TAVARES, Fla. — A federal judge has ruled that Lake County Commissioner Anthony Sabatini must comply with Florida’s longstanding resign-to-run law if he wants to continue his campaign for Florida’s 11th Congressional District.
U.S. District Judge Mark Walker denied Sabatini’s request for an injunction that would have allowed him to run for Congress without surrendering his current elected position. The ruling represents a setback for the Mount Dora Republican, who filed a federal lawsuit challenging portions of Florida’s election law.
Walker concluded that Sabatini failed to demonstrate a strong likelihood of success on the merits of his constitutional challenge.
“This Court is not persuaded that the sole purpose of this resign-to-run law is to create an additional qualification to run for Congress,” Walker wrote in his order.
Challenge to Florida’s Resign-to-Run Law Fails
Sabatini argued that Florida’s resign-to-run requirement improperly adds qualifications for candidates seeking federal office beyond those established in the U.S. Constitution.
The Constitution requires members of the U.S. House of Representatives to meet age, citizenship, and residency requirements. Sabatini contended that forcing elected officials to resign before seeking federal office effectively creates another hurdle not contemplated by the Constitution.
Judge Walker disagreed, citing existing court precedents that allow states to regulate election procedures so long as those laws do not serve solely to create additional qualifications for federal office.
The ruling relied in part on legal principles established by the Supreme Court in the landmark 1995 case U.S. Term Limits v. Thornton.
Congressional Ambitions Collide With County Office
Sabatini announced in April that he would seek the Republican nomination for Florida’s 11th Congressional District following the retirement announcement of U.S. Rep. Dan Webster.
The move came less than a year after Sabatini won election to the Lake County Commission. He defeated incumbent Doug Shields in a Republican primary and began serving a four-year term in November.
Under Florida law, elected officials seeking another office that overlaps with their current term must submit an irrevocable resignation. Candidates may choose an effective resignation date that coincides with the start of the new office, but they must file the resignation before qualifying.
The resignation deadline passed on May 29, while congressional qualifying remains open through June 12.
Crowded Republican Primary Emerging
Florida’s 11th Congressional District is expected to draw significant attention from Republican voters following Webster’s retirement.
Several Republican candidates have opened federal campaign accounts, including Sabatini, Steve Farley, Antonette Harmon, Ivette Palomo, Nizam Razack, Tim Wilkins, and Michael Wilnau.
Multiple Democratic candidates and a Libertarian candidate have also filed for the race.
The district remains one of the most Republican-leaning congressional seats in Florida, meaning the GOP primary could effectively determine Webster’s successor.
Why the Ruling Matters
The decision reinforces Florida’s resign-to-run law, a statute that has shaped political campaigns across the state for decades.
Supporters argue the law prevents officeholders from using their current positions as political safety nets while pursuing higher office. Critics contend it discourages qualified candidates from seeking other positions by forcing them to risk their existing elected roles.
For Sabatini, the ruling means his path to Congress now comes with a significant political decision: continue pursuing Florida’s 11th Congressional District or preserve his newly won seat on the Lake County Commission.



