Sam Ronan, an Air Force veteran seeking to challenge incumbent U.S. Rep. Mike Carey in Ohio's 15th congressional district Republican primary, was removed from the ballot after a voter protested, alleging that he was not in fact a Republican. The Franklin County Board of Elections deadlocked two to two on the challenge, sending the dispute to Ohio Secretary of State Frank LaRose, who broke the tie in favor of the protester and against Ronan.

The removal turned on Ronan's political history. LaRose pointed to Ronan's 2017 run for chair of the Democratic National Committee, during which LaRose said Ronan continued to advocate for a strategy of running Democrats as Republicans in deeply red districts. Ohio law requires candidates to attest, among other things, that if elected they would support and abide by the principles enunciated by the Republican Party. Both U.S. District Judge Sarah Morrison and the Sixth Circuit declined to intervene, with the Sixth Circuit concluding that Ronan had not shown that such a requirement violates the First Amendment.

Ronan brought a 23-page filing to the Supreme Court's interim docket on Monday, arguing that it is undisputed that he was removed from the ballot based solely on the content of his core political speech. He warned that early voting was set to begin April 7 — a date that passed before the Court announced its decision Thursday.

Ohio Solicitor General Mathura Sridharan, representing LaRose, urged the justices to let the ballot proceed without Ronan, telling them that Ronan faced "an all-but-insurmountable obstacle" to obtaining relief, because he is seeking "an extraordinary, first-in-time injunction reinstating his candidacy in an ongoing election."

The Supreme Court declined to block the lower court ruling, leaving Ronan off the ballot. The 15th District, which stretches from the Columbus suburbs, was won by President Donald Trump by nine points in 2024.