Robert Gibbs is in danger of becoming a caricature by relentlessly repeating the line "I'd refer you to the memo" in response to the continued questions about Joe Sestak. The White House had better watch out, because the phrase ranks right up there with "no controlling legal authority."

New Mexico will elect its first woman governor this November, no matter which party is victorious. Republicans there nominated Susana Martinez, the Doña Ana County district attorney, in that state's primary today. Lt. Gov. Diane Denish was unopposed in the Democratic primary. Gov. Bill Richardson (D) is term-limited.

Martinez's win comes after a late endorsement from Sarah Palin, though she had a healthy list of local backers as well. The RGA said in a release congratulating Martinez that she "brings a proven record of holding government accountable and enforcing the rule of law that contrasts sharply with Diane Denish's failed leadership."

UPDATE: Larry Sabato points out that Martinez may be the first Latina woman nominated by a major party for governor anywhere in the United States. An interesting footnote considering the impact of an immigration law in neighboring Arizona is expected to have on the party's outreach toward Hispanic voters.

Agriculture Commissioner Ron Sparks is headed for the general election in Alabama, as he defeated the person most observers expected to win the Democratic gubernatorial nomination, Rep. Artur Davis. Sparks led 65-35 percent with nearly 60 percent of the votes counted when the AP called the race.

The winner will likely have to await the Republican challenger, as Tim James, Bradley Byrne and Robert Bentley were all within 1 point of each other. With no one taking more than 26% so far, the top two finishers will need to move on to a July 13 runoff.

Davis left behind a safe congressional district and was hoping to become the state's first black governor -- more than a lofty goal in the state still scarred by its racial history.

Noting that many had questioned his decision to leave behind his seat for such a challenge, Davis, in December, replied: "Something is stirring in Alabama right now."

Gallup's generic polling shows the number of voters saying that they would vote for Republicans rising three points from last week, while the number saying they will vote for Democrats dropped four points.  The 49%-43% lead for the Republicans is the largest that the pollster has ever recorded for the party.  Moreover, Democratic enthusiasm for voting this fall fell a point, while enthusiasm among Republicans stayed about fifteen points higher.  This indicates an even wider lead for Republicans once Gallup imposes a likely voter screen this fall.

There's any number of reasons for this:  the public's perception of Obama's response to the oil spill, the shaky stock market performance last week, continued concern about the economy and spending.  The bottom line is that, despite what is perceived as an underperformance for the Republicans in PA-12 a couple of weeks ago, there are still plenty of Democrats in trouble for this November.

Nothing is as tried and true in politics as running ads against "politicians." A handful of new ads today all use that same foil.

In California alone there are three new spots out ahead of next Tuesday's primary. Democrat Jerry Brown launched the first spot of his campaign today, which makes the point that "While the politicians are fighting, 2.3 million Californians out of work."

Brown has spent more years in elected politics than his potential GOP rivals, but he uses their heavy campaign spending against them nonetheless.

One of those Republicans, former eBay CEO Meg Whitman, also has a new ad in which she tells viewers, "I'm running for governor to clean up the mess those politicians have made in Sacramento."

Did you know that Mickey Kaus is running for Senate? He's challenging Barbara Boxer in the Democratic primary, and uses the Paul Wellstone playbook to make the case that he "is no politician."

And in Arkansas, Lt. Gov. Bill Halter has another ad in his runoff campaign against Sen. Blanche Lincoln (D). He says, "The only way to change Washington is to change who we send there."

South Dakota's lone congresswoman, Stephanie Herseth Sandlin (D), is currently polling below the 50% mark against three potential Republican opponents, a new Rasmussen survey finds (May 27, 500 LV, MoE +/- 4.5%). Republicans tested against her include: Secretary of State Chris Nelson, and state Reps. Kristi Noem and Blake Curd.

Running for her fourth full term, Herseth Sandlin is a leader of the fiscally conservative Blue Dog Democrats. She has won her last two elections with at least 68% of the vote, but won her 2004 special election and general election with 51% and 53%.

Herseth Sandlin 47 - Nelson 43 - Und 6

Herseth Sandlin 46 - Noem 43 - Und 8

Herseth Sandlin 48 - Curd 41 - Und 8

Public Policy Polling (D) takes a look at both primaries for governor in Michigan, and finds both parties with competitive races.

Republican Primary Election Matchup
(377 RVs, 5/25-27, MoE +/- 5.1%)
Snyder 20
Hoekstra 19
Cox 17
Bouchard 15
Und 20

PPP finds that Rick Snyder's lead the GOP primary is boosted by strong support from independent voters eligible to participate in the August 3 contest. Snyder leads among indies with 36 percent, compared to 24 percent for Oakland County Sheriff Mike Bouchard and 18 percent for Rep. Pete Hoekstra. Snyder's "one tough nerd" ad campaign may be one reason why. Among Republicans only it's a much tigher race between Hoekstra (19%), Attorney General Mike Cox (18%) and Snyder (16%).

Democratic Primary Election Matchup
(314 RVs, 5/25-27, MoE +/- 5.5%)
Bernero 26
Dillon 23
Und 51

In the general election, RCP classifies the race as Lean Republican.

A new Rasmussen survey of the Rhode Island gubernatorial race finds former GOP Sen. Lincoln Chafee (I) and state Treasurer Frank Caprio (D) close in a three-way general election race, with both former state Rep. Victor Moffit (R) and John Robitaille (R), a former aide to Gov. Don Carcieri, in third. With Attorney General Patrick Lynch running as the Dem, the Republicans place second.

Chafee (I) 37 - Robitaille (R) 29 - Lynch (D) 19 - Und 15

Chafee (I) 35 - Caprio (D) 32 - Robitaille (R) 25 - Und 9

Chafee (I) 35 - Moffitt (R) 28 - Lynch (D) 24 - Und 13

Caprio (D) 35 - Chafee (I) 33 - Moffitt (R) 22 - Und 10

The survey was conducted May 27 of 500 LV with a MoE of +/- 4.5%.

Former Iowa Gov. Terry Branstad (R) is the favorite to win his party's nomination and the right to seek his old job again this fall, a new Public Policy Polling (D) survey finds. But in this anti-establishment year, the former four-term executive is not the runaway choice.

Gubernatorial Primary Election Matchup
(474 LVs, 5/25-27, MoE +/- 4.5%)
Branstad 46
Vander Plaats 31
Roberts 13
Und 11

Because it's Iowa and because we're already looking toward the presidential caucuses, it's worth noting that this race has reignited a battle. Mitt Romney has endorsed Branstad, while 2008 caucus winner Mike Huckabee has endorsed and campaigned with Bob Vander Plaats.

In another primary in the Hawkeye State next week, PPP finds attorney Roxanne Conlin leading the Democratic field in the Senate race. She's at 48 percent, well ahead of Bob Krause (13 percent) and Tom Fiegen (8 percent); 31 percent are undecided. Notably, the Des Moines Register endorsed Fiegen this weekend, saying of Conlin: "we were surprised and disappointed she was not knowledgeable about and so oversimplified the details of important policy." The winner faces Chuck Grassley in a race RCP calls Likely Republican.

It's primary day in three states -- Alabama, Mississippi and New Mexico. There are several races to watch today, including AL-5 GOP primary, MS-1 GOP primary and NM Gov GOP primary. For more on these and other races, check out some local newspaper stories from each state:

Montgomery Advertiser (AL):

Alabama's chief election official expects more than one-third of Alabama's voters to participate in Tuesday's primary, which means the millions that some candidates spent would have been enough to take each likely voter to lunch at a fast-food restaurant.

Clarion Ledger (MS):

Jo Hubbard said she doesn't plan to cast a ballot in today's primary elections because there isn't a challenger in the party race she is supporting. But Steven Dampier said he is voting because "that's just how I was raised. I was raised to vote." These conflicting takes from the two Brandon residents on the 2010 congressional primaries likely will determine who turns out at polls across the state today.

Santa Fe New Mexican (NM):

The GOP gubernatorial race turned nasty in the closing weeks of the campaign, as front-runners Susana Martinez and Allen Weh punched and counterpunched with television attack ads. GOP state chairman Harvey Yates waded into the dispute a week before the election, declaring that one of Weh's ads was "dishonest" and "inappropriate."