Justia Election Law Opinion Summaries

Plaintiffs, three Minnesota-based grass roots advocacy organizations, challenged a Minnesota law that made it a crime to knowingly, or with reckless disregard for the truth, make a false statement about a proposed ballot initiative under the Minnesota Fair Campaign Practices Act ("FCPA"), Minn. Stat. 211.B06, subd.1. At issue was whether the district court erred when it dismissed plaintiffs' complaint for lack of jurisdiction; when it alternatively held that it would dismiss plaintiffs' complaint for failing to state a claim upon which relief could be granted; and when it denied plaintiffs' motion for summary judgment. The court held that plaintiffs' claims were justiciable and that subject matter jurisdiction was proper in federal court; that plaintiffs did allege First Amendment claims upon which relief could be granted; and that the district court's denial of plaintiffs' motion for summary judgment based on its findings of mootness was vacated. Therefore, the court remanded for additional development of arguments regarding whether section 211.b06 satisfied strict scrutiny.

The United States Secretary of Labor ("Secretary") appealed the district court's grant of summary judgment to Amalgamated Transit Union, Local 1005 ("Local 1005) on the claim that Local 1005's November 2008 election procedures violated the "adequate safeguards" provision of the Labor Management Reporting and Disclosure Act ("LMRDA"), 29 U.S.C. 481(c). At issue was whether the district court applied the wrong legal standard in its analysis and whether the district erred when it determined that Local 1005 did not violate the "adequate safeguards provision" of the LMRDA. The court held that the district court did not apply the wrong legal standard where the district court found no violation of section 481(c). The court also affirmed summary judgment and held that Local 1005's actions regarding the accurate announcement of the sole requirement to stand for elected office, coupled with the fully accurate notices posted both on Local 1005's job site bulletin and boards, as well as on its website, amounted to "adequate safeguards" under the LMRDA.

Appellant George Janiec, a Republican Party candidate for Mayor of the City of Hammond and an incumbent member of the Hammond School Board, was removed from the May 3, 2011 primary election ballot by Appellee Lake County Board of Election and Registration. Appellant challenged the Boardâs decision in Lake Superior Court, requesting judicial review and injunctive relief. The trial court found in favor of the Board. Appellant appealed the trial courtâs decision and sought immediate transfer of the appeal to the Supreme Court. The Board and Lake Superior Court held that Appellantâs candidacy was inconsistent with the ethical policies applicable to members of the Hammond School Board. The Supreme Court found no basis in statute or law for disqualifying Appellant on this basis, and enjoined the Board from removing Appellantâs name from the ballot in the May 2011 primary election.