Citizenship and the 2020 Census

John Christie • February 7, 2019

On January 15, 2019, Judge Jesse Furman, a federal district court judge in New York, issued a 277-page opinion overruling the decision of the Secretary of Commerce, Wilbur Ross, to add a citizenship question to the 2020 census. The decision followed a five-month discovery process, an eight-day trial, extensive post-trial briefing, and closing arguments. Based upon the evidence before him, Judge Furman concluded that Secretary Ross violated both the law and the public trust.

Unfortunately given today’s constantly cascading news cycles, the decision itself and the story of how Secretary Ross’ decision came to be made and its implications for the 2020 census were largely lost on the public. However, as told by Judge Furman’s own extensive findings of fact and law, the story deserves much greater attention as it demonstrates how the public interest can be potentially subverted by efforts founded on political goals rather than good government.

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The Constitution mandates that an “actual Enumeration” be conducted “every . . . ten Years, in such Manner as [Congress] shall by Law direct,” an effort now commonly known as the census, or, more precisely, the decennial census. (Art. I, § 2, cl. 3.) By its terms, every ten years the federal government must endeavor to count every single person residing in the United States, whether citizen or non-citizen, whether living here with legal status or without.

The original purpose of this “Enumeration” was to apportion congressional representatives among the states “according to their respective Numbers.” Today, however, its impact is far greater. Among other things, the census count affects the allocation of electors to the Electoral College, the division of congressional electoral districts within each State, and the apportionment of state and local legislative seats. The census results also directly control the distribution of hundreds of billions of dollars of federal funding each year to both States and localities. It is for all of these reasons that the census has been described by Congress itself as “one of the most critical constitutional functions our Federal Government performs.”

Congress has assigned its constitutional duty to conduct the census to the Secretary of Commerce and the Census Bureau, today a part of the Commerce Department. The Secretary’s fundamental obligation is to obtain a total-population count that is as accurate as possible, consistent with the Constitution and the law. The Bureau conducts the required enumeration principally by sending a short form questionnaire to every household.

The questions posed on the short form census have ebbed and flowed since the first census in 1790 asked each household about “the sexes and colours of free persons,” as well the age of each resident. Most relevant here, a question regarding citizenship appeared for the first time on the fourth census in 1820, when Congress directed enumerators to tally the number of “Foreigners not naturalized.” With one unexplained exception (the 1840 census), a question about citizenship status or birthplace appeared on every census thereafter through 1950.

That changed in the 1960 census. That year, only five questions were posed to all respondents, concerning the respondent’s relationship to the head of household, sex, color or race, marital status, and month and year of birth. In a review of that census several years later, the Census Bureau explained the decision not to ask all respondents about citizenship as follows: “It was felt that general census information on citizenship had become of less importance compared with other possible questions to be included in the census.”

Beginning in 1960, the decennial census questionnaire sent to every household has not included any question related to citizenship status. In both Republican and Democratic administrations, the Census Bureau has vigorously opposed adding any such question because of its concern that doing so would depress response rates, including those of non-citizens and immigrants, thereby undermining the accuracy of the headcount. The Bureau concluded that questions designed “to ascertain citizenship will inevitably jeopardize the overall accuracy of the population count” because such questions “are particularly sensitive in minority communities and would inevitably trigger hostility, resentment and refusal to cooperate.” Census Bureau directors appointed by presidents of both political parties have agreed. (See Endnote 1.)

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In March 2018, Secretary Ross announced that he had decided to add a citizenship question to the 2020 census short questionnaire. In a memorandum announcing this decision, Secretary Ross stated that he only “began” considering adding a citizenship question after receiving a letter from the Department of Justice, dated December 12, 2017, requesting citizenship data from the census in order to enforce the Voting Rights Act (VRA). The Secretary reiterated in subsequent congressional testimony that the citizenship question on the 2020 short form census “is necessary to provide complete and accurate data in response to the DOJ request.” And the Secretary also stated that he was “not aware” of any discussions between himself and any White House officials about the citizenship question.

Eight days after Secretary Ross’s March 26, 2018 memorandum announcing his decision, a case challenging the decision was filed by a coalition of governmental entities, including 18 states (Maryland being one of them), the District of Columbia, and 15 cities and counties. These governmental entities all alleged that Secretary Ross’s decision to include a citizenship question violated the Administrative Procedure Act (APA). The APA “sets forth the procedures by which federal agencies are accountable to the public and their actions subject to review by the courts.” (See Endnote 2.)

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According to Judge Furman, the evidence disclosed at trial revealed that Secretary Ross’s description of the citizenship decision was “materially inaccurate.” In fact, “a very different set of events” had occurred as described in painstaking detail in his opinion.

In particular, the evidence showed that shortly after his confirmation as Secretary of Commerce, Secretary Ross discussed the addition of the citizenship question with then-White House advisor Steve Bannon, among others; that Secretary Ross wanted to add the question to the 2020 census prior to, and independent of, the DOJ’s December 12, 2017 request; that the Secretary and his political aides pursued that goal vigorously for almost a year, with no apparent interest in promoting more robust enforcement of the VRA. Then, after becoming convinced that they needed another agency to request and justify a need for the question, Secretary Ross and his political aides worked hard to generate such a request for the citizenship question from both the Department of Homeland Security and the DOJ. Frustrated at the delay in the receipt of an affirmative response from DOJ, Secretary Ross directly intervened by a phone conversation with Attorney General Sessions which resulted in the DOJ’s request for a citizenship question. In setting up the phone call, an aide to Sessions emailed Ross’ chief of staff saying that “it sounds as if we can do whatever you need us to do. The AG is eager to assist.”

Based upon trial testimony and documentary evidence, Judge Furman held “while the Court is unable to determine—based on the existing record, at least—what Secretary Ross’s real reasons for adding the citizenship question were, it does find, by a preponderance of the evidence, that promoting enforcement of the VRA was not his real reason for the decision.” (See Endnote 3.) Secretary Ross and his political aides aimed to “launder” their request through another agency—that is, to obtain cover for a decision that they had already made—and the reasons underlying any request from another agency were “secondary, if not irrelevant.”

The trial record also revealed that Secretary Ross’s decision had been made in contravention of the Census Bureau’s long-held opposition to such a question, which continued. Following the receipt of the DOJ letter, the Census Bureau, including the Bureau’s Chief Scientist, concluded that adding the question would “harm the quality of the census count” by “reducing the self-response rate,” thereby increasing the Bureau’s costs and harming the overall data and integrity of the census.

Judge Furman concluded that the evidence in the trial record “overwhelmingly” supported the conclusion that the addition of a citizenship question to the 2020 census would cause a significant net differential decline in self-response rates among households with at least one non-citizen and that the Bureau’s follow-up procedures aimed at non-responding households would fail to cure that decline. More specifically, he found that the addition of a citizenship question to the 2020 census would cause an incremental net differential decline in self-responses among non-citizen households of at least 5.8%. He further opined that that estimate is “conservative and that the net differential decline could be much higher.” The implementation of the Bureau’s follow-up procedures for non-responding households would simply replicate all of the same effects on non-citizen response that will cause the decline in self-response in the first place.

On the merits, Judge Furman determined that Secretary Ross had violated the APA in multiple independent ways—“a veritable smorgasbord of classic, clear-cut APA violations.” Secretary Ross’s decision to add a citizenship question was “arbitrary and capricious” on its own terms. He failed to consider several important aspects of the problem; alternately ignored, cherry-picked, or badly misconstrued the evidence in the record before him; acted irrationally both in light of that evidence and his own stated decisional criteria; and failed to justify significant departures from past policies and practices. Finally, the evidence establishes that Secretary Ross’s stated rationale—to promote VRA enforcement—was just a pretext. In other words, that he announced his decision in a manner that concealed its true basis rather than explaining it, as the APA required him to do.

As further described by Judge Furman, “these violations are no mere trifles.” The fair and orderly administration of the census is one of the Secretary of Commerce’s most important duties, and it is critical that the public have “confidence in the integrity of the process.” (See Endnote 4.)

It should also be noted that four former Census Bureau Directors opposed the addition of a citizenship question. They and two other former Directors wrote to Secretary Ross to express “deep concern” about the addition of such a question. In addition, five of the six former Directors filed an amicus brief in support of Plaintiffs in these cases and the sixth, John Thompson, testified as an expert witness on Plaintiffs’ behalf.

The current professionals in the Census Bureau also concluded that the DOJ’s stated interest in having more granular citizenship data could be satisfied in a less costly, more effective and less harmful manner. The evidence reveals that at the express direction of Attorney General Sessions, DOJ deliberately (and unusually) refused to meet with representatives of the Census Bureau to discuss the Census Bureau’s conclusion.

Appeals from Judge Furman’s decision by the Department of Justice have already been made to both the Second Circuit Court of Appeals and to the Supreme Court. In fact, the Solicitor General has urged the Supreme Court to resolve the appeal prior to any judgment of the Second Circuit, which would ordinarily rule before the Supreme Court. As a result, although the opinion of Judge Furman is an important chapter in this significant dispute, it is obviously not yet likely the last chapter. These appeals to Judge Furman’s decision against including a citizenship question will need to be resolved soon as the 2020 census is now less than a year away.


Endnotes:


  1. The Bureau has recently requested citizenship information through other means besides the decennial census questionnaire. However, such requests have gone to a limited number of individuals and thus have not raised the same concerns as does adding a citizenship question to the decennial census. Until 2000, the Bureau requested such information through a “long-form” census questionnaire—a list of questions sent each decade to just one of every six households. In 2005, the Bureau replaced the long-form questionnaire with the American Community Survey (ACS), which contains more than forty-five questions and is sent annually to only one of every thirty-six households.
  2. Challenges to Secretary Ross’ decision also have been brought in four other cases in federal district courts in California and Maryland. Bench trials are ongoing in all four cases as this is being written.
  3. The DOJ vigorously opposed Judge’s Furman’s order allowing a deposition of Secretary Ross up to the Supreme Court which suspended the deposition until after briefs and oral argument on the issue. In light of the opinion of Judge Furman on the merits, the issue involving the deposition became moot.
  4. Although not directly relevant to Judge Furman’s ultimate opinion, it is worthy to note the unusual extent to which the Department of Justice endeavored to prevent or delay a decision on the merits of this issue. As Judge Furman noted, the defendants “tried mightily” to avoid a ruling. They asserted a slew of unsuccessful jurisdictional arguments, raised multiple challenges to this Court’s decisions authorizing discovery beyond the administrative record and tried no fewer than fourteen times to halt the proceedings altogether. Fortunately for the rule of law, these tactics failed to prevent the court from reaching the result described herein.


Common Sense for the Eastern Shore

“Give me your tired, your poor, your huddled masses yearning to be free”

By John Christie • February 17, 2026
These are the words from Emma Lazarus’ famous 1883 sonnet “The New Colossus” inscribed on a bronze plaque on the pedestal of the Statue of Liberty. In 1990, Congress reaffirmed this vision of America by establishing the Temporary Protected Status program. TPS is designed to provide humanitarian relief to foreign nationals in the United States who come from disaster-stricken countries. In its present form, the TPS legislation gives the Secretary of the Department of Homeland Security responsibility for the program. However, the legislation prescribes the kind of country conditions severe enough to warrant a designation under the statute, the specific time frame for any such designation, and the process for periodic review of a TPS designation which could culminate in termination or extension. All initial TPS designations last from six to eighteen months. Before the expiration of a designation, the statute mandates that the Secretary shall review the conditions in the foreign state to decide if the conditions for the designation continue to be met, following consultation with appropriate agencies of the government. Extension is the default; the designation “shall be extended” unless the secretary affirmatively determines that conditions are “no longer met.” ------------------------------------------------------------- A massive earthquake devastated Haiti in January 2010, and precipitated an unprecedented humanitarian crisis. Shortly after, then-DHS Secretary Janet Napolitano, after consultation with the State Department, designated Haiti for TPS due to “extraordinary conditions.” Haitian nationals in the United States continuously as of January 12, 2010, could thus apply for TPS, and obtained the right to remain and work in the U.S. while Haiti maintained its TPS designation. Napolitano set the initial TPS designation for 18 months. As Haiti’s deterioration worsened, successive DHS secretaries have extended this program. Gang violence and kidnappings have spiked. In 2021, a group of assailants killed Haiti’s then-President Jovenel Moìˆse. In 2023, another catastrophic earthquake hit Haiti. In 2024, in response to these conditions, then-DHS Secretary Alejandro Mayorkas once again extended and redesignated Haiti for TPS, this time effective through February 3, 2026. During the 2024 election cycle, the GOP candidate, Donald Trump clearly indicated that time had not tempered his views on Haiti, characterized by him as a “shithole country” during his first term. He stated that when elected, he would “absolutely revoke” Haiti’s TPS designation and send “them back to their country.” On December 1, 2025, Kristi Noem, DHS secretary in the second Trump administration, announced, “I just met with the president. I am recommending a full travel ban on every damn country that’s been flooding our nation with killers, leeches, and entitlement junkies. Our forefathers built this nation on blood, sweat, and the unyielding love of freedom, not for foreign invaders to slaughter our heroes, suck dry our hard-earned tax dollars, or snatch the benefits owned to Americans. We don’t want them, not one.” So says the official responsible for overseeing the TPS program. And one of those (her word) “damn” countries is Haiti. Three days before making the above post, Secretary Noem announced she would terminate Haiti’s TPS designation as of February 3, 2026. Five Haitian TPS holders filed suit in federal court in Washington initially seeking an injunction against the termination of the Haitian TPS program pending the completion of the litigation. These plaintiff TPS holders are not “killers, leeches, or entitlement junkies.” They are instead a neuroscientist researching Alzheimer’s disease, a software engineer at a national bank, a laboratory assistant in a toxicology department, a college economics major, and a full-time registered nurse. The case was assigned to district court judge Ana Reyes who granted the plaintiffs’ injunction request on February 2, 2026, by way of an 83-page opinion. The plaintiffs charge that Secretary Noem preordained her termination decision because of hostility to non-white immigrants. According to Judge Reyes, “This seems substantially likely. Secretary Noem has terminated every TPS country designation to have reached her desk — twelve countries up, twelve countries down.” Judge Reyes also decided that Noem’s conclusion that Haiti (a majority non-white country) faces only “merely concerning” conditions cannot be squared with the “perfect storm” of “suffering and staggering” humanitarian toll described in page after page of the record in the case. In Judge Reyes’ view, Noem also ignored Congress’s requirement that she review the conditions in Haiti “after consulting with appropriate agencies.” Indeed, the record indicates she did not consult other agencies at all. Her “national interest” analysis focuses on Haitians outside the United States or here illegally, ignoring that Haitian TPS holders already live here and legally so. And though Noem states that the analysis must include “economic considerations,” Judge Reyes concluded Noem ignored altogether the billions that Haitian TPS holders contribute to the economy. The administration’s primary response in the litigation has been to assert that the TPS statute gives Secretary Noem “unbounded” discretion to make whatever determination she wants, any way she wants. Yes, Judge Reyes acknowledges, the statute does grant Noem some discretion. But, in Judge Reyes’ opinion, “not unbounded discretion.” To the contrary, Congress passed the TPS statute to standardize the then ad hoc temporary protection system; in Judge Reyes’ words, "to replace executive whim with statutory predictability.” The administration also argued that the harms to Haitian TPS holders were “speculative” if they are forced to return to Haiti. Because the State Department presently warns, “Do not travel to Haiti for any reason,” the administration asserts that harm is “speculative” only because DHS “might not” remove them. However, according to Judge Reyes, this argument fails to take Secretary Noem at her word: “We don’t want them. Not one.” The public interest also favors the injunction, in the opinion of Judge Reyes. Secretary Noem complains of the strains that unlawful immigrants place on our immigration-enforcement system. Noem’s answer is to turn 352,959 lawful TPS Haitian immigrants into unlawful immigrants overnight. Noem complains of strains to our economy; her answer is to turn employed lawful immigrants who contribute billions in taxes into the legally unemployable. Noem complains of strains to our health care system. Noem’s answer is to turn the insured into the uninsured. “This approach is many things – but the public interest is not one of them,” according to Judge Reyes. The opinion of Judge Reyes concludes: “Kristi Noem has a First Amendment right to call immigrants killers, leeches, entitlement junkies, and any other inapt name she wants. Secretary Noem, however, is constrained by both our Constitution and the law to apply faithfully the facts to the law in implementing the TPS program. The record to-date shows she has yet to do that. The administration has already appealed. John Christie was for many years a senior partner in a large Washington, D.C. law firm. He specialized in anti-trust litigation and developed a keen interest in the U.S. Supreme Court about which he lectures and writes.

Gov. Moore Signs Legislation to Prohibit Md. Jurisdictions from Deputizing Officers for Federal Civil Immigration Enforcement

By Office of the Governor • February 16, 2026
Gov. Wes Moore signed legislation on February 17, 2026, to prohibit State and local jurisdictions from deputizing officers for federal civil immigration enforcement activity. The law, created under SB 245/HB 444 , is effective immediately. “In Maryland, we defend Constitutional rights and Constitutional policing — and we will not allow untrained, unqualified, and unaccountable ICE agents to deputize our law enforcement officers,” Moore said. “This bill draws a clear line: we will continue to work with federal partners to hold violent offenders accountable, but we refuse to blur the lines between state and federal authority in ways that undermine the trust between law enforcement and the communities they serve. Maryland is a community of immigrants, and that's one of our greatest strengths because this country is incomplete without each and every one of us.” “As an immigrant, this bill is deeply personal to me,” said Lt. Gov. Aruna Miller. “Immigrants make Maryland stronger every day, and our communities are safer when everyone feels protected and valued. This legislation ensures that our law enforcement resources remain focused on keeping Marylanders safe, not on actions that create fear in our neighborhoods. I thank the bill sponsors and Governor Moore for their leadership in ensuring Maryland remains a place where dignity and opportunity go hand in hand.” U.S. Department of Homeland Security Immigration and Customs Enforcement, also known as ICE, established its 287(g) program to authorize local law enforcement officials to perform federal civil immigration enforcement functions under ICE’s oversight. Under SB 245/HB 444, State and local jurisdictions in Maryland are prohibited from engaging in such agreements. Any local jurisdictions with standing 287(g) agreements must terminate them immediately. The legislation does not: Authorize the release of criminals Impact State policies and practices in response to immigration detainers that are issued by the U.S. Department of Homeland Security Prevent the State or local jurisdictions from continuing to work with the federal government on shared public safety priorities, including the removal of violent criminals who pose a risk to public safety Prevent State or local jurisdictions from continuing to notify ICE about the impending release of an individual of interest from custody or from coordinating the safe transfer of custody within constitutional limits State and local law enforcement will also maintain the ability to work with the federal government on criminal investigations and joint task forces unrelated to civil immigration enforcement. Any individual who is charged with a crime is entitled to due process and, if convicted, must serve their sentence.

Farmers Now Owe a Lot More for Health Insurance

By Sarah Boden and Drew Hawkins, Gulf States Newsroom • February 16, 2026
And now, the enhanced Affordable Care Act subsidies that many Americans, including farmers, relied on to purchase health insurance are gone, having expired at the end of December.

It’s Not Your Grandfather’s Department of Justice

By John Christie • December 16, 2025
When I practiced law, much of my litigation involved issues arising under federal antitrust laws. The Department of Justice (DOJ) was my frequent adversary in court. In some cases, DOJ challenged a client’s conduct as anticompetitive. In others, they claimed an intended client merger would create a monopoly. Some of these DOJ court battles were won, others were not. Overall, I had great respect for DOJ lawyers. They were professional, well prepared, and dedicated to their mission of seeing justice done. They were courteous, honest, and forthright with the courts before which we argued our cases. In those days, without resorting to social media or press conferences, the DOJ spoke entirely through its court filings. Although as an advocate I took issue with various DOJ investigatory decisions as well as decisions to initiate litigation, I never thought politics was involved. Post-Watergate internal rules strictly limited communication with any figures at the White House. Not so, it seems, anymore. Beginning last January 20, all of this changed rapidly and spectacularly . On March 14, Trump triumphantly arrived at the main DOJ building in D.C. to be welcomed by a group of carefully selected VIPs. He was greeted by Pam Bondi, his chosen new attorney general, who exclaimed, “We are so proud to work at the directive (sic) of Donald Trump.” Bondi’s boast that the DOJ now worked at the president’s behest was something never said before and, in effect, surrendered the department’s long and proud independence. And Bondi’s comment was not an empty gesture. As chronicled by reporters Carol Leonnig and Aaron Davis in their new book, Injustice: How Politics and Fear Vanquished America’s Justice Department , within hours of being sworn in, Trump and his lieutenants began punishing those at the Justice Department who had investigated him or those he considered his political enemies. Career attorneys with years of experience under many administrations were fired or reassigned to lesser work, or they resigned. As Leonnig and Davis report, what followed was “the wholesale overthrow of the Justice Department as Trump insert[ed] his dutiful former defense attorneys and 2020 election deniers atop the department.” [Source: Injustice , p. xix.] In the place of years of experience, the new team appears credentialed simply by loyalty to the president’s causes. The DOJ’s conduct in court has since caused damage to judicial and public faith in the integrity and competence of the department. Just Security is an independent, non-partisan, daily digital law and policy journal housed in the Reiss Center on Law and Security at the New York University School of Law. Since January 20, it has documented federal judicial concerns about DOJ conduct. In 26 cases, judges raised questions about DOJ non-compliance with judicial orders and in more than 60 cases, judges expressed distrust of government-provided information and representations. This count was taken the day after a federal court dismissed the DOJ cases against former FBI Director James Comey and New York Attorney General Letitia James. [Source: Just Security , “The ‘Presumption of Regularity’ in Trump Administration Litigation,” Nov. 20, 2025.] As summarized by the Georgetown Law Center’s Steve Vladeck, “It’s one thing for the Department of Justice to so transparently pursue a politically motivated prosecution. But this one has been beset from the get-go with errors that remotely competent law students wouldn’t make. Indeed, it seems a virtual certainty that the Keystone Kops-like behavior of the relevant government lawyers can be traced directly to the political pressure to bring this case; there’s a reason why no prosecutors with more experience, competence, or integrity were willing to take it on.” [Source: One First , Nov. 24, 2025.] Rather than accept criticism and instead of trying to do better, Bondi’s DOJ and the Trump administration lash out in a fashion apparently aimed at demeaning the federal judiciary. At a recent Federalist Society’s National Lawyers Convention, Deputy Attorney General Todd Blanche, one of Trump’s former defense attorneys, attributed the Trump administration’s myriad losses in the lower federal courts to “rogue activist judges.” He added, “There’s a group of judges that are repeat players, and that’s obviously not by happenstance, that’s intentional, and it’s a war, man.” Deputy Chief of Staff Stephen Miller decries each adverse ruling against the Trump administration as just part of a broader “judicial insurrection.” Not to be left behind, Trump himself regularly complains of “radical left lunatic” judges. In addition to the harm these comments inflict on the federal courts, their premise is simply not true. According to a survey by Vladeck, as of Nov. 14, there were 204 cases in which federal district courts have ruled on requests for preliminary relief against the Trump administration. In 154 of them, district judges granted either a temporary restraining order, a preliminary injunction, or both. Those 154 rulings came from 121 district judges appointed by seven presidents (including President Trump) in 29 district courts. In the 154 cases with rulings adverse to the Trump administration, 41 were presided over by 30 Republican-appointed judges, fully half of whom were appointed by President Trump. No, it is no longer your grandfather’s Department of Justice. John Christie was for many years a senior partner in a large Washington, D.C. law firm. He specialized in anti-trust litigation and developed a keen interest in the U.S. Supreme Court about which he lectures and writes.

Salisbury City Council Appoints Melissa Holland to Fill District 2 Seat

By CSES Staff • December 16, 2025
The Salisbury City Council has appointed longtime public servant Melissa D. Holland to fill the vacancy in District 2. Holland was selected on Dec. 1 after the council reviewed several applicants. A 27-year resident of Salisbury, Holland brings more than 20 years of experience in government, education, and administration. As executive assistant to the president of the University of Maryland Center for Environmental Science, she currently oversees operations, budgeting, communications, and planning. Before joining UMCES, Holland worked for nearly 11 years with the Wicomico County Council, gaining extensive experience in legislative procedure, constituent services, research, and budget preparation. Her background includes positions with the Wicomico County Board of Education, the State of Maryland’s Holly Center, and multiple early-learning programs. Approved by a 3-1 council vote, Holland was selected based on her administrative expertise and long-standing community involvement. (Salisbury’s City Council is now comprised of only women.) She has a bachelor’s degree in legal studies from Post University and an associate degree from Wor-Wic Community College. She has also served as PTA president at East Salisbury Elementary and Wicomico Middle School. In her application, Holland emphasized her commitment to maintaining transparency in city government and ensuring that District 2 residents remain informed and represented. “I plan to be well-informed on the issues that matter to the citizens of Salisbury and to listen to their concerns carefully,” she wrote. “I want to make a positive and lasting impact on our city.” Holland’s appointment restores the City Council to full membership as it faces debates over budgeting, infrastructure planning, and local governance initiatives. She is expected to begin constituent outreach immediately and participate fully in the selection of the next council president.

Democrats Ambushed in Hurlock Election

By CSES Staff • November 4, 2025
Voters in Hurlock have delivered sweeping changes in this year’s municipal election, as Republican and GOP-aligned candidates won key races there. The results mark a setback for Democrats and a significant political shift in a community that has historically leaned Democratic in state and federal contests. The outcome underscores how local organizing and turnout strategies can have an outsized impact in small-town elections. Analysts also suggest that long-term party engagement in municipal contests could shape voter alignment in future county and state races. Political analysts warn that ignoring municipal elections and ceding them to the GOP could hurt the Maryland Democratic Party in statewide politics. Turnout increased by approximately 17% compared with the 2021 municipal election, reflecting heightened local interest in the mayoral and council races. Incumbent Mayor Charles Cephas, a Democrat, was soundly defeated by At-Large Councilmember Earl Murphy, who won with roughly 230 votes to Cephas’s 144. In the At-Large Council race, Jeff Smith, an independent candidate backed by local Republicans, secured a 15-point win over Cheyenne Chase. In District 2, Councilmember Bonnie Franz, a Republican, was re-elected by 40 percentage points over challenger Zia Ashraf, who previously served on the Dorchester Democratic Central Committee. The only Democrat to retain a seat on the council was David Higgins, who was unopposed. The Maryland Republican Party invested resources and campaign attention in the Hurlock race, highlighting it on statewide social media and dispatching party officials, including Maryland GOP Chair Nicole Beus Harris, to campaign. Local Democrats emphasized support for Mayor Cephas through the Dorchester County Democratic Central Committee, but the Maryland Democratic Party did not appear to participate directly.
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