A by-election was held in the Cook Islands electorate of Tengatangi-Areora-Ngatiarua on 14 November 2019.
[2] Following the by-election, Democratic party candidate Nandi Glassie filed a petition against her victory, alleging that she had effectively bribed voters by covering the charge of a private aircraft to carry voters to vote on Atiu.
[3] Brown resigned in April 2019 during the process of the petition through the courts and although Glassie was allowed to challenge the election result, this was reversed on appeal.
[5] Glassie was too ill to contest the by-election,[6] and the Democratic party instead selected businesswoman June Baudinet.
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