Court of Petty Appeals: Ryan Keane v. The University Board of Elections Two, “This Time, It’s Personal”

Ryan Keane

v.

The University Board of Elections Two

“This Time, It’s Personal”

78 U.Va 18 (2026)

Berklich, J., delivers the opinion of the Court, in which Demitry, C.J., Wu, Vanger, Kaufmann, and Becker, J.J. join. Moore, J., dissents.

Berklich, J., delivers the opinion of the Court.

Facts

Keen (¬‿¬) court observers will remember last year’s case Friends of Ryan Keane for 3L Senator Political Action Committee (FRACK-PAC) v. UVA Law Student Bar Association, No. 25-19 (2025). There, local funnyman Ryan Keane made a desperate plea to the UVA Student Bar Association for eligibility for the election of the 2025-2026 Student Bar Association President position, despite missing the registration deadline, and his being far too silly about it. Keane ran on a platform with policies like renaming the Virginia Law Review to the Virginia Law Ryan, replacing the library’s quiet zones with “loud zones,” bringing food trucks to Spies garden (would be sick, actually), and [redacted]. See, Petition of Plaintiff in FRACK-PAC v. UVA SBA, No. 25-19 (2025).

In an unreported super-secret interim half-enchilada Shadow the Hedgehog docket opinion, the Court of Petty Appeals ruled that Keane was ineligible to run for President because the deadline of “Friday, February 14th at 5 pm” was a clear bright-line rule despite Keane’s argument that “The elections are about popularity” and his contention that the fact “[his] campaign posted a singular promotional message in the school-wide GroupMe, which received 133 likes” made him the automatic winner. Id. Now, Keane brings another suit disputing his eligibility for candidacy.

In an “unprecedented occurrence,” no candidates ran for any executive position for the 2025-2026 SBA elections. This fact has dismal implications for UVA School Spirit and underscores the general feeling of apathy among the student body. Lucky for the Law Weekly, we do “elections” in early February, beating the Overcommitment Anxiety Window in early March. Unfortunately, the same strategy did not work for SBA.

Despite the fact that SBA reports that “no candidates” ran, this is not exactly true. In what cannot be said to be an “unprecedented occurrence,” Ryan Keane once again submitted himself for candidacy to become SBA president. This time, his petition was timely. However, the University Board of Elections identified a flaw with Keane’s election petition, and refused to honor his candidacy: for the majority of Keane’s prospective term, he will not be a student at UVA Law. Keane is a 3L and—so the UBE claims—ineligible to run.

Keane argues that the language of the SBA Constitution is clear: “The President must be a member of the 3L class.” Keane is a member of the 3L class; thus, he is eligible to run. Keane brings suit against the University Board of Elections and the UVA Law SBA, asking, as relief, for his name to be placed on the ballot.

Discussion

The question before the court is: What did the UVA Law SBA mean when it said “the President must be a member of the 3L class”? Two plain readings emerge from the language SBA Constitution: 1) The president must, while serving, be a member of the 3L class, and 2) the president must at all times, both while running and while serving, be a member of the 3L class. This Court finds little evidence for Keane’s reading: that only 3L class members are eligible to run, and that there is no need to be a member of the 3L class while actually serving as President.

Confronting a definite ambiguity, this particular Court feels more than free to break out the full interpretive toolbox (or at least what of it we can understand after Legislation). Some of us aren’t so hot on legislative history, so we’re leaving that out. But other connected documents, such as the position descriptions, the SBA election presentation, and the SBA election rules, can shed light on the True Meaning of this ambiguous phrase.

Both the election presentation and the position description jibe with the SBA Constitution in specifying that the president must be a “3L.” This language in the majority of SBA documents is clear and at odds with current practice. At the moment, all public servants elected to positions start those positions immediately after election, in the spring of the election year. This means that a 2L candidate, if elected, will become President as a 2L, in clear violation of the SBA constitution. While Keane would not face this issue, as a 3L, he will soon not be a 3L if he successfully graduates (godspeed).

The issue is complicated by the SBA election rules, which specify in a more sensible and tiresome fashion that the SBA President must be a “rising member of the 3L class.” However, this added detail is more paradoxical than dispositive. According to the SBA election rules and the SBA Constitution, which reigns supreme over any statute (see Marg. Tower v. Madison, -145 U.Va. (1 Crunch) 137, 177 (1803)), the SBA President must, at all times, be a member of the 3L class. If SBA members start their terms in the year they are elected, then it follows that the only students eligible to hold the position—and implicit in that, to be elected—are indeed 3Ls. Point one, Mr. Keane.

It is contended by Keane that this 3L status invalidates the requirement of the election statute that students also must be rising 3Ls when running for the position of SBA President. He argues that the statute is entirely unconstitutional in light of the 3L position-holding requirement.

We see no need to resolve this tension by declaring the statute unconstitutional. UVA Law Society for Religious Free-Speech Post-Birth Abortions v. UVA Law SBA, 53 U.Va 14 (2001) (upholding that the “Savings Canon” allows lazy Court of Petty Appeals justices to simply adopt the constitutional reading of SBA statutes, rather than spend endless hours dithering about it, thus saving their time). Instead, we find an alternate, implicit requirement in the SBA statute. The SBA President must be elected as a rising 3L, and must serve as a 3L. The conflict this requirement has with current practices can be remedied in one easy way: the SBA president can start their term on day one of 3L year, whilst running as a 2L.

But fear not, Mr. Keane, because we have a solution for you. Sticking to the applicable rules as identified by the contours of the SBA constitution and election statute, Ryan Keane is eligible to run if, as a 3L, he is also a rising 3L. The solution is simple: Keane must pledge to flunk 3L and repeat it in order to successfully run as SBA President. We find this to be the funniest possible outcome, and stop just short of compelling it through judicial action.

Plaintiff’s petition for relief is denied.

SO ORDERED

Moore, J., dissents.

 While the ponderous and eloquent analysis of the learned brothers of the court is some of the most logical yet read by the same Justice, the court’s ignorance of time is rivaled only by that of the Protagonist’s confusion with temporal pincer movements. See Sir Christopher Nolan, Tenet. The exercise in logic is ultimately unnecessary for the reason that these very elections are unconstitutional so the esteemed Mr. Keane may not be on the ballot because there ought not be a ballot according to the current constitution.

The SBA has jurisdiction over “all elections and referenda required by this Constitution,” which is specified in this case to be “Spring Elections.” See SBA Const. Art. I, § 1.F; and Art. III, § 3. The textualism of the majority is sadly lacking when it comes to interpreting this section. According to common definitions, spring is defined as “The season between winter and summer.” See Spring, Oxford English Dictionary. The season of spring begins on the spring equinox, “usually 20th or 21st March” and lasts until the summer solstice. See Spring Equinox Oxford English Dictionary. Yet the elections to which the SBA aspire to administer encompass a timeline from January through the end of voting on 26th February. Thus these take place not in the spring, but in the winter and therefore are not valid fora via which officers can be elected in the first place. While acting with such haste and placing unnecessary pressure on students may be the modus operandi for law firms of a certain size and law reviews, the drafters of the SBA Constitution foresaw these tragic developments and generously protected the current and future students by delimiting their jurisdiction to elections in the spring and fall—not the winter. Perhaps if the present SBA leaders followed the model of their brethren of yesteryear and delayed their elections to nextermonth students would actually have time to make informed decisions about whether or not to run. Or we can follow the majority and everyone else’s opinion to their natural conclusion and present toddlers with admission to UVA, a SBA position, and a series of summer associateships and management training programs upon their graduations from Kinder-Block. See Succession: Safe Room (HBO 2019); Andor: Harvest (Disney+ 2025).