NYS Court Overturns PCFB Disqualification of Blakeman-Hood Ticket – How Future Candidates Can Avoid this Same Type of Problem
By: Joseph T. Burns
In a May 12, 2026, decision, an Albany County Supreme Court Justice vacated the New York State Public Campaign Finance Board's determination that the Bruce Blakeman-Todd Hood gubernatorial joint ticket was ineligible to receive public matching funds under New York's Public Campaign Finance Program. The decision is legally and politically consequential. Candidates in the public campaign finance program, campaign staff, and party leaders should understand precisely what the Court did and what they can do to avoid encountering similar compliance issues.
What Happened and Why It Matters
The dispute traces to the PCFB's March 31, 2026, determination, by a 4-3 vote, that the Blakeman-Hood ticket had failed to comply with PCFB regulations requiring both candidates on a gubernatorial ticket to jointly submit an application and certification by the statutory deadline. Bruce Blakeman timely filed his individual registration and certification forms. His running mate, lieutenant governor candidate Todd Hood, filed nothing with the PCFB before the deadline. In a vote that broke along party lines, the PCFB declared the entire ticket ineligible for public matching funds.
The court rejected two of petitioners' arguments. The court found no basis for the claim that the PCFB lacked authority to make an ineligibility determination, and it rejected outright the contention that Hood's complete failure to file anything was a minor, insignificant deficiency. The court’s language was deliberate: a lieutenant governor candidate is not an "appendage" to the governor, and the filing obligations — which require a candidate to personally attest responsibility for complying with the full scope of the public campaign finance program rules — are substantive legal commitments, not administrative formalities.
Where the ruling broke against the PCFB was narrower, and it turned entirely on the Board's failure to follow its own regulations. Under PCFB regulations, when the PCFB determines that an application is incomplete, it is required to notify the candidate and provide an opportunity for the candidate to cure. That obligation extends to joint-ticket candidacies under the PCFB’s regulations, which apply unless inconsistent with the specific joint-ticket rules. The court found that once the joint-ticket regulation took effect and the Petitioners filed their certificate of party designation with the New York State Board of Elections, Blakeman's prior individual filings with the PCFB became incomplete as a matter of law. He submitted amended filings before the deadline for candidates to get into the program but still received no deficiency notice from the PCFB. The deadline passed. Only then did the PCFB act.
The PCFB’s procedural failures compounded its substantive ones. Its own counsel conceded at oral argument that no specific joint certification form was ever created by the PCFB. The PCFB’s handbook contained no guidance on how candidates could satisfy the joint submission requirement. The mandatory training session held January 8, 2026, similarly offered no instruction on the mechanics of compliance for a joint gubernatorial ticket. And a February 6, 2026, internal PCFB staff email revealed that the Board's own staff were uncertain, just two weeks before the deadline for candidates to get into the program, how joint-ticket submissions should be processed.
The court vacated the ineligibility determination and ordered the PCFB to provide petitioners one week to cure any remaining deficiency in their certifications.
This Fight is Likely to Continue
The decision is a trial court ruling, and the PCFB has already filed its Notice of Appeal. The PCFB’s partisan split, combined with the first-impression nature of the regulations at issue, means this case is likely far from over. Until the appellate process runs its course, the Blakeman-Hood ticket's standing in the Program remains legally unsettled. Candidates watching this case as a signal that the courts will rescue campaigns from compliance mishaps would be drawing the wrong conclusion.
Lessons for Candidates
Blakeman prevailed not because his campaign was compliant but because the PCFB failed to adhere to its own rules. Future candidates who find themselves in similar predicaments aren’t likely to have the opportunity to make this same argument.
New York's Public Campaign Finance Program is among the most technically demanding voluntary public campaign finance programs in the nation. Its gubernatorial joint-ticket provisions, effective for the first time this year, introduced requirements that proved sufficiently complex to confound even the PCFB’s own staff. For candidates and their campaigns, the safest path through this bureaucratic maze is with early and expert legal counsel.
Getting compliance right from the outset means correct and timely registration and certification. It means not being surprised when a deficiency is discovered. An incomplete or late filing can put thousands of public matching funds in jeopardy and mean the difference between victory and defeat. Smart candidates understand compliance with the requirements of the public campaign finance program is as important to a campaign’s success as a strong get-out-the-vote operation or a clear, persuasive message to voters.
