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    New York lawmaker removed from legislature

    Topic: State Legislative Tracker

     From Ballotpedia - Reading time: 11 min
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    March 10, 2014[edit]

    Edited by Joel Williams
    This week’s tracker includes a look at the controversy surrounding a removed New York legislator.

    Weekly highlight[edit]

    Last week, two states, Florida and Louisiana, began their legislative sessions. Meanwhile, Oregon, Virginia, West Virginia and Wyoming adjourned for 2014. Here is a brief look at issues making headlines across the country:

    • Massachusetts: The Massachusetts legislature acted quickly to pass a bill banning the taking of 'upskirt' photos after the Massachusetts Supreme Judicial Court overturned a man's conviction for doing so while riding a Boston trolley in 2010. The defendant, Michael Robertson, argued that his actions were constitutionally protected. In its decision last Wednesday, the court found that under the pre-existing voyeurism law, a woman wearing a skirt or dress could not be considered "partially nude," and that the women Robertson surveilled did not prove a reasonable expectation of privacy as they were on a public trolley. Gov. Deval Patrick (D) signed the bill into law Friday morning, praising the legislature for its atypically swift action and quipping "they can do it when they want to." Under the law, taking photos or video of "the sexual or other intimate parts of a person under or around the person’s clothing" when a "reasonable person" would expect not to see those parts in public is considered a misdemeanor, with distributing such material now being a felony.[1][2][3][4][5]
    • New York: William Boyland (D) of District 55 was removed from the New York State Assembly on March 6, 2014, following his conviction on 21 counts of bribery, extortion conspiracy, attempted extortion and theft. Boyland was arrested in November 2011 for soliciting $250,000 in bribes from two undercover FBI agents who were posing as out-of-town real estate investors. The $250,000 bribe was to help Boyland with legal fees for his Manhattan corruption trial that he was facing at the time and ultimately beat. On undercover audio and video recordings, Boyland can be heard asking for money in exchange for political favors. Loretta E. Lynch, the United States attorney for the Eastern District of New York, said that the trial was "a spectacle of arrogance and entitlement that has been both truly breathtaking and also profoundly sad.” Boyland faces up to 30 years in prison when he is sentenced on June 30. Last September, Boyland withdrew from a plea deal that would have called for a nine-year prison sentence. Boyland's conviction now leaves 12 vacancies in the New York State Legislature; two in the Senate and ten in the Assembly. Governor Andrew Cuomo (D) has given no indication that he will schedule a special election for Boyland's seat or the other eleven empty seats.[6][7][8][9]
    • Tennessee: Sponsors for Tennessee's "Religious Freedom Act" that would allow for wedding businesses to refuse same-sex clients because of religious beliefs are being accused of discrimination. The Religious Freedom Act was created to protect a pastor, rabbi, or singer from being sued for not participating in a same-sex marriage "if doing so would violate the sincerely held religious beliefs of the person." Rep. Bill Dunn (R) said that the bill was necessary because "a person shouldn't get sued for choosing not to participate in a person's wedding." The bill also allows for a person or company to refuse a number of services to those in civil unions, same-sex marriages, or transgender individuals. It would be permitted for food, accommodation, counseling, or adoption services to be denied based on violation of personal religious beliefs. However, the bill would not have allowed for hospitals to refuse service. The bill was introduced on February 5, but after it was met with great opposition, it is being dropped until next year by lead sponsor Sen. Brian Kelsey (R). Same-sex marriages were banned by a 2006 constitutional amendment in Tennessee by 81 percent of voters. A similar "Religious Freedom Act" in Arizona was vetoed by Gov. Jan Brewer (R) for being too controversial.[10][11][12][13]

    Sessions[edit]

    Regular sessions[edit]

    Current sessions capture for the week of March 10, 2014
    See also: Dates of 2014 state legislative sessions
    Click here to see a chart of each state's 2014 session information.

    Currently 37 out of 50 state legislatures are meeting in regular session. One state, Wisconsin, is in special session but currently recessed.

    The following states have convened their 2014 regular session:[14]

    The following states have adjourned their 2014 regular session:[15]

    Special sessions[edit]

    Snapshot of State Legislatures
    There are 7,383 Total State Legislators
    Total Democratic state legislators 3,272 (Expression error: Unexpected < operator.%)
    Total Republican state legislators 3,990 (Expression error: Unexpected < operator.%)
    There are 99 Total State Legislative Chambers
    Total Democratic Party-controlled chambers 41
    Total Republican Party-controlled chambers 57
    Total tied or nonpartisan chambers 1
    2014 Session Information
    Total Special Elections 14
    Total Special Sessions 1
    Wisconsin[edit]

    Gov. Scott Walker (R) called the legislature into special session on January 22. Walker asked the legislature to find a way to fund $500 million worth of property and income tax cuts.[16]

    In recess[edit]

    As of today, March 10, there are two state legislatures currently in recess:[17]









    2014 Legislative Elections[edit]

    See also: State legislative elections, 2014

    A total of 87 of the 99 chambers will hold state legislative elections on November 4, 2014.

    The 87 chambers with elections in 2014 are in 46 states. They are:

    The Kansas, Minnesota, New Mexico and South Carolina senates also typically hold elections in odd years. However, senators are elected to 4-year terms in those states and those will not be up for election again until 2015.

    1090 of the country's 1,972 state senate seats are up for re-election in November 2014, and 4,958 of the country's 5,415 state house seats are up for re-election. Altogether, 6,048 of the country's 7,387 state legislative seats are up for re-election on November 4, 2014.

    Primary Information[edit]

    See also: Signature requirements and deadlines for 2014 state legislative elections

    The state legislative filing deadlines and primary dates are as follows:

    Note: Ballot access is a complicated issue. The dates in the table below are primarily for candidates filing for access to the primary. For more detailed information about each state's qualification requirements -- including all relevant ballot access dates for the primary and general election -- click to our detailed pages in the state column.

    2014 State Legislative Primary Information
    State Filing Deadline Primary Date Days from Deadline to Primary
    Alabama Red padlock.png 2/7/2014 Red padlock.png 6/3/2014 116
    Alaska Red padlock.png 6/2/2014[18] Red padlock.png 8/19/2014 78
    Arizona Red padlock.png 5/28/2014[19] Red padlock.png 8/26/2014 90
    Arkansas Red padlock.png 3/3/2014[20][21] Red padlock.png 5/20/2014 78
    California Red padlock.png 3/7/2014[22][23][24] Red padlock.png 6/3/2014 88
    Colorado Red padlock.png 3/31/2014[25][26] Red padlock.png 6/24/2014 85
    Connecticut Red padlock.png 6/10/2014[27] Red padlock.png 8/12/2014 90
    Delaware Red padlock.png 7/8/2014 Red padlock.png 9/9/2014 63
    Florida Red padlock.png 6/20/2014[28][29] Red padlock.png 8/26/2014 67
    Georgia Red padlock.png 3/7/2014 Red padlock.png 5/20/2014 74
    Hawaii Red padlock.png 6/3/2014[30] Red padlock.png 8/9/2014 67
    Idaho Red padlock.png 3/14/2014 Red padlock.png 5/20/2014 78
    Illinois Red padlock.png 12/2/2013 Red padlock.png 3/18/2014 106
    Indiana Red padlock.png 2/7/2014 Red padlock.png 5/6/2014 88
    Iowa Red padlock.png 3/14/2014 Red padlock.png 6/3/2014 81
    Kansas Red padlock.png 6/2/2014 Red padlock.png 8/5/2014 65
    Kentucky Red padlock.png 1/28/2014[31][32] Red padlock.png 5/20/2014 112
    Maine Red padlock.png 3/17/2014[33] Red padlock.png 6/10/2014 85
    Maryland Red padlock.png 2/25/2014[34] Red padlock.png 6/24/2014 119
    Massachusetts Red padlock.png 6/3/2014[35] Red padlock.png 9/9/2014 98
    Michigan Red padlock.png 4/22/2014 Red padlock.png 8/5/2014 105
    Minnesota Red padlock.png 6/3/2014 Red padlock.png 8/12/2014 70
    Missouri Red padlock.png 3/25/2014 Red padlock.png 8/5/2014 133
    Montana Red padlock.png 3/10/2014 Red padlock.png 6/3/2014 85
    Nebraska Red padlock.png 3/3/2014[36] Red padlock.png 5/13/2014 85
    Nevada Red padlock.png 3/14/2014 Red padlock.png 6/10/2014 88
    New Hampshire Red padlock.png 6/13/2014 Red padlock.png 9/9/2014 88
    New Mexico Red padlock.png 2/4/2014 Red padlock.png 6/3/2014 119
    New York Red padlock.png 7/10/2014 Red padlock.png 9/9/2014 61
    North Carolina Red padlock.png 2/28/2014 Red padlock.png 5/6/2014 67
    North Dakota Red padlock.png 4/7/2014 Red padlock.png 6/10/2014 64
    Ohio Red padlock.png 2/5/2014 Red padlock.png 5/6/2014 90
    Oklahoma Red padlock.png 4/11/2014 Red padlock.png 6/24/2014 74
    Oregon Red padlock.png 3/11/2014 Red padlock.png 5/20/2014 70
    Pennsylvania Red padlock.png 3/11/2014 Red padlock.png 5/20/2014 70
    Rhode Island Red padlock.png 6/25/2014 Red padlock.png 9/9/2014 76
    South Carolina Red padlock.png 3/30/2014 Red padlock.png 6/10/2014 72
    South Dakota Red padlock.png 3/25/2014 Red padlock.png 6/3/2014 70
    Tennessee Red padlock.png 4/3/2014 Red padlock.png 8/7/2014 126
    Texas Red padlock.png 12/9/2013 Red padlock.png 3/4/2014 85
    Utah Red padlock.png 3/20/2014 Red padlock.png 6/24/2014 96
    Vermont Red padlock.png 6/12/2014 Red padlock.png 8/26/2014 75
    Washington Red padlock.png 5/17/2014 Red padlock.png 8/5/2014 80
    West Virginia Red padlock.png 1/25/2014 Red padlock.png 5/13/2014 108
    Wisconsin Red padlock.png 6/2/2014 Red padlock.png 8/12/2014 71
    Wyoming Red padlock.png 5/30/2014 Red padlock.png 8/19/2014 81


    Special Elections[edit]

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    See also: State legislative special elections, 2014

    There is one special primary scheduled this week in Florida.

    Florida House of Representatives District 44[edit]

    See also: Florida state legislative special elections, 2014

    Eric Eisnaugle (R) defeated Shaun Raja (D) in the special election, which took place on April 8.[37][38] Raja was unopposed in the March 11 Democratic primary, while Eisnaugle defeated Stephen Vincent Facella in the March 11 Republican primary.[39][40]

    Eisnaugle, a state representative from 2008-2012, chose not to run for re-election in 2012 when redistricting drew him against fellow Rep. Stephen Precourt (R). With Precourt term-limited in 2014, Eisnaugle planned to run for the seat again. Several Republicans, including Speaker Steve Crisafulli (R), backed Eisnaugle. "Eric’s track record of leadership will allow him to serve his Orange County constituents well. It is obvious that his message of job growth and fiscal responsibility resonated with the voters of his district." Crisafulli said.[41]

    The seat was vacant following Stephen Precourt's (R) appointment as the head of the Orlando-Orange County Expressway Authority.[42]

    A special election for the position of Florida House of Representatives District 44 was called for April 8, with a primary if necessary on March 11. The filing deadline for candidates wishing to run in this election was January 23.[43]

    Florida House of Representatives, District 44, Special Election, 2014
    Party Candidate Vote % Votes
         Republican Green check mark transparent.pngEric Eisnaugle 74.2% 6,983
         Democratic Shaun Raja 25.8% 2,429
    Total Votes 9,412
    Democratic PartyMarch 11 Democratic primary candidates:
    Republican PartyMarch 11 Republican primary candidates:

    Recent election results[edit]

    March 4, 2014[edit]

    ☐ Massachusetts State Senate Fifth Middlesex District

    See also: Massachusetts state legislative special elections, 2014

    Jason M. Lewis (D) defeated Monica C. Medeiros (R) in the special election, which took place on April 1.[37][44] Lewis defeated Christopher G. Fallon and Anthony V. Guardia in the Democratic primary, while Medeiros was unopposed in the Republican primary.[39][45]

    The seat was vacant following Katherine Clark's (D) election to Massachusetts' Fifth Congressional District.

    A special election for the position of Massachusetts State Senate Fifth Middlesex District was called for April 1, with a primary on March 4. The filing deadline for candidates wishing to run in this election was January 28.[46]

    Massachusetts State Senate, Fifth Middlesex District, Special Election, 2014
    Party Candidate Vote % Votes
         Democratic Green check mark transparent.pngJason M. Lewis 53.2% 10,611
         Republican Monica C. Medeiros 46.8% 9,321
    Total Votes 19,932
    Democratic PartyMarch 4 Democratic primary candidates:
    Republican PartyMarch 4 Republican primary candidates:

    ☐ Massachusetts House of Representatives Fourth Hampden District

    See also: Massachusetts state legislative special elections, 2014

    John C. Velis (D) defeated Dan Allie (R) in the special election, which took place on April 1. Velis was unopposed in the Democratic primary, while Allie was unopposed in the Republican primary.[39][37][47]

    The seat was vacant following Donald F. Humason, Jr.'s (R) election to the Massachusetts State Senate.[48]

    A special election for the position of Massachusetts House of Representatives Fourth Hampden District was called for April 1, with a primary on March 4. The filing deadline for candidates wishing to run in this election was January 28.[48]

    Massachusetts House of Representatives, Fourth Hampden District, Special Election, 2014
    Party Candidate Vote % Votes
         Democratic Green check mark transparent.pngJohn C. Velis 53.4% 2,697
         Republican Dan Allie 46.6% 2,354
    Total Votes 5,051
    Democratic PartyMarch 4 Democratic primary candidates:
    Republican PartyMarch 4 Republican primary candidates:

    ☐ Massachusetts House of Representatives Second Suffolk District

    See also: Massachusetts state legislative special elections, 2014

    Daniel Joseph Ryan defeated Roy A. Avellaneda and Christopher Remmes in the Democratic primary[49] and was unopposed in the special election, which took place on April 1.[39][37][50]

    The seat was vacant following Eugene O'Flaherty's (D) appointment as Boston's corporation counsel.[51]

    A special election for the position of Massachusetts House of Representatives Second Suffolk District was called for April 1, with a primary on March 4. The filing deadline for candidates wishing to run in this election was January 28.[51]

    Massachusetts House of Representatives, Second Suffolk District Special Election Democratic Primary, 2014
    Candidate Vote % Votes
    Green check mark transparent.pngDaniel Joseph Ryan 58.9% 2,291
    Roy A. Avellaneda 29.8% 1,161
    Christopher Remmes 11.3% 438
    Total Votes 3,890
    Democratic PartyMarch 4 Democratic primary candidates:

    ☐ Massachusetts House of Representatives Thirteenth Suffolk District

    See also: Massachusetts state legislative special elections, 2014

    Daniel J. Hunt defeated Liam P. Curran, Gene I. Gorman, Paul L. Mccann, Jr. and John K. O’Toole in the Democratic primary[52] and was unopposed in the special election, which took place on April 1.[39][37][53]

    The seat was vacant following Martin Walsh's (D) election as Mayor of Boston.[54]

    A special election for the position of Massachusetts House of Representatives Thirteenth Suffolk District was called for April 1, with a primary on March 4. The filing deadline for candidates wishing to run in this election was January 28.[37]

    Massachusetts House of Representatives, Thirteenth Suffolk District Special Election Democratic Primary, 2014
    Candidate Vote % Votes
    Green check mark transparent.pngDaniel J. Hunt 49.9% 2,338
    John K. O’Toole 23.1% 1,082
    Liam P. Curran 19% 892
    Paul L. Mccann, Jr. 5% 233
    Gene I. Gorman 3% 141
    Total Votes 4,686
    Democratic PartyMarch 4 Democratic primary candidates:

    ☐ Massachusetts House of Representatives Sixteenth Suffolk District

    See also: Massachusetts state legislative special elections, 2014

    RoseLee Vincent (D) defeated Todd B. Taylor (R) in the special election, which took place on April 1.[37][55] Vincent defeated Joshua D. Monahan and Linda S. Rosa in the Democratic primary, while Taylor was unopposed in the Republican primary.[39][56]

    The seat was vacant following Kathi-Anne Reinstein's (D) resignation to become the Government Affairs Manager for the Boston Beer Company.[51]

    A special election for the position of Massachusetts House of Representatives Sixteenth Suffolk District was called for April 1, with a primary on March 4. The filing deadline for candidates wishing to run in this election was January 28.[51]

    Massachusetts House of Representatives, Sixteenth Suffolk District, Special Election, 2014
    Party Candidate Vote % Votes
         Democratic Green check mark transparent.pngRoseLee Vincent 67.9% 1,586
         Republican Todd B. Taylor 32.1% 749
    Total Votes 2,335
    Democratic PartyMarch 4 Democratic primary candidates:
    Republican PartyMarch 4 Republican primary candidates:

    Looking ahead[edit]

    Upcoming special elections include:

    • March 18: Pennsylvania State Senate District 28
    • March 25: Alabama House of Representatives District 53
    • March 25: California State Senate District 23
    • April 1: Massachusetts State Senate Fifth Middlesex District
    • April 1: Massachusetts House of Representatives Fourth Hampden District
    • April 1: Massachusetts House of Representatives Second Suffolk District
    • April 1: Massachusetts House of Representatives Thirteenth Suffolk District
    • April 1: Massachusetts House of Representatives Sixteenth Suffolk District

    See also[edit]

    Footnotes[edit]

    1. ↑ ABC News, "Massachusetts 'Upskirt' Ruling Clears Man Who Took Photos," March 6, 2014. Accessed March 7, 2014
    2. ↑ The Republican, "House Speaker Robert DeLeo: Massachusetts legislature could pass 'upskirting' bill today," March 6, 2014. Accessed March 7, 2014
    3. ↑ The Republican, "Massachusetts Legislature passes bill banning 'upskirting,'" March 6-7, 2014. Accessed March 7, 2014
    4. ↑ Los Angeles Times, "'Upskirting' banned in Boston after governor signs bill," March 7, 2014
    5. ↑ Boston Globe, "Patrick signs bill to ban ‘upskirting,’" March 7, 2014. Accessed March 7, 2014
    6. ↑ NY times, "Assemblyman Is Convicted in Second Corruption Trial," accessed March 7, 2014
    7. ↑ Wall Street Journal, "New York Assemblyman Found Guilty of Federal Bribery Charges," accessed March 7, 2014
    8. ↑ NY daily news, "Brooklyn Assemblyman William Boyland, Jr. convicted for soliciting bribes ," accessed March 7, 2014
    9. ↑ News day, "Assemb. William Boyland guilty on all counts," accessed March 7, 2014
    10. ↑ Mother Jones, "Inside the Conservative Campaign to Launch 'Jim Crow-Style' Bills Against Gay Americans," February 20, 2014
    11. ↑ Washington Blade, "Arizona's 'turn away the gay' bill part of national trend," February 24, 2014
    12. ↑ New Republic, "Do the New 'Turn the Gays Away' Bills Stand Up to the Constitution?" February 25, 2014
    13. ↑ Johnson City Press, "Turn away gays' bill looks to be dead in Tennessee - for now," March 3, 2014
    14. ↑ Stateside Associates, " Session Calendar 2014," accessed March 10, 2014
    15. ↑ Stateside Associates, " Session Calendar 2014," accessed March 10, 2014
    16. ↑ Wisconsin Governor's Office, "Governor Scott Walker Calls Special Session, Calls on Legislators to Pass the Blueprint for Prosperity," January 23, 2014
    17. ↑ StateNet, " Daily Session Summary," accessed March 10, 2014
    18. ↑ Alaska Statutes, "Section 15.25, Nomination of Candidates," accessed October 31, 2013
    19. ↑ Secretary of State Website, "2014 Election Important Dates," accessed November 4, 2013
    20. ↑ Running for Public Office, "A 'Plain English' Handbook for Candidates," 2012 Edition, accessed October 21, 2013 (dead link)
    21. ↑ Arkansas Code of 1987, "Title 7, Elections," accessed October 30, 2013
    22. ↑ Summary of Qualifications and Requirements for the Office of State Senator, Member of the Assembly, "June 3, 2014, Primary Election," accessed October 21, 2013
    23. ↑ California Elections Code, "Section 8100-8107," accessed October 28, 2013
    24. ↑ California Secretary of State Website, "Key Dates and Deadlines," accessed October 21, 2013
    25. ↑ Colorado Secretary of State Website, "Major Political Parties FAQs," accessed October 31, 2013
    26. ↑ Colorado Revised Statutes, "Title 1, Elections," accessed October 31, 2013
    27. ↑ Connecticut Secretary of State Website, "Frequently Asked Questions, Nominating Papers," accessed October 31, 2013
    28. ↑ Florida Department of State Division of Elections, "2013-2014 Dates to Remember," accessed November 6, 2013
    29. ↑ 2013 Florida Statutes, "Section 99.061," accessed December 2, 2014
    30. ↑ Hawaii State Legislature, "HRS §12-6 Nomination papers: time for filing; fees", accessed May 22, 2013
    31. ↑ 2014 Kentucky Election Calendar, accessed November 12, 2013
    32. ↑ Kentucky State Board of Elections "Candidate Qualifications and Filing Fees" accessed November 26, 2011
    33. ↑ Maine Secretary of State "State of Maine 2014 Candidate's Guide to Ballot Access," accessed February 11, 2014
    34. ↑ The State Board of Elections, "Candidacy," accessed November 5, 2013
    35. ↑ 2014 Massachusetts State Primary and State Election Schedule, accessed December 2, 2013
    36. ↑ Official Election Calendar for the State of Nebraska, accessed November 18, 2014
    37. ↑ 37.0 37.1 37.2 37.3 37.4 37.5 37.6 Orlando Sentinel "Eric Eisnaugle wins special election in Florida House District 44," April 8, 2014 Cite error: Invalid <ref> tag; name "result" defined multiple times with different content Cite error: Invalid <ref> tag; name "result" defined multiple times with different content Cite error: Invalid <ref> tag; name "result" defined multiple times with different content Cite error: Invalid <ref> tag; name "result" defined multiple times with different content Cite error: Invalid <ref> tag; name "result" defined multiple times with different content
    38. ↑ Florida Department of State, "Official special election results," accessed May 7, 2014
    39. ↑ 39.0 39.1 39.2 39.3 39.4 39.5 Florida Secretary of State, "Official candidate list," accessed January 24, 2014 Cite error: Invalid <ref> tag; name "list" defined multiple times with different content Cite error: Invalid <ref> tag; name "list" defined multiple times with different content Cite error: Invalid <ref> tag; name "list" defined multiple times with different content Cite error: Invalid <ref> tag; name "list" defined multiple times with different content Cite error: Invalid <ref> tag; name "list" defined multiple times with different content
    40. ↑ sunshinestatenews.com, "Eric Eisnaugle Closer to Tallahassee Return After Big Primary Win," March 11, 2014
    41. ↑ sunshinestatenews.com, "Eric Eisnaugle Breezes Back to Florida House after Stunning Special Election Victory," April 8, 2014
    42. ↑ Orlando Sentinel, "Special election set to replace Steve Precourt in Florida House," January 12, 2014
    43. ↑ Florida Department of Elections, "H44 Notice of Election," accessed January 21, 2014
    44. ↑ Massachusetts Secretary of State, "Official special election results," accessed April 16, 2014
    45. ↑ winchester.patch.com, "Lewis, Medeiros Win Special State Senate Primaries," March 4, 2014
    46. ↑ sec.state.ma.us, "Special election calendar," accessed December 13, 2013
    47. ↑ Massachusetts Secretary of State, "Official special election results," accessed April 16, 2014
    48. ↑ 48.0 48.1 masslive.com, "Special election to fill Don Humason's former 4th Hampden District House seat set," December 30, 2013
    49. ↑ Boston Globe, "Daniel Hunt nominated for Martin Walsh seat," March 5, 2014
    50. ↑ Massachusetts Secretary of State, "Official special election results," accessed April 16, 2014
    51. ↑ 51.0 51.1 51.2 51.3 Boston Globe, "Boston Mayor Martin J. Walsh announces six Cabinet appointments," January 7, 2014. accessed January 9, 2014 Cite error: Invalid <ref> tag; name "announce" defined multiple times with different content
    52. ↑ Boston Globe, "Daniel Hunt nominated for Martin Walsh seat," March 5, 2014
    53. ↑ Massachusetts Secretary of State, "Official special election results," accessed April 16, 2014
    54. ↑ The New York Times, "State Lawmaker is Elected Mayor in Boston," November 5, 2013. Retrieved November 5, 2013.
    55. ↑ Massachusetts Secretary of State, "Official special election results," accessed April 16, 2014
    56. ↑ Boston Globe, "Daniel Hunt nominated for Martin Walsh seat," March 5, 2014
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