Justia Election Law Opinion Summaries

The case involves a challenge to Indiana's ballot access laws by the Indiana Green Party, the Libertarian Party of Indiana, and associated individuals. They argue that the requirements for candidates to collect signatures amounting to 2% of the votes cast in the last Secretary of State election, the process for submitting petitions, and the early deadline for submission are unconstitutional under the First and Fourteenth Amendments. They also challenge the law's indexing of party-level access to the results of the most recent Secretary of State election.The United States District Court for the Southern District of Indiana granted summary judgment in favor of the defendant, Indiana’s Secretary of State. The district court concluded that the 2% signature requirement and the June 30 deadline for submitting petitions were constitutionally permissible, relying on precedent from the Supreme Court and the Seventh Circuit. The court did not address the burdens created by the county-level submission requirement or the challenge to the indexing of the full slate access option.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court held that Indiana's ballot access requirements do not impose severe burdens on the plaintiffs' rights. The 2% signature requirement, the June 30 deadline, and the county-level submission process were deemed reasonable and justified by the state's interests in preventing voter confusion and ensuring orderly elections. The court also found that the requirement for parties to garner 2% of the vote in the Secretary of State election to maintain full slate access was reasonable, given the alternative petitioning route available to candidates. The court concluded that the state's regulatory interests were sufficient to justify the challenged restrictions. View "Indiana Green Party v. Morales" on Justia Law

Colby Jenkins contested the results of the 2024 primary election for the Utah Republican Party candidate for the U.S. House of Representatives in Utah’s Second Congressional District. After a recount, election officials determined that Celeste Maloy had won by a narrow margin. Jenkins challenged the rejection of certain ballots that were deemed untimely because they were not postmarked by the deadline specified in Utah’s election code. He argued that these ballots were mailed before election day but were delayed in receiving a postmark due to variations in U.S. Postal Service practices.The Lieutenant Governor questioned whether Jenkins had the standing to assert constitutional arguments on behalf of the voters whose ballots were not counted. However, the court did not need to decide on this issue because Jenkins failed to establish that he was entitled to the relief he sought. Jenkins argued that the statutory postmark requirement resulted in unequal treatment of voters and interfered with the fundamental right to vote. However, he did not adequately brief these constitutional arguments, failing to cite relevant case law or provide sufficient analysis.The Utah Supreme Court denied Jenkins’s petition for extraordinary relief. The court held that Jenkins did not meet his burden of demonstrating a constitutional violation. Specifically, Jenkins did not show that election officials failed to comply with any statutory mandate, nor did he provide adequate legal support for his claims that the postmark requirement was unconstitutional. The court concluded that voters could ensure their ballots were timely postmarked by mailing them well in advance or by taking them directly to the post office. Therefore, the petition was denied. View "Jenkins v. Beaver County" on Justia Law

In this case, the plaintiffs, Election Integrity Project California, Inc., and ten former political candidates, challenged the California Secretary of State’s certification of the November 2020 general election results and sought to declare California’s vote-by-mail election system unconstitutional. They alleged that state and county officials diluted the voting power of in-person voters and voters in certain counties by inadvertently counting some invalid vote-by-mail ballots.The United States District Court for the Central District of California dismissed the plaintiffs’ claims for failure to state a claim. The district court concluded that even if all the plaintiffs’ allegations were true, they failed to state plausible claims of constitutional violations in the administration of California’s elections. The plaintiffs appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal. The Ninth Circuit held that the plaintiffs’ vote dilution claim failed as a matter of law because they did not show disproportionate voting power for some voters over others. The court found that any effect of counting invalid vote-by-mail ballots was the same for all votes, regardless of voting method or geography. The court also rejected the plaintiffs’ claim that California’s election laws and county practices violated the Equal Protection Clause, finding that the state’s election rules and practices satisfied the requirements of equal treatment and fundamental fairness. Additionally, the court found that the plaintiffs’ allegations of election irregularities did not plausibly demonstrate the scale of disenfranchisement or lack of integrity necessary to state a due process claim.Finally, the Ninth Circuit held that the district court did not abuse its discretion by denying the plaintiffs a further opportunity to amend their complaint, as any further amendment would likely prove futile. The court affirmed the district court’s order dismissing the plaintiffs’ claims without leave to amend. View "ELECTION INTEGRITY PROJECT CALIFORNIA, INC. V. WEBER" on Justia Law

The case involves a challenge to the Re-Enfranchisement Act, which allows individuals convicted of felony-level offenses to vote once they are no longer incarcerated. The plaintiffs, individual taxpayers and the Minnesota Voters Alliance, argued that the Act violates the Minnesota Constitution by restoring only the right to vote rather than all civil rights. They also claimed that using public funds to educate and notify people about the new voting provision is unlawful if the Act itself is unconstitutional.The district court denied the petition, concluding that the plaintiffs lacked standing. The court determined that taxpayer standing requires a challenge to an illegal expenditure or waste of tax money, which the plaintiffs failed to demonstrate. The court also found that the Minnesota Voters Alliance lacked associational standing because its members did not have standing.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court clarified that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. The court held that the plaintiffs could not manufacture standing by pointing to incidental expenditures related to implementing the law. Since the plaintiffs' challenge was primarily against the substantive law itself and not the expenditures, they lacked the necessary standing. Consequently, the Minnesota Voters Alliance also lacked associational standing. The court did not address the merits of the case due to the lack of standing. View "Minnesota Voters Alliance vs. Hunt" on Justia Law

A nominee for Lieutenant Governor in Georgia and the Libertarian Party of Georgia challenged a state law that allows only certain political parties to form "leadership committees" capable of accepting unlimited campaign contributions. The Libertarian Party, classified as a "political body" under Georgia law, was excluded from forming such committees, which they argued violated their First Amendment and Equal Protection rights.The United States District Court for the Northern District of Georgia denied the plaintiffs' motion for a preliminary injunction. The court found that the plaintiffs lacked standing because their alleged injury was not traceable to the defendants and could not be redressed by the requested relief. The court also noted that the plaintiffs failed to show that the defendants had enforced or threatened to enforce the law against them. Additionally, the court concluded that the plaintiffs did not meet the prerequisites for a preliminary injunction.The United States Court of Appeals for the Eleventh Circuit reviewed the case and determined it was moot because the 2022 election had already occurred, and the nominee had lost. The court found that the plaintiffs' claims were specific to the 2022 election and did not present a live controversy. The court also rejected the plaintiffs' argument that the case fell under the "capable of repetition yet evading review" exception to mootness, as there was no reasonable expectation that the same controversy would recur involving the same parties.The Eleventh Circuit vacated the district court's judgment, dismissed the appeal, and remanded the case to the district court to dismiss it as moot. View "Graham v. Attorney General" on Justia Law

The case involves a dispute over the Utah Legislature's repeal and replacement of a citizen initiative known as "Proposition 4," which aimed to reform the state's redistricting process to prevent partisan gerrymandering. Proposition 4, passed by Utah voters in 2018, established an Independent Redistricting Commission and set forth neutral redistricting standards, including a prohibition on partisan gerrymandering. However, before the next redistricting cycle, the Utah Legislature enacted Senate Bill 200 (S.B. 200), which repealed Proposition 4 and replaced it with a new law that did not include the same anti-gerrymandering provisions and weakened the role of the Independent Commission.In the Third Judicial District Court, Salt Lake County, the plaintiffs argued that the Legislature's actions violated the Utah Constitution by nullifying the reforms enacted by the people through Proposition 4. The district court dismissed this claim, holding that the Legislature has the authority to amend or repeal any statute, including those enacted by citizen initiative, without limitation. The plaintiffs appealed this decision.The Utah Supreme Court reviewed the case and focused on two constitutional provisions: the Initiative Provision in article VI, section 1, which grants the people the power to initiate legislation, and the Alter or Reform Clause in article I, section 2, which states that the people have the right to alter or reform their government. The court concluded that these provisions, when read together, limit the Legislature's power to amend or repeal a citizen initiative that reforms the government. The court held that the people’s right to reform the government through an initiative is constitutionally protected from legislative actions that would impair the reform enacted by the people.The Utah Supreme Court reversed the district court's dismissal of Count V, which challenged the Legislature's repeal and replacement of Proposition 4, and remanded the case for further proceedings. The court emphasized that legislative changes to a government-reform initiative must not impair the reform and must be narrowly tailored to advance a compelling government interest if they do. View "League of Women Voters v. Utah State Legislature" on Justia Law

The case involves the Upstate Jobs Party (UJP) and two of its leaders who sued the Commissioners of the New York State Board of Elections over campaign finance regulations. UJP, an independent body, argued that it is similarly situated to political parties because both nominate candidates that compete in the same elections. UJP claimed that New York's preferential treatment of parties violates the Fourteenth Amendment right to equal protection. UJP also asserted First Amendment violations, alleging that New York's campaign finance rules distinguishing between parties and independent bodies are not closely drawn to a sufficient state interest in preventing corruption or the appearance thereof.The United States District Court for the Northern District of New York determined that differences in contribution limits applicable to parties and independent bodies violate the Fourteenth and the First Amendments. However, it also determined that allowing parties but not independent bodies to maintain so-called “housekeeping accounts” did not violate either amendment. Both UJP and the State Board appealed.The United States Court of Appeals for the Second Circuit reversed in part and affirmed in part the district court’s judgment. The court held that parties and independent bodies are not similarly situated, and that the state’s contribution limits and housekeeping account exception are closely drawn to serve the state’s anticorruption interests. Therefore, the court concluded that the state’s campaign finance laws withstand all constitutional challenges raised. View "Upstate Jobs Party v. Kosinksi" on Justia Law

A group of Utah voters, led by Ian Daniel Phillips, sought to initiate state legislation that would impose an age limit on Utah candidates for federal office. The Lieutenant Governor of Utah rejected the group's initiative application, concluding that the proposed law was "patently unconstitutional" under U.S. Term Limits, Inc. v. Thornton, a Supreme Court case that forbids states from enacting laws imposing qualifications on candidates for federal congressional office. The group then sued the Lieutenant Governor, seeking a declaration that the initiative is not patently unconstitutional and could become law if enacted.The district court dismissed the group's complaint, ruling that the proposed initiative is "squarely foreclosed by" Thornton, a decision that the court had no authority to overrule. The group appealed, maintaining that Thornton should be overruled because its prohibition on state-created qualifications for federal officeholders violates the Tenth Amendment of the United States Constitution. However, they acknowledged that the Supreme Court of the State of Utah lacks authority to overturn Thornton and asked the court to affirm the district court’s decision, thereby paving the way for them to petition the United States Supreme Court for review.The Supreme Court of the State of Utah affirmed the district court's ruling. The court held that the group had appellate standing, despite their concession that they cannot prevail at this stage of the appeal. The court also agreed with the district court that the proposed law is patently unconstitutional under Thornton. Therefore, the group did not state a claim upon which relief may be granted. View "Phillips v. Henderson" on Justia Law

The case revolves around the petitioner, Ryan Binkley, who sought to have his name included on the Republican Party of Minnesota's ballot for the 2024 presidential nomination primary. However, the Chair of the Republican Party of Minnesota did not include Binkley as a candidate when notifying the Minnesota Secretary of State, Steve Simon, of the candidates for its ballot. Consequently, Binkley and his campaign committee filed a petition with the court, arguing that the procedures established by Minnesota Statutes section 207A.13, subdivision 2(a), which allow a major political party to determine the candidates that will appear on its ballot for the presidential nomination primary, violate the Electors Clause of the United States Constitution.The case was brought before the Minnesota Supreme Court after the petitioners' claim was denied in the lower court. The petitioners argued that the Electors Clause prohibits state-based favoritism on ballots through the exclusion of qualified candidates. The Secretary of State, however, contended that the presidential nomination primary is not subject to the Electors Clause because Minnesota does not use the presidential nomination primary to appoint presidential electors.The Minnesota Supreme Court agreed with the Secretary of State, ruling that the presidential nomination primary is not part of the process that Minnesota uses to appoint presidential electors. Therefore, the statutes that govern the presidential nomination primary do not fall within the scope of the Electors Clause. The court concluded that the petitioners' claim that section 207A.13, subdivision 2(a) violates the Electors Clause fails as a matter of law. The petition was thus denied. View "J. Binkley for President 2024 vs. Simon" on Justia Law

The Supreme Court of Kansas reviewed a case involving the League of Women Voters of Kansas and other organizations against the Kansas Secretary of State and the Kansas Attorney General. The plaintiffs challenged three new Kansas election laws, alleging that they violated various provisions of the Kansas Constitution. The laws in question prohibited the false representation of an election official, prohibited election officials from counting advance ballots that did not have a signature or had a signature that an election official determined did not match the signature on file, and prohibited any person from collecting and returning more than 10 advance ballots for other voters.The case was initially heard in the Shawnee County District Court, which denied the plaintiffs' request for a temporary injunction against the false representation statute. The court also granted the defendants' motion to dismiss the claims against the signature verification requirement and the ballot collection restriction. The plaintiffs appealed these decisions, and the cases were consolidated.The Supreme Court of Kansas held that the plaintiffs had demonstrated a likelihood of prevailing on the merits of their claim that the false representation statute was constitutionally infirm. Therefore, the district court erred in denying their request for a temporary injunction. The court also held that the signature verification requirement was a valid effort by the Legislature to provide "proper proofs" of the right to be a qualified elector. However, the court remanded the case to the district court to consider whether the statute and its implementing regulations complied with the constitutional guarantees of equal protection and due process. Finally, the court affirmed the district court's grant of the defendants' motion to dismiss the claim that the ballot collection restriction was constitutionally infirm, because the restriction was not a new qualification on the right to be an elector, and because the proscribed activity—the delivery of ballots—was not political speech or expressive conduct. View "League of Women Voters of Kansas v. Schwab" on Justia Law