Rep. Bill Lowery (R-San Diego) cannot call himself the incumbent in the newly created 51st Congressional District, the California secretary of state has ruled.
Lowery, who was elected in 1990 to represent the 41st Congressional District, had wanted to be designated as the incumbent in the 51st District, a district created in January through reapportionment.
Officials from Lowery's campaign proposed that he be labeled as the incumbent in the 51st District because of a ruling by the San Diego County registrar of voters. Last month, the registrar's office said Lowery could call himself the incumbent in the district because of the large overlapping of constituents from his old district.
The secretary of state's ruling will only allow Lowery to list himself as "United States representative" on the primary ballot.
Lowery and Rep. Randy (Duke) Cunningham, Republican incumbent in the old 44th Congressional District, are battling in the GOP primary in the 51st District.