In most Philippine homeowners association (HOA) elections, a candidate should not be automatically disqualified just because of a campaign poster violation. An HOA may regulate campaign posters, common areas, bulletin boards, tarpaulins, flyers, and online campaign materials, but disqualification is a serious penalty because it affects a member’s statutory right to be eligible for elective office. The key questions are: Was there a clear written rule? Was disqualification expressly allowed as a penalty? Was due process observed? Was the violation serious enough to affect a free, orderly, and honest election? This article explains how Philippine law treats this issue, what an Election Committee can and cannot do, and what a candidate or homeowner can do if disqualification is being threatened or imposed.

The Short Answer

An HOA candidate can be disqualified for campaign poster violations only in limited cases.

Disqualification is more defensible when all of the following are present:

The HOA has a valid written campaign rule issued before the campaign period.
The rule is based on the HOA bylaws, election rules, or a valid Election Committee resolution.
The rule clearly states that certain violations may result in disqualification.
The candidate received written notice of the alleged violation.
The candidate was given a fair chance to explain, remove the poster, or correct the violation.
The Election Committee issued a written ruling based on evidence.
The penalty is proportionate to the violation.

Disqualification is legally vulnerable when:

The rule was vague, unwritten, or invented after the campaign started.
Other candidates committed similar violations but were not penalized.
The candidate was disqualified without notice or hearing.
The violation was minor, such as a poster being slightly larger than allowed.
The Election Committee acted with bias or under pressure from incumbent officers.
The bylaws or election rules only allow removal of the poster, warning, or fine, not disqualification.

A poster violation may justify removal of the poster, warning, fine, or other administrative sanction, but not necessarily the drastic penalty of removing the candidate from the ballot.

Why HOA Election Disqualification Is a Serious Matter

A homeowners association is not the same as the Commission on Elections (COMELEC). HOA elections are private association elections, not public elections for government office.

But they still involve important legal rights.

Under Republic Act No. 9904, the Magna Carta for Homeowners and Homeowners’ Associations, an association member has the right:

to participate in association meetings and elections;
to vote;
to be eligible for elective or appointive office, subject to the qualifications in the bylaws;
to inspect association records;
to enjoy other rights under the bylaws.

Section 7(c) of RA 9904 is especially important. It recognizes the member’s right “to participate, vote and be eligible for any elective or appointive office of the association,” subject to the qualifications in the bylaws.

That means an HOA cannot casually remove a candidate from the election simply because the candidate is unpopular, critical of the incumbent board, or accused of a campaign violation. A candidate’s eligibility is a legal right tied to membership.

Legal Basis for HOA Election Rules in the Philippines

The main legal sources are:

Legal source	Why it matters
RA 9904	Main law governing homeowners associations in the Philippines.
2021 and 2024 Revised IRR of RA 9904	Implementing rules issued through DHSUD, including HOA governance and elections.
HOA Articles of Incorporation and Bylaws	The association’s internal constitution; usually contains qualifications, election process, officers, quorum, committees, and sanctions.
Election Rules or Election Committee Guidelines	Specific rules for the election period, including campaign period, posters, ballots, proxies, and protests.
RA 11201	Created DHSUD and HSAC; transferred housing and HOA regulatory/adjudicatory functions from the old HLURB framework.
HSAC Rules and DHSUD issuances	Relevant for disputes involving HOA elections, qualifications, and election protests.
Supreme Court decisions	Help interpret due process, election disputes, and the powers of administrative bodies.

RA 9904 Section 10 allows an association to adopt rules and regulations and to regulate common areas, subject to law and its governing documents. Section 10 also recognizes the power to impose sanctions for violations of the bylaws and rules.

But that power is not unlimited. RA 9904 also requires fairness. For example, Section 9 states that the right to due process must be observed when administrative sanctions are imposed on delinquent members. Section 12(c) also refers to due notice and hearing before fines for violations of association rules.

Although a campaign poster violation is not always a “delinquency” issue, the same principle applies: a member should not suffer a serious sanction without fair procedure.

What Counts as a Campaign Poster Violation in an HOA Election?

Campaign poster rules vary from one subdivision, village, or housing project to another. There is no single national poster size rule for all HOA elections like there is in public elections.

Common HOA poster violations include:

posting outside the allowed campaign period;
using posters larger than the allowed size;
placing tarpaulins on gates, guardhouses, trees, streetlights, clubhouses, perimeter walls, or common areas without approval;
posting on private houses without the owner’s consent;
using association resources, official HOA pages, guard personnel, maintenance staff, or office supplies for campaign purposes;
failing to submit campaign materials to the Election Committee before posting, if required;
destroying or covering another candidate’s posters;
posting defamatory, obscene, threatening, or misleading materials;
continuing to campaign on election day if prohibited;
posting in group chats, Facebook pages, or Viber communities after the campaign period has ended.

Some poster violations are merely technical. Others may be serious.

For example:

Situation	Likely legal treatment
Poster is slightly bigger than allowed	Usually warning, removal, or correction.
Poster placed on a prohibited common area but removed immediately after notice	Usually not enough for disqualification.
Repeated posting despite written warnings	May justify stronger sanctions if rules allow.
Candidate uses HOA guards or staff to distribute materials	More serious; may affect fairness of election.
Candidate destroys opponent’s posters	May justify disciplinary action and possible election protest.
Candidate posts fake notices pretending to be official HOA announcements	Serious; may justify disqualification if proven and rules allow.
Candidate posts defamatory accusations	May lead to election protest, civil complaint, or even criminal issues depending on content.

Can the Election Committee Make Poster Rules?

Yes, but only within its authority.

Most HOA bylaws create an Election Committee, often called the EleCom, to manage elections. RA 9904 Section 15 recognizes that bylaws should provide for the creation of election, grievance, audit, and other necessary committees.

In practice, the Election Committee usually handles:

election calendar;
filing of candidacies;
screening of candidates;
final list of qualified voters;
campaign period;
ballot preparation;
polling procedures;
counting and canvassing;
proclamation of winners;
initial handling of election-day objections or protests.

The Election Committee may issue campaign rules if the bylaws or the general membership authorize it. But the rules must be reasonable, transparent, and applied equally.

A valid poster rule should normally state:

where campaign materials may be posted;
maximum size and number of posters;
start and end of campaign period;
whether approval is needed before posting;
prohibited locations;
prohibited content;
process for reporting violations;
penalties for first, second, or serious violations;
appeal or protest procedure.

A vague rule such as “improper campaign materials are prohibited” is weak if used as the sole basis for disqualification. If the HOA wants disqualification to be a possible penalty, the rule should say so clearly.

When Disqualification May Be Valid

Disqualification may be valid when the poster violation is not merely a small mistake but a material breach of election rules that harms fairness, order, or voter choice.

Examples include:

1. The candidate repeatedly ignored written notices

If the rule says posters must be removed from common areas, and the candidate receives repeated written notices but continues posting, the Election Committee may have stronger grounds to impose a serious penalty.

Still, the committee should show:

copies of notices;
photos of posters;
dates and times;
witnesses;
proof the candidate knew of the rule;
proof of refusal or repeated violation.

2. The campaign materials misled voters

Disqualification may be more defensible if the poster falsely claims:

the candidate is officially endorsed by DHSUD;
the candidate is already proclaimed;
the Election Committee cancelled another candidate’s candidacy;
the incumbent board officially supports only one slate, when association resources were used;
voting dates, venues, or ballot instructions were changed.

Misleading voters can affect the integrity of the election.

3. The violation involved abuse of HOA resources

A candidate who uses official HOA property or personnel for campaign purposes may violate fairness rules, especially if the candidate is an incumbent officer.

Examples:

using HOA guards to distribute flyers;
ordering office staff to print campaign posters using HOA funds;
using official HOA letterhead for campaign propaganda;
posting campaign materials on official association channels while denying access to opponents.

This may also raise issues of misuse of association funds or abuse of position.

4. The rule expressly provides disqualification

The strongest case exists when the bylaws, duly approved election rules, or Election Committee guidelines clearly state that a particular violation may result in disqualification.

Even then, the committee must still observe due process. A rule allowing disqualification does not mean the committee can disqualify instantly.

5. The violation made a free and honest election impossible

The Revised IRR of RA 9904 recognizes that serious causes may affect the holding of a free, orderly, and honest election. This is usually discussed in the context of postponement or failure of election, but the same practical concern matters in evaluating election misconduct.

For example, a coordinated campaign of fake notices, intimidation, destruction of campaign materials, and abuse of official HOA channels may be more than a simple poster issue.

When Disqualification Is Likely Invalid or Abusive

Disqualification is more likely to be invalid when it looks like a pretext to remove a candidate.

Common red flags include:

1. No written rule exists

If the Election Committee cannot point to a bylaw provision, election rule, board-approved policy, or written campaign guideline, disqualification is weak.

A candidate cannot be expected to comply with a penalty that was never clearly announced.

2. The rule does not mention disqualification

If the rule only says “unauthorized posters shall be removed,” then removal is the likely remedy. The Election Committee should be careful before upgrading the penalty to disqualification.

3. The rule was changed after the campaign began

Changing campaign rules midstream can be unfair, especially if the change targets one candidate or slate.

Election rules should be set before filing of candidacy or before the start of the campaign period.

4. The violation is minor

A minor poster mistake rarely justifies disqualification.

Examples:

poster was a few inches larger;
poster was posted one hour before the campaign period because of confusion;
supporter posted without the candidate’s knowledge and removed it immediately;
poster was placed in a questionable area because the map of allowed areas was unclear.

5. The committee did not give notice and hearing

A candidate should be told:

what rule was violated;
when and where the violation happened;
what evidence supports the charge;
what penalty is being considered;
when the candidate may submit an explanation.

A surprise disqualification is vulnerable to challenge.

6. The rule is selectively enforced

If only one candidate is punished while others are ignored for the same conduct, the issue becomes unequal treatment.

Selective enforcement is one of the most common reasons HOA election disputes become bitter.

7. The Election Committee is not impartial

An Election Committee member should not act as a campaigner, slate organizer, close adviser, or active supporter of a candidate.

If the committee is visibly biased, its rulings may be challenged before the proper forum.

Due Process Before Disqualifying an HOA Candidate

Due process means basic fairness. It does not always require a courtroom-style trial, but it does require a real chance to respond.

The Philippine Supreme Court’s classic administrative due process doctrine in Ang Tibay v. Court of Industrial Relations is often cited for the idea that administrative bodies must observe fundamental fairness, including the right to be heard, consideration of evidence, and a decision supported by substantial evidence.

For HOA elections, a practical due process checklist looks like this:

Written complaint or incident report The violation should be documented. A vague verbal accusation is not enough.
Specific rule cited The notice should identify the exact bylaw, election rule, or committee guideline allegedly violated.
Evidence attached or described Photos, screenshots, witness statements, dates, and locations should be provided.
Opportunity to explain The candidate should be allowed to submit a written explanation or appear before the Election Committee.
Opportunity to cure when appropriate For minor poster violations, the candidate should usually be asked to remove or correct the material first.
Written decision The committee should issue a written ruling explaining the facts, rule applied, and reason for the penalty.
Record preservation Ballots, complaints, photos, minutes, notices, and decisions should be preserved in case of an election protest.

What the Election Committee Should Do Before Imposing Disqualification

A careful Election Committee should avoid emotional or politically motivated decisions. The committee should follow a structured process.

Step 1: Receive and docket the complaint

The complaint should identify:

complainant;
candidate complained of;
date and time of violation;
location of poster;
specific rule violated;
requested action;
evidence attached.

Anonymous complaints should be treated cautiously unless supported by clear evidence.

Step 2: Issue a notice to the candidate

The notice should state:

the alleged violation;
the rule allegedly violated;
the possible penalties;
deadline to answer;
whether the poster must be removed immediately;
date of conference or hearing, if any.

For urgent election matters, the timeline may be short, but it should still be fair.

Step 3: Allow the candidate to respond

The candidate may explain that:

the poster was not authorized by the candidate;
the poster was placed by a supporter without consent;
the rule was unclear;
other candidates did the same;
the poster was already removed;
the alleged location is not a prohibited area;
the evidence is incomplete or inaccurate.

Step 4: Evaluate proportionality

The committee should ask:

Was the violation intentional?
Was it repeated?
Did it affect voters?
Was there prior warning?
Is disqualification expressly allowed?
Would a lesser penalty be enough?

Step 5: Issue a written ruling

A proper ruling should state:

facts found;
evidence relied upon;
rule applied;
penalty imposed;
reason the penalty is proportionate;
remedy or appeal/protest procedure.

Step 6: Notify all affected parties

If disqualification changes the ballot, voter notice may be necessary. If ballots are already printed, the committee must decide how votes for the disqualified candidate will be treated, based on the election rules and applicable DHSUD/HSAC guidance.

What a Candidate Can Do If Threatened With Disqualification

A candidate should respond quickly and in writing. HOA election disputes move fast, and delay can make the issue harder to correct.

Step-by-step response

Ask for the exact written rule

Request the specific bylaw provision, election rule, or resolution being used.
Ask for the evidence

Request photos, screenshots, incident reports, witness statements, or minutes.
Submit a written explanation

Keep the tone factual. Avoid personal attacks.
Remove or correct the poster if appropriate

If the violation is minor, curing it quickly helps show good faith.
Document unequal treatment

Take photos of other candidates’ similar posters, with dates, times, and locations.
Request inhibition of biased committee members

If an Election Committee member is actively campaigning, ask that person to inhibit from ruling.
Ask for a written ruling

Do not rely on verbal decisions.
File an election protest or appropriate complaint if necessary

Depending on the rules and timing, the matter may go to the Election Committee first, then to the proper DHSUD/HSAC process.

What Homeowners Can Do If They Believe a Candidate Violated Poster Rules

A homeowner or opposing candidate should also act properly. A weak complaint can backfire and make the election more divisive.

A good complaint should include:

copy of the campaign rule;
photo of the poster;
date and time taken;
exact location;
explanation why the location or content violates the rule;
names of witnesses, if any;
requested remedy;
proof that the violation affected fairness, if claiming disqualification.

Avoid tearing down the poster yourself unless the rules clearly allow it or the Election Committee directs it. Removing another candidate’s materials without authority can become a separate violation.

Where to File an HOA Election Dispute

HOA disputes used to be commonly associated with the Housing and Land Use Regulatory Board (HLURB). Under Republic Act No. 11201, the housing framework changed. The Department of Human Settlements and Urban Development (DHSUD) now has regulatory functions, while adjudicatory functions involving housing and HOA disputes are handled through the Human Settlements Adjudication Commission (HSAC).

In practical terms:

Issue	Usual first step
Minor poster violation during campaign	File with the Election Committee.
Candidate disqualification before election	Submit opposition/answer to Election Committee; preserve right to protest.
Irregular Election Committee action	Raise immediately with the committee and document objection.
Election protest after voting	File according to HOA election rules and HSAC/DHSUD procedures.
Dispute over candidate qualifications, proclamation, or validity of election	May fall within HSAC jurisdiction as an HOA election dispute.
Need for DHSUD-supervised election	DHSUD Regional Office involvement may arise under applicable rules, orders, conciliation agreements, or HSAC/court directives.

The Supreme Court has recognized in HOA election disputes that proper authority to call and conduct elections matters. In Multinational Village Homeowners’ Association, Inc. v. Gacutan, the Court dealt with competing HOA groups and election validity, stressing the importance of authorized election processes and the role of the housing regulator under the then-HLURB framework.

Documents to Prepare

Whether you are the candidate, complainant, or homeowner, prepare documents early.

Document	Why it matters
HOA bylaws	Shows candidate qualifications, election process, and committee authority.
Articles of incorporation	Confirms association identity and governance structure.
Election rules or guidelines	Shows campaign poster rules and penalties.
Election calendar	Shows campaign period, filing dates, election day, and protest deadlines.
Candidate certificate of candidacy	Confirms candidate status.
Notices from Election Committee	Shows whether due process was observed.
Photos/videos of posters	Main evidence of violation or unequal enforcement.
Screenshots of online posts	Important for Facebook, Messenger, Viber, or HOA group campaign disputes.
Written explanation or answer	Candidate’s defense.
Minutes of committee meetings	Shows how the decision was made.
Written ruling	Needed for protest or appeal.
Master list of voters/candidates, if relevant	Useful if the dispute affects ballots or proclamation.

For official filings, documents may need to be signed, dated, and in some cases notarized. If a foreign homeowner is abroad, documents signed overseas may require consular notarization or apostille, depending on the receiving office’s requirements and the type of document.

Practical Timelines

Timelines vary by HOA rules, DHSUD/HSAC procedures, and urgency. But in real HOA elections, these are common practical timeframes:

Stage	Practical timeline
Campaign violation reported	Same day to a few days after discovery.
Candidate asked to explain	Often 24–72 hours in urgent election settings.
Minor poster removal	Usually immediate or within 24 hours.
Election Committee ruling	Often before election day, especially if ballot inclusion is affected.
Election protest	Usually very short deadlines under HOA rules; check the specific election guidelines.
DHSUD/HSAC proceedings	Can take weeks to months, depending on complexity, service of notices, hearings, and appeals.

The biggest bottleneck is usually timing. If disqualification happens close to election day, ballots may already be printed, voters may already have seen the candidate’s name, and the association may be forced to decide whether to proceed, postpone, or treat votes in a particular way.

This is why Election Committees should set campaign rules early and resolve complaints quickly.

Special Issues for Incumbent Officers Running for Reelection

Poster violations become more sensitive when the candidate is an incumbent officer.

Incumbents may have access to:

HOA bulletin boards;
official Facebook pages;
homeowner databases;
guards and staff;
maintenance teams;
HOA funds;
official letterhead;
clubhouse facilities.

Using these resources for personal campaign purposes may be more serious than an ordinary poster violation. It can raise issues of abuse of office, unequal access, and misuse of association property.

A fair election rule should state whether all candidates have equal access to:

designated poster boards;
official campaign forum;
HOA bulletin boards;
candidate profiles;
homeowner mailing lists;
debate or town hall opportunities.

If only incumbents can use association-controlled platforms, the election may be challenged as unfair.

Special Issues for Foreign Homeowners and Absentee Owners

Foreigners may own condominium units in the Philippines, subject to constitutional and statutory limits, and may be members of condominium or homeowners associations depending on the governing documents. In subdivisions, foreign land ownership restrictions under the 1987 Constitution and related property laws are important, but foreigners may still be involved through condominium ownership, leases, corporations subject to nationality rules, marriage-related property arrangements, or authorized representatives.

For HOA elections, foreign or overseas homeowners often face practical issues:

they may not receive notices on time;
they may rely on representatives or proxies;
they may not know local poster rules;
they may campaign through online groups instead of physical posters;
they may need notarized or apostilled authorizations if signing documents abroad;
they may not understand that HOA elections are governed by bylaws, not COMELEC rules.

If an absentee owner is accused of a poster violation made by a caretaker, tenant, agent, or supporter, the Election Committee should determine whether the candidate authorized or ratified the act. Automatic liability may be unfair if the candidate had no knowledge and promptly corrected the issue.

Can the HOA Fine a Candidate Instead of Disqualifying Them?

Yes, if the bylaws and rules allow fines.

RA 9904 recognizes the association’s power to impose sanctions and reasonable fines for violations of bylaws and rules, but due notice and hearing should be observed.

For many poster violations, a graduated penalty system is more reasonable:

Violation level	Possible remedy
First minor violation	Notice and removal.
Repeated minor violation	Written warning.
Continued violation after warning	Fine, if allowed by rules.
Serious misleading or abusive campaign material	Stronger sanction, possible disqualification if rules allow.
Conduct affecting election integrity	Election protest, possible annulment or other HSAC/DHSUD remedy.

A graduated system is usually better than immediate disqualification because it protects both election fairness and the voters’ right to choose.

Can the Election Proceed While a Disqualification Issue Is Pending?

It depends on timing and the election rules.

Possible approaches include:

Resolve before ballot printing Best option if there is enough time.
Include the candidate but mark the candidacy as under protest This may preserve voter choice while allowing later resolution.
Proceed with election and allow post-election protest Common when the issue cannot be resolved in time.
Postpone election only for serious causes Postponement should not be used lightly. Minor poster disputes usually should not stop the election.
Declare failure of election only when justified A failure of election generally requires serious circumstances, such as lack of quorum, lack of sufficient candidates, violence, force majeure, or other causes making a free, orderly, and honest election impossible.

A single poster issue rarely justifies failure of election unless it is part of broader misconduct that undermines the entire process.

Common Mistakes by Election Committees

Disqualifying first, explaining later

This is risky. The written explanation should come before or at the time of the ruling, not after public backlash.

Treating all poster violations as equal

A poster on an unauthorized wall is not the same as a fake official notice misleading voters.

Relying on verbal rules

Campaign rules should be written, dated, circulated, and acknowledged by candidates.

Allowing the board to control the Election Committee

The Election Committee should be independent. Incumbent officers should not dictate who gets disqualified.

Ignoring online campaign materials

Many HOA campaign disputes now happen on Facebook, Messenger, Viber, and community apps. Election rules should cover both physical and digital campaign conduct.

Forgetting record preservation

If the dispute reaches HSAC or another reviewing body, the record matters. Minutes, notices, rulings, photos, and ballot records may decide the case.

Common Mistakes by Candidates

Assuming COMELEC rules automatically apply

COMELEC rules apply to public elections. HOA elections are governed by RA 9904, DHSUD/HSAC rules, the bylaws, and the association’s election guidelines.

Ignoring a written notice

Even if the accusation seems unfair, answer in writing. Silence can be treated against the candidate.

Letting supporters post anywhere

Candidates should brief supporters. “My supporters did it, not me” may not always be accepted, especially if the candidate benefits and does not correct it.

Campaigning through official HOA channels

Using official association pages, staff, or resources can create serious problems.

Attacking the Election Committee without evidence

Bias should be documented, not merely alleged.

Frequently Asked Questions

Can an HOA automatically disqualify a candidate for an oversized poster?

Usually, no. An oversized poster is often a correctable violation. Disqualification may be excessive unless the election rules clearly provide that penalty and the candidate was given notice and an opportunity to explain or correct the violation.

What if the candidate posted on the clubhouse or guardhouse?

Posting on the clubhouse, guardhouse, gate, or other common area may violate HOA rules. The usual remedy is removal, warning, or fine. Disqualification may be possible only if the written rules allow it and the violation is serious or repeated.

Can the board of directors disqualify a candidate?

Normally, candidate screening and campaign violations should be handled by the Election Committee, not by the incumbent board acting for its own political advantage. The board may have administrative powers, but election decisions should follow the bylaws and election rules.

What if the Election Committee is biased?

Document the bias. Save messages, minutes, photos, and rulings. Ask the biased member to inhibit from the case. If the committee proceeds unfairly, the issue may become part of an election protest or HOA dispute before the proper forum.

Can a candidate be disqualified for posters made by supporters?

Not automatically. The committee should determine whether the candidate authorized, knew of, tolerated, or benefited from the posters. If the candidate promptly removes unauthorized materials and warns supporters, disqualification may be too harsh.

Can campaign posters be banned completely inside the subdivision?

A total ban may be questioned if it prevents candidates from reasonably reaching voters. However, the HOA may regulate locations, sizes, schedules, and content to protect common areas, safety, cleanliness, and order. A better approach is to designate common poster areas equally available to all candidates.

Is a Facebook post considered a campaign material?

It can be. Many HOA election rules now cover online campaigning, especially official HOA pages, community groups, Messenger chats, Viber groups, and candidate pages. If the rules cover digital campaign materials, the same fairness and due process principles apply.

Can a poster violation annul the entire HOA election?

Only if the violation materially affected the election’s integrity or results. A minor poster violation by one candidate usually will not annul the entire election. But widespread misleading materials, intimidation, unequal use of official resources, or systematic suppression of opponents may support an election protest.

Should the candidate still be on the ballot if the disqualification is disputed?

If there is no final written ruling yet, keeping the candidate on the ballot may be the safer option to preserve voter choice. But the correct approach depends on the election rules, timing, and the seriousness of the alleged violation.

Where can I verify the law on HOA rights and elections?

Start with RA 9904 on Lawphil, RA 11201 on Lawphil, official DHSUD issuances, and HSAC guidance on HOA disputes. The association’s registered bylaws and election rules are equally important because RA 9904 expressly makes eligibility subject to the qualifications in the bylaws.

Key Takeaways

An HOA candidate is not automatically disqualified for a campaign poster violation.
Disqualification requires a clear written rule, proper authority, evidence, due process, and proportionality.
Minor poster issues usually justify removal, correction, warning, or fine, not immediate disqualification.
The Election Committee must act independently and apply rules equally to all candidates.
A candidate should answer any notice in writing, preserve evidence, and correct minor violations quickly.
HOA election disputes may involve DHSUD and HSAC procedures, especially when candidate qualifications, proclamation, or election validity is challenged.
The most important documents are the HOA bylaws, election rules, notices, evidence, minutes, and written rulings.