COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

STATE OF MICHIGAN
IN THE CIRCUIT COURT
INGHAM COUNTY

THE PEOPLE OF THE STATE OF MICHIGAN, Plaintiff
(Signatures Attached)

v.

DANA NESSEL, in her official capacity as Attorney General of the State of Michigan, Defendant

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

Case No.
Hon.

I. INTRODUCTION

Plaintiff brings this action to prevent the Attorney General of the State of Michigan from using the power and resources of her office to interfere with, obstruct, or circumvent legitimate legal proceedings against Secretary of State Jocelyn Benson. Defendant Dana Nessel has demonstrated a clear and documented pattern of partisan bias and has a track record of using her office to protect political allies rather than serve the People of Michigan. Her continued involvement in any proceeding related to the 2026 gubernatorial election or actions against Jocelyn Benson constitutes a conflict of interest that cannot be permitted to stand. The People of Michigan demand impartiality from their highest law enforcement officer. They are not receiving it.

II. PARTIES

1. Plaintiffs are the People of the State of Michigan, represented by the signatures attached hereto, all of whom are registered voters and residents of the State of Michigan.
2. Defendant Dana Nessel is the duly elected Attorney General of the State of Michigan and is the chief law enforcement officer of the state.

III. JURISDICTION AND VENUE

3. This Court has jurisdiction pursuant to MCL 600.605 and MCL 14.28.
4. Venue is proper in Ingham County as the office of the Attorney General is located within this county and the actions complained of originate there.

IV. STATEMENT OF FACTS

5. Defendant Dana Nessel currently serves as Attorney General of the State of Michigan.
6. As Attorney General, Nessel is the chief law enforcement officer of the state and holds the authority to initiate, intervene in, and obstruct legal proceedings on behalf of the state.
7. The People of Michigan have initiated or are in the process of initiating legal proceedings against Secretary of State Jocelyn Benson regarding her unlawful dual role as both a candidate for Governor and the administering officer of the 2026 gubernatorial election.
8. Defendant Nessel has a documented history of partisan conduct, selective enforcement, and using the authority of her office to benefit political allies and obstruct political opponents.
9. Defendant Nessel and Defendant Benson are members of the same political party, have publicly supported one another, and share aligned political interests in the outcome of the 2026 gubernatorial election.
10. Defendant Nessel cannot impartially represent the People of Michigan in any matter involving Jocelyn Benson or the integrity of the 2026 election.
11. Any action taken by Nessel to defend, shield, or intervene on behalf of Benson in the aforementioned legal proceedings would constitute an abuse of office and a direct conflict of interest.
12. The People of Michigan have a constitutional right to legal proceedings free from the interference of a conflicted state officer acting in her own political interest rather than the public interest.

V. LEGAL CLAIMS

Count I. Violation of Due Process. US Constitution, Fourteenth Amendment.

13. Plaintiffs incorporate all prior paragraphs by reference.
14. The Due Process Clause of the Fourteenth Amendment guarantees every citizen the right to a fair and impartial legal process free from bias, political interference, and the appearance of impropriety.
15. Defendant Nessel\'s continued involvement in matters related to the 2026 election and proceedings against Benson violates this guarantee.

Count II. Abuse of Office and Conflict of Interest. MCL 14.28 and Michigan Common Law.

16. Plaintiffs incorporate all prior paragraphs by reference.
17. MCL 14.28 defines the duties of the Attorney General as serving the People of Michigan, not the political interests of allied officeholders.
18. Defendant\'s documented bias and political alignment with Defendant Benson renders her constitutionally and ethically incapable of impartial conduct in these matters.
19. Her continued involvement constitutes an abuse of the powers of her office.

Count III. Declaratory Relief.

20. Plaintiffs seek a declaration from this Court that Defendant Dana Nessel is disqualified by conflict of interest and demonstrated bias from participating in, intervening in, advising on, or obstructing any legal proceeding related to the conduct of the 2026 Michigan gubernatorial election or any action brought against Secretary of State Jocelyn Benson in connection therewith.

Count IV. Injunctive Relief.

21. Plaintiffs seek a permanent injunction barring Defendant Nessel and her office from taking any action, formal or informal, to defend, shield, advise, or otherwise intervene on behalf of Jocelyn Benson in any proceeding related to the 2026 gubernatorial election.
22. Plaintiffs further seek the appointment of a special independent counsel to handle all matters related to the 2026 election in place of the Attorney General\'s office.

VI. RELIEF REQUESTED

WHEREFORE, Plaintiffs respectfully request that this Court:

A. Declare that Defendant Dana Nessel is disqualified by conflict of interest and demonstrated partisan bias from participating in any legal proceeding related to the 2026 Michigan gubernatorial election or any action brought against Secretary of State Jocelyn Benson.

B. Issue a preliminary and permanent injunction ordering Defendant Nessel and the Office of the Attorney General to immediately recuse themselves from all proceedings, advisory roles, and interventions related to the 2026 gubernatorial election and any legal action against Jocelyn Benson.

C. Direct the appointment of a special independent counsel, free from political affiliation with either Defendant, to assume all relevant duties of the Attorney General\'s office in these matters.

D. Award such other relief as this Court deems just and proper.

Respectfully submitted on behalf of the People of the State of Michigan

Lead Petitioner:
Printed Name:
Signature:
Address:
Date:
Contact:

Signature pages attached and incorporated herein by reference.