Saturday, August 31, 2019

Florida: Publisher calls for Miami Commissioner recall

The publisher of a Miami Community Newspapers is calling for the recall of Miami Commissioner Joe Carollo over cclaims that he is conducting a revenge campaign against his opponents. Carollo is the former City Manager of the City of Doral and the publisher claims that Carollo had previously called any opponents part of a "secret Communist cabal."

Petitioners would need 1580 signatures in 30 days and then 4738 signatures in 60 days.

Friday, August 30, 2019

Alaska: Thoughts on the Unique Challenges of the Alaska Gubernatorial recall

I wrote the following op-ed on the effort to recall Alaska Governor Mike Dunleavy (R) after his line item vetoes. I want to expand on those thoughts here.

While there have been five other governors who have been threatened with a recall, the Alaska recall effort stands out.

1) Dunleavy is the only Republican facing a recall effort -- the other five are Democrats.

2) The recall drive is significantly less partisan -- numerous Republicans are involved in the petition effort. The others recall efforts appear to be explicitly partisan to the degree that the state party chairs are publicly involved.

3) Unlike the other states, due to Alaska law, if Dunleavy is removed, he will automatically be replaced by a Republican, his Lieutenant Governor Kevin Meyer. Oregon has some questions in this area, but the the leaders of the other five recall efforts clearly believe that they will flip the State Executive with a successful recall.

4) Alaska is the only "malfeasance standard" state to have a recall effort, which means that the courts could throw the recall out.

The first three points speak for themselves. But the fourth one is arguably the most important.

Nineteen states allow for a recall of a governor. But there is a big division in what is needed to get a recall on the ballot. In 11 states, including the five mentioned above, there is a political recall law. Under these laws, officials can face a recall for almost any reason. Causes of action, such as alleging actual criminal behavior or incompetence, is not required at all for the recall to move forward.

Alaska has what I call the malfeasance or judicial recall (not to be confused with a recall of a judge) standard, requires that the petitioner show a violation of a law, lack of fitness or some manifest incompetence. These laws vary greatly from state to state. In Illinois, only the governor is covered by recall, and in Virginia, there is no election but rather a judicial hearing. But all of these malfeasance standard states require an agency or the courts to hold that a specific, statutorily delineated bad act was performed by the elected official.

The difference is clear. There have been six state-wide recalls in US history, all in political states. There have been 39 state legislative recalls. Only one (in Washington in 1981) was in a malfeasance standard state.

In Alaska, the malfeasance standard appears to operate quite a bit differently than other states, in such a way that it is almost a hybrid version that may allow political recalls at will.

In Alaska’s case, petitioners must first gather verified signatures amounting to 10% of the turnout in the previous election (28,501), and then have the director of the Division of Elections-- headed by the same Lieutenant Governor who would become governor if Dunleavy is removed -- agree that the reasons stated in the petition meets the cause requirements in Alaska’s law. If the director approves this, petitioners must then gather signatures amounting to 25% of turnout (71,252 signatures). In the past, the division has rejected recalls against a governor, two state senators and one assembly representative due to a failure to state a valid cause of action.

But at the same time, a 1984 Alaska Supreme Court ruling held that the recall law “should be liberally construed so that the people are permitted to vote and express their will” - at least on the local level. In 2017, a Superior Court judge used this decision to allow a recall to move forward against three Homer City Council members over their support for protesters against the Dakota pipeline. The judge noted that the Alaska Supreme Court has previously held that the recall In the end, the Homer recall took place, though all the officials survived the vote. The Homer recall is not the only one to take place in recent years. This liberal construction of the recall has led to at least 27 recalls making the ballot since 2011, including the mayor of Whittier and a city councilman in Sarah Palin’s hometown of Wasilla.

What does this mean? One, as always as usual, we are ending up in the courts before this move forward. Two, the petitioners clearly think they have a good chance of success. But plenty of others have thought that in the past. Will the Alaska Supreme Court accept this liberal approach to recall law and allow it to go forward, or will they dial this effort back? It seems like we are about to find out.

Michigan: House calls for resignation of State Representative indicted over bribery and extortion charges

The move to push out Michigan State Representative Larry C. Inman (R) after a grand jury charged him with attempted extortion, bribery and lying to the FBI continues, with the House voting 98-8 to call for his resignation. Inman is accused of trying to get a bribe from a union group for a vote to repeal the state's prevailing wage law.

Petitions are being collected and would need 12201 signatures to get on the ballot.

Maine: Four Mechanic Falls Councilors up for a vote on September 24

A recall against Mechanic Falls Council Chair Cathy Fifield (242), Vice Chair Wayne Hackett (248) and Councilors Nicholas Konstantoulakis (231) and John Emery (224) is set for September 24. The issue was a 4-1 vote to dismiss Town Manager Zakk Maher in what is alleged to be a violation of the Open Meeting Act.

Petitioners needed at least 192 signatures in 30 days (15% of gubernatorial turnout). There is a "absentee veto" provision, where the total votes in the recall must be at least 30% of the those cast in the 2018 gubernatorial election -- that is 384.

California: Signature gathering advances in Foster City Vice Mayor recall effort

Petitioners claim to have over 2500 signatures to get the recall of Foster City Vice Mayor Herb Perez  on the ballot over complaints about his conduct and "pro development agenda." Perez claims the issue is housing.  Petitioners 3313 signatures.

Thursday, August 29, 2019

Articles on Gubernatorial Recall efforts

Lots going on with Gubernatorial recalls:

1) Here's 538 on the gubernatorial recall efforts

2) A look at the Oregon Governor Recall

3) Republicans in Oregon are claiming that they are on track to get enough signatures against Governor Kate Brown

4) One of the groups raising funds for the Colorado Governor Jared Polis recall has spent a good portion of its raised funds to Colorado for Trump.

Michigan: Two more Flint Council member petitions approved

The recall effort against Councilwoman Kate Fields, after officials threw out a majority of the signatures turned in. Petitioners handed in 825 signatures and needed 556. But only 332 were found valid.

There is still petitions out against Councilmembers Santino Guerra, Allan Griggs and Monica Galloway.

Guerra and Fields were facing a petition over a vote to extend a $12 million waste removal contract. Galloway is facing the petition over being absent for a vote to enter into a $5.6 million contract with a construction company.

Fields claims that Mayor Karen Weaver, Councilmember Eric Mays  and Community Liaison for Economic Development Aonie Gilcreast are behind the recall effort. Mays has acknowledged this.


Maine: Ogunquit Selectman who survived recall vote resigns office

Ogunquit Selectman Charles Waite III resigned from office after surviving a recall vote in May.  Waite  was one of three recall survivors, winning the race 386-358. The resignation was over a private matter.

Arizona: Signature gathering ongoing against Payson Mayor and Three Council members

Payson Mayor Tom Morrissey and Councilmembers Suzy Tubbs-Avakian, Janell Sterner and Jim Ferris are facing a recall effort over the firing of a town manager and spending and transparency issues.

Petitioners, including former Payson Mayor Kenny Evans and Councilor and Town Manager Fred Carpenter, have set a deadline on August 30 (so that they are on the November ballot). They need 770 for the mayor and 1653 for each council member.

Colorado: Petitions taken out against Elizabeth Mayor and Trustees

Elizabeth Mayor Megan Vasquez and Trustees Angela Ternus, Rachel White, June Jurczewsky, Steve Gaither, Loren Einspahr, Tammy Payne are facing a recall effort over development issues, with petitioners claiming that the town has more demands on services. Petitioners need 53 signatures for Vasquez and between 33-36 for the others.

California: Westminster Mayor and City Council facing recall efforts

Westminster Mayor Tri Ta and Councilmembers Kimberly Ho, Chi Charlie Nguyen, Tai Do and Sergio Contreras are also facing recall petitions over a council fight allegations of corruption and grandstanding. Ta, Ho and Nguyen are aligned on one side, while Do and Contreras are on the other.

Westminster has had difficulty retaining personnel, with 10 managers in 14 years and 5 police chiefs in 8.

Wisconsin: Vernon Supervisor Ousted in a recall

Vernon Town Supervisor Ed Moline was kicked out in a recall vote, finishing fourth with 49 votes. Former Town Chairman Fred Michalek won the race with almost 83% of the vote, 797-70-50-49.

The recall was over Moline's support for a boundary agreement between Vernon and Mukwonago. The petition specifically cited his approval of three newsletters that "favorably discussed" the agreement. Residents overwhelmingly opposed the agreement in a nonbinding referendum, 816-90. Town Chairman Carl Fortner also served as a recall petitioner.

Idaho: Three Middleton School Board members survive recall vote; One survives by absentee veto provision

Middleton School Board Members Tim Winkle, Marianne Blackwell and Alicia McConkie survived a special election recall vote on August 27. The vote for Winkle was 145-151 and Blackwell was 103-108.

The vote against McConkie was quite different. 115 voted to remove, and only 93 voted for her to remain in office. However, she survived the recall due to an "absentee veto" provision in Idaho law. 55% of voters cast ballots to remove McConkie. However, the vote to remove must exceed the amount of votes the candidate received when they won the office in the last election. This time the removal vote was 115. She got 120 last election.

Turnout was 11 percent.

The recall was over a vote not to renew the High School principal's contact. The principal has accused school administrators of harassing him. A fourth member, Kirk Adams, is facing threats, but due to his recent election, is not eligible for a recall until the November election.

Kenya: MP facing recall threat over alleged drunk appearance

MP Kuria Kimani is facing a recall threat after allegedly appearing drunk at a public meeting which was set up to discuss how to battle the sale of illicit drinks. Petitioners must get 30% of registered voters signatures, plus 15% in every ward. They also cannot launch a recall in the 24 months after an election and the one year prior to an election.

Monday, August 26, 2019

Washington: Clark County GOP Chair facing recall threats

Clark County GOP Republican Chair Earl Bowerman is facing a recall effort over claims of party finance problems, broken rules and other issues. Bowerman lost a GOP Primary last year to Congressman Jaime Herrera Beutler.

Party Vice Chair Brook Pell was also targeted over claims that she bashed Republicans and did not attend board meetings, but Pell has since resigned.

Sunday, August 25, 2019

California: Amador County School Board effort fails

Recall efforts against Board President Susan Ross and members Kandi Thompson and Janet White failed after petitioners handed in signatures but did not get enough. No signatures were handed in against Deborah Pulskamp.

Nebraska: Two Antelope Commissioners up for special election recall vote on October 15

Antelope Commissioners Tom Borer and Allan Bentley will be facing a recall vote on October 15 on the ballot. The meeting to schedule the vote was contentious, with Borer objecting to the date. The recall is over claims of mismanagement of funds. Petitioners needed 203 signatures for Borer and 135 signatures for Bentley (35% of turnout).

California: Three Lakeport School Board members facing recall effort

Lakeport school board members Dan Buffalo, Carly Alvord and Jennifer Hanson are facing recall threats over claims of harassment and the decision to fire the Superintendent, who removed a principal. So far, the first two petitions have been rejected, once for being too long and the other for not having all the required information.

Petitioners would need 1490 signatures (25% of registered voters) to get on the ballot.

Friday, August 23, 2019

Nebraska: Geneva Mayor facing recall effort

Geneva Mayor Eric Kamler facing recall effort over non-specific claims of irresponsible behavior, though Kamler claims that the recall is over his age (he is 28). Petitioners need 332 signatures by September 16.

Idaho: Three Middleton School Board members facing August 27 recall vote

The recall against Middleton School Board Members Tim Winkle, Marianne Blackwell and Alicia McConkie will be on the ballot in a special election on August 27.

The recall is over a vote not to renew the High School principal's contact. The principal has accused school administrators of harassing him. A fourth member, Kirk Adams, is facing threats, but due to his recent election, is not eligible for a recall until the November election. For the recall to succeed, the vote to remove must exceed the amount of votes the candidate received when they won the office in the last election.

North Dakota: Morton Township Supervisor and Clerk/Treasurer survived recall vote

Morton Township Supervisor Daymon Mill (30-26) and Clerk/Treasurer Mary Malard (29-27) survived recall votes on Tuesday. The recall's were their vote in favor of a wind farm. There have been other recalls in Michigan over wind farm votes.

There is a separate challenge her, as it is unclear how to have a recall of a township official. The Township elections take place in a township meeting and there is no early voting or absentee ballots.

Wednesday, August 21, 2019

Alaska: Governor rolls back most of spending cuts; still facing recall effort

Governor Mike Dunleavy (R) is still facing a recall effort after he signed a budget which got rid of many of his spending cuts aimed at the University of Alaska. Dunleavy refused to restore funding to a health program.

Colorado: Estes Park Mayor Pro Tem kicked out in recall vote

Mayor Pro Tem Cody Walker was kicked out in a special election recall vote on Tuesday, losing 1298-882. Eric Blackhurst, a former Trustee, won the replacement race with 1133 votes.

The issue was a change in the code in 2017 to allow commercial activity in a downtown park, which "inadvertently allowed commercial ventures almost anywhere in town or in the Estes Valley."

California: Simi Valley City Council member facing petitions over allegedly false statement of ICE raid

Simi Valley City Council member Ruth Luevanos is facing a recall effort and a censure vote after she claimed that there was a federal ICE agents raid at a supermarket.

North Dakota: Morton Township Supervisor and Clerk/Treasurer facing petitions over windfarm issue

Morton Township Supervisor Daymon Mill and Clerk/Treasurer Mary Malard are facing petitions over a kitchen sink of complaints, but the main one was a vote in favor of a wind farm. There have been other recalls in Michigan over wind farm votes.

There is a separate challenge her, as it is unclear how to have a recall of a township official. The Township elections take place in a township meeting and there is no early voting or absentee ballots.

Tuesday, August 20, 2019

California: Buena Park City Councilwoman facing petitions over sign stealing

Buena Park City Councilwoman Youngsun "Sunny" Park (D) is facing petitions after being charged with allegedly stealing campaign signs that attacked her. Park beat Virginia Vaughn (R), the incumbent mayor, by 16 votes -- 1560-1544.

Petitioners need somewhere in the order of 1875 signatures by October 9 to get on the ballot.

Colorado: Petitions approved against State Senate President

State Senate President Leroy Garcia is now facing petitions, which were just approved by the Secretary of State.

Arizona: Four Payson council members face petitions

Payson Mayor Tom Morrisey, Vice Mayor Janell Sterner and Councilors Jim Ferris and Suzy Tubbs-Avakian are facing petitions over the 4-3 vote to fire the Town Manager (and other complaints). Petitioners need 770 signatures for the mayor and 1653 for the other council members -- the discrepancy is not clear from the article, but it must be due to turnout of some sort.

One of the lead petitioners is Stan Garner, who is the widow of former Councilor Su Connell.  

Maine: Signatures handed in against Four Mechanic Falls Councilors over Town Manager firing

Signatures have been handed in for Mechanic Falls Council Chair Cathy Fifield (242), Vice Chair Wayne Hackett (248) and Councilors Nicholas Konstantoulakis (231) and John Emery (224) over the recent 4-1 vote to dismiss Town Manager Zakk Maher in what is alleged to be a violation of the Open Meeting Act.

Petitioners need at least 192 signatures in 30 days (15% of gubernatorial turnout). There is a "absentee veto" provision, where the total votes in the recall must be at least 30% of the those cast in the 2018 gubernatorial election.

Friday, August 16, 2019

Alaska: Petitioners claim over 29,000 signatures collected against Governor

Petitioners claim to have gathered 29,577 signatures for the recall of Governor Mike Dunleavy (R), which is more than the 28501 needed to move pass the first stage of the recall. Of course, they will almost certainly need a larger cushion to top the verification process.

Petitioners need to first get the 28,501 signatures before the Division of Elections will consider if they meet the petitions meet the state's malfeasance standards. Then they would need an additional 71,252 signatures to get to the ballot.

Alaska is a malfeasance standard/judicial recall state, so a showing of cause is needed (though the state courts has taken a lenient view of the the cause requirement in past instances).

North Dakota: Surrey Mayor resigns in the face of recall effort; Signatures being collected against Council President

Surrey Mayor Jason Strand has resigned in the face of a recall and Council President and Acting Mayor Karla Walsh is still recall effort over complaints of employee turnover. There has also been threats to recall Council Member Rodney Hjelden, but because his term ends within the year, he is not eligible.

Colorado: Nederland Mayor, two Trustees facing petitions

Nederland Mayor Kristopher Larson and Trustees Dallas Masters and Julie Gustafson are facing petitions over claims of "dereliction of duty." A regular town critic who is actually lives outside the town is one of the leaders of the effort. The complaints seems to be a kitchen sink effort, including complaints about Nederland's growth and lifting a moratorium on cannabis dispensaries. Petitioners need 58 signatures for Larson and 47 for the other two.

Thursday, August 15, 2019

Nebraska: Plattsmouth Mayor recall effort fails

The recall against Mayor Paul Lambert failed, with petitioners handling in 200 signatures. They needed 538 in 30 days. The recall was after city workers threw out items left on or near gravestones. Petitioners are claiming that there was a lack of communication before the clean-up.

Rhode Island: Tiverton Council President, Vice President recall voted to be scheduled for October 10

Signatures were verified against Tiverton Council President Robert Coulter and Vice President Justin Katz over complaints about an executive session at meetings. The council approved a vote for October 10. The lead petitioner, William McLaughlin, lost as a council candidate in November.

Petitioner got 625 signatures for Katz (they needed 587) and 553 for Coulter (needed 505).

The town has an absentee veto provision. The turnout has to exceed the amount of votes each got in the last election for the recall to count (though unlike Idaho, the amount voting yes does not have to top the previous election's numbers).

Wednesday, August 14, 2019

Newsweek Op-ed on the Recall Moves against Governors

Here's an op-ed I wrote for Newsweek on the moves against Governors throughout the country, especially the unusual fact that many of the efforts are being led by the Republican leadership in the states. I intend to write a full "state of play" post later on.

Colorado: State Supreme Court turns down effort to stop Cripple Creek-Victory School District Board Member recall; Set for November 5

The State Supreme Court has turned down a request from Cripple Creek-Victory School Board President Tim Braun to end the recall effort against him. The article describes the decision as almost "apologetic" over the delay, which has led the recall to be moved from an original target of July 16 to November 5.

Two other board members, treasurer Dennis Jones and secretary Tonya Martin resigned in the face of the recall.

The recall is over claims of violation of the open record act and possibly a suspension of the superintendent. One of the leader was a former Head Start director who lost to Jones by 30 votes in November 2017.

Nebraska: Signatures handed in against two Antelope Commissioners

Signatures were handed in to get the recalls of Antelope Commissioners Tom Borer and Allan Bentley on the ballot, though they need to be verified. The recall is over claims of mismanagement of funds. Petitioners need 203 signatures for Borer and 135 signatures for Bentley (35% of turnout) in 30 days.

Northern Arapaho Tribal Chairman facing recall efforts

Northern Arapaho Tribal Chairman Lee Spoonhunter is facing a recall effort over issues over the casino and the use of advisors and law firms.

Monday, August 12, 2019

Colorado: Brighton Mayor will face recall -- Recall to take place on Election Day

Brighton Mayor Ken Kreutzer will be on the recall ballot over the firing of the City Manager. The City Manager was allegedly fired because he uncovered $70 million in unused water money. No word yet on when the recall will take place -- it may wait until Election Day in November.

Petitioners handed in 1782 signatures, they needed 1136 signatures.

Friday, August 9, 2019

Louisiana: Jefferson Parish President who faced recall efforts won't run for reelection

Jefferson Parish President Mike Yenni, who was the subject of a prominent recall effort after he was accused of sexting with a 17-year old high school student (this was back when he was Kenner's mayor), has announced he won't run for reelection.

Thursday, August 8, 2019

Alaska: Petitioners claim 18,000 signatures collected against Governor after first week

Governor Mike Dunleavy (R) is the target recall effort, with petitioners claiming to have 18000 signatures after the first week.

Alaska is a malfeasance standard/judicial recall state, so a showing of cause is needed (though the state courts has taken a lenient view of the the cause requirement in past instances).

Petitioners need to first get 28,501 signatures before the Division of Elections will consider if they meet the malfeasance standards. Then they would need 71,252 signatures to get to the ballot.

Wednesday, August 7, 2019

California: Second recall effort targeting Governor by former Senate candidate

A second attempt has been filed to recall Governor Gavin Newsom (D), this time by Erin Cruz, who came in sixth in the US Senate primary in 2018.  The recall effort mimics an early one set up by Dr. James Veltmeyer, who lost the Republican primary for a Congressional seat in 2018. The petitions seems to be focused on immigration issues, though there are also claims of capital punishment and the cost of the state wildfires and "medicare for all." There is also a preexisting online petition led by someone else that has 42,000 signers, of which exactly zero would count to a real petition.

Petitioners would need about 1.5 million signatures to get on the ballot.

Oregon: New debate over who would actually replace Governor in case of recall removal

Oregon is now having a debate about its gubernatorial replacement law. Bill Currier, the chairman of the State Republican Party, has filed recall papers against Governor Kate Brown (D). Another petition was also filed by a local resident, focusing on homeless issues.

What is perhaps most noteworthy is that Oregon's recall law does not provide for the immediate election of a replacement. Replacements are instead "filed immediately in the manner provided by law for filing a vacancy in that office arising from any other cause." A special election replacement race would take place on Election Day, 2020.

For Oregon, that would seem to mean that Secretary of State Beverly Clarno (R), an 83-year old former Speaker of the State House of Representatives, who was recently appointed after the death of her predecessor, would  automatically become Governor. Clarno was appointed by Brown herself.

However, Oregon law also appears to disallow the replacement by an appointed official. Under this interpretation, which is supported by Clarno, the replacement would be State Treasurer Tobias Read (D). The recall backers claim this is incorrect, though this article seems to be basing it on a tortured understanding of the use of the term "acting Secretary." Regardless, Clarno could herself resign, resulting in Read taking the position.

This no-vote provision is fairly common on the local level. However, it is relatively rare on the state level. I believe Idaho has a similar provision. State lawmakers appointed for a vacancy must be of the same party. In the wake of a 2011 state House recall and the 2012 Wisconsin recalls next door, Michigan changed its law so that the Governor  would be replaced by the next in line (i.e., the Lieutenant Governor), thereby short circuiting any recall push.

The recall was filed on the first possible day (after Brown had been in office six months). Petitioners would need 280,050 in 90 days. 

Oregon, the first state to adopt the recall for state-level officials way back in 1908, has had recalls against three state legislators, but never a Governor. Brown actually got the job when her predecessor John Kitzhaber face a recall threat.


Tuesday, August 6, 2019

New Jersey: Great article on New Jersey's use of the recall law

This article by Terrence McDonald in the Record gives some good history to the use of the recall in New Jersey, going back before the 1993 passage of the statewide recall law. It takes as its jumping off point the Englewood Cliffs recall attempt.

Among the highlights:

1. North Bergen Mayor Peter Mocco lost a recall in 1978 and was reelected to his seat in the same ballot.

2. Stafford Mayor Wesley Bell was recalled in 1983, a decision that was tossed out by an appellate court, which was overturned by the State Supreme Court.

3. Wildwood Mayor Ernie Troiano lost a recall in 2009 and won back his office in May 2011. He is still mayor.

4. Mahwah Mayor John Laforet was removed in 2018.

Texas: Mineral Wells City Council member facing recall threats

Mayor Christopher Perricone is facing a recall effort. Petitioners need over 1800 signatures by August 30  to get on the ballot

Alaska: Recall petitions taken out against Governor

Petitions have now been taken out against Governor Mike Dunleavy (R), with over 10,000 signatures collected on the first day.

Dunleavy announced major spending cuts.

Alaska is a malfeasance standard/judicial recall state, so a showing of cause is needed (though the state courts has taken a lenient view of the the cause requirement in past instances).

Petitioners need to first get 28,501 signatures before the Division of Elections will consider if they meet the malfeasance standards. Then they would need 71,252 signatures to get to the ballot.

Michigan: Wind Farm projects leads to recall threats in Casnovia Township

Three Casnovia Township officials, Clerk Jennie Powell, Treasurer Gayle Brock and Trustee Dan Winell, are facing recall attempts on their vote to approve wind farms.

Wisconsin: Merrill Alderman resigns after surviving a previous recall

Merrill Alderman Dave Sukow, who was one of four alderman survived a recall vote in July, resigned. There was no reason given in the article.

Friday, August 2, 2019

UK: Liberal Democrats win Brecon & Radnor MP Seat in recall triumph; Conservative MP ousted

Liberal Democrat Party Leader Jane Dobbs won the by-election for the Seat in Brecon and Radnor, toppling, Conservative Party MP Chris Davies, who was removed in a recall and was the Conservative candidate to replacement himself. Dobbs won 13826 to 12401, with the Brexit Party gaining 331 and Labour coming in fourth, with a drop of 12.4%. Turnout was 60%.

Davies was removed after 10,005 signatures were handed in (petitioners needed 5303 (10% of voters) to get on the ballot.

Davies was fined 1500 pounds and hit with 50 hours of community service over two false expense invoices for landscape photographs. Since the sentence was under 12 months, he is not automatically ousted.

This was the second recall removal this year. Labour MP Fiona Onasanya was ousted and replaced by a Labour MP in June.