Johnson filed an emergent appeal, the Appellate Division summarily reversed the denial of the recount. A recount conducted on August 4 reduced Wilkerson’s margin of victory from three to two votes. On August 7, Johnson filed an amended petition for an election contest in the trial court.

In a September 9 decision, the trial court found sufficient evidence that three voters had improperly been denied the right to vote and ordered a new election. Following a motion to clarify filed by the Attorney General, the trial court heard oral argument and reconsidered its decision. In a September 12 order, the court “remove[d] the requirement of a new election” and directed “that the candidate shall be selected pursuant to N.J.S.A. 19:13-20” by September 14. The Democratic County Committee selected Johnson as the party’s nominee by a vote of 20 to 7.

Wilkerson asked the Appellate Division to reverse the trial court’s September 12 order. The Appellate Division affirmed, upholding the use of the process outlined in N.J.S.A. 19:13-20, which led to Johnson’s selection as the party’s nominee.

Wilkerson filed an emergent application asking the Court to direct that both a special primary election and a special general election be held after Election Day. Alternatively, she requested that the names of both Democratic primary candidates be placed on the general election ballot.

HELD: Neither remedy Wilkerson seeks finds support in the statutory scheme.

1 1. Two statutes that apply to primary elections lie at the center of this matter: N.J.S.A. 19:13-18 (section 18) and N.J.S.A. 19:13-20 (section 20). Those sections govern here because (1) a majority of the votes cast in the primary election selected Wilkerson as the Democratic party’s nominee, and (2) the trial court set aside the results of the election. Tracking the language of section 18, the court’s ruling rendered Wilkerson’s nomination “inoperative” and created a vacancy. Section 20 outlines how to fill that vacancy. Section 20(a)(4) applies when a vacancy arises “among candidates nominated at a primary election” -- the situation in this case. Although section 20 requires that the vacancy “shall occur not later than the 70th day before the general election” -- in this case, August 26 -- and the trial court’s ruling resulting in a vacancy was issued on September 9, the Court agrees with the Appellate Division that delays in the trial court litigation warrant relaxation of the 70-day requirement. Section 20(a)(4) therefore applies and directs that the county committee of the political party “shall . . . select[]” the candidate in matters like this one. (pp. 8-12)

2. Wilkerson presents an impassioned argument that principles of equity and fairness require that “the people -- and not the party -- should be permitted to decide their elected representative.” But the law does not provide for a special primary election after the date of the general election. Nor is there support for a special general election after a vacancy in the nomination process, let alone for holding such an election after Election Day. Certain statutes call for special elections for vacancies in offices, but none address a vacancy in a nomination for an office. In the alternative, Wilkerson asks the Court to order that both her name and Johnson’s be placed on the ballot for the general election. That course would effectively transform the general election into a second primary election for the Democratic candidates. There is no statutory support for that alternative approach either. (pp. 12-14)

3. In several cases, the Court has broadly construed or relaxed the requirements of sections 18 and 20 to promote the right to vote. But those cases did not set aside the State’s election laws and create new constructs not supported by the statutes. The remedies Wilkerson seeks -- hosting a new primary after the date of the general election or placing both Democratic primary candidates on the general election ballot -- go beyond what the statutes envision. The law provides no basis for the relief sought. And neither proposed option calls for an orderly general election to be held early in November consistent with the statutory scheme. (pp. 14-19)

4. The Court looks to the Legislature for guidance on such issues and has tried to act in accordance with legislative intent in this case by interpreting relevant laws. The Legislature, as always, has the authority to amend existing statutes. (p. 19)

AFFIRMED.

JUSTICES PATTERSON, PIERRE-LOUIS, WAINER APTER, NORIEGA, and HOFFMAN join in CHIEF JUSTICE RABNER’s opinion. JUSTICE FASCIALE did not participate. 2 SUPREME COURT OF NEW JERSEY S-10 September Term 2025 091201

Cynthia Johnson,

Respondent,

v.

Denise Wilkerson,

Applicant,

and

Union County Board of Elections; Joanne Rajoppi, Union County Clerk; and Lisette Sanchez, Borough of Roselle Municipal Clerk,

Respondents.

On an Emergent Application Pursuant to Rule 2:9-8.

Decided by Order Opinion Filed September 19, 2025 October 27, 2025

PEM Law, attorneys for applicant Denise Wilkerson (Rajiv D. Parikh and Avi D. Kelin, of counsel, and Julia Pudimott and Maximilian Ranzato, on the brief).

King Moench & Collins, attorneys for respondent Cynthia Johnson (Matthew C. Moench, of counsel and on the brief, and Alyssa Duffy Zara, on the brief).

1 Angela Cai, Acting Attorney General of New Jersey, attorney for respondent Union County Board of Elections (Sookie Bae-Park, Assistant Attorney General, of counsel, and Brian D. Ragunan, Deputy Attorney General, on the brief).

Union County Counsel’s Office, attorneys for respondent Joanne Rajoppi, Union County Clerk (Bruce H. Bergen, Union County Counsel, on the brief).

CHIEF JUSTICE RABNER delivered the opinion of the Court.

This matter involves an election dispute. Denise Wilkerson won the

Democratic primary for a council seat in Roselle by three votes. A recount

and a court hearing followed. After the trial court found that several voters

had been improperly denied the right to vote, the court invalidated the election.

The court ultimately directed that the Democratic County Committee select the

Democratic candidate for the general election, pursuant to N.J.S.A. 19:13-20

(section 20).

Wilkerson filed an emergency application for relief with the Appellate

Division. She asked the appellate court, and now asks this Court, to direct that

both a special primary election and a special general election be held after

Election Day. Alternatively, she requests that the names of both Democratic

primary candidates be placed on the general election ballot. Neither remedy

finds support in the statutory scheme.

2 The Appellate Division denied Wilkerson’s request for relief.

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Cynthia Johnson v. Denise Wilkerson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cynthia-johnson-v-denise-wilkerson-nj-2025.