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2023 December 28, Shenna Bellows, “Ruling of the Secretary of State”, in State of Maine Secretary of State, archived from the original on 29 December 2023, page 15:
Attorney Gordon cites no authority for his interpretation of the Twenty-Second Amendment, which is contrary to the Amendment's plain meaning. Application of the term limit turns on whether an individual has actually been elected President twice, not on beliefs or assertions about that fact. Cf. Nader v. Butz, 398 F. Supp. 390, 397 (D.D.C. 1975) ("Having been elected to [the presidency] twice, [Richard Nixon] is precluded from serving again.") That Mr. Trump has falsely asserted that he won the 2020 election is no more disqualifiying than it would be for him to proclaim that he is not a United States citizen. In other words, political grandstanding does not trigger the bar of the Twenty-Second Amendment.