A Democratic Congressional candidate in Michigan filed a complaint against his transgender opponent alleging that she violated state campaign law by not using her deadname on her application to run in the August primary election.
Frank Liberati, a former member of the Michigan House who represented the state’s 13th District from 2015 to 2021, alleges that Joanna Whaley, a trans woman and fellow Democrat running for the same District 2 seat, did not list her legal name on her when she filed to run for office. His complaint to the Wayne County Clerk’s office, first reported by the Michigan Advance on April 30, referenced a name change petition for Whaley from 2023 that was dismissed.
However, Whaley has indeed since legally changed her name, returning to the court after the 2023 petition to complete the process. According to the Michigan Advance, those court records were sealed for Whaley’s safety due to her increasing visibility as a public figure.
Jay Kaplan, an LGBTQ+ rights attorney for the ACLU of Michigan, also told the publication that because Whaley has used the name Joanna for over five years, she would be covered under “common law name changes” anyway, allowing her to legally list her current name on the ballot. According to the State Bar of Michigan, common law name changes are legally recognized by the state and apply to people who begin going by a name other than their legal one for non-fraudulent purposes.
Michigan campaign law states that those who have changed their name must list both their current name and old name on the ballot, if required by the affidavit of identity for the election. The common law name change is an exception to this rule, however, meaning that Whaley would not be in violation of the campaign name law under that reading, according to Kaplan.
“It’s not going to hold because we have all the proof and documents, and I’ve got 100 witnesses who know me by Joanna,” Whaley told the Advance.
Regardless of the substance of the complaint, or lack thereof, the incident has sparked broader discussions about Democratic candidates turning their backs on trans people amid electoral campaigns. The Michigan Legislative LGBTQ+ Caucus condemned Frank Liberati’s attack on Whaley for not deadnaming herself to run for office.
“The Michigan Legislative LGBTQ+ Caucus denounces Frank Liberati’s meritless, transphobic attempt to remove Joanna Whaley from the primary election ballot,” the caucus wrote in a statement. “Weaponizing transphobia as an electoral tactic has no place whatsoever in Michigan politics, and certainly not in a Democratic Party primary.”
In fact, Whaley said she decided to run after Tullio Liberati, her opponent’s brother and retiring state representative for Michigan’s 2nd district, voted in favor of banning trans girls from sports teams in March 2025. She is one of two trans women running in Michigan’s 2026 primary elections, the other being Toni Mua in the state’s 9th district.
Rather than talking about her name, Whaley wants to focus on single-payer healthcare and reducing cost of living expenses such as utility bills for all Michigan residents.
“My hope for future trans candidates is that we’ve gotten bloody enough to bust the hole in the wall that they can just walk through it,” she said. “I’m willing to take those punches to make it easier for folks in the future. And so that’s why, for me, it’s important to not just let this go.”
Frank Liberati did not immediately respond to Them’s request for comment.















