Justia Election Law Opinion Summaries

After the Missouri legislature enacted a new congressional redistricting map in 2025, two groups of residents challenged its constitutionality. The residents argued that the map violated article III, section 45 of the Missouri Constitution, which requires congressional districts to be comprised of contiguous territory, to be as compact as possible, and to have nearly equal populations. Their claims focused particularly on districts 4, 5, and 6, alleging lack of compactness, improper splitting of Kansas City communities, and that a voting tabulation district (KC 811) was assigned to two congressional districts, violating contiguity and equal population requirements.The Circuit Court of Jackson County consolidated the two cases and held a bench trial. After reviewing extensive expert and lay testimony, statistical measures of compactness, and evidence regarding county and municipal splits, the circuit court found that the 2025 Map was more compact than prior maps, satisfied contiguity and equal population requirements, and did not violate the constitutional standards. The circuit court rejected claims regarding community splits and alternative maps, emphasizing its role was not to weigh policy preferences but to apply constitutional directives.On appeal, the Supreme Court of Missouri reviewed the circuit court’s factual findings with deference and applied de novo review to legal questions. The Court held that the plaintiffs failed to demonstrate the 2025 Map clearly and undoubtedly violated article III, section 45. The Court emphasized that statistical and historical comparisons supported the circuit court’s findings, and that departures from compactness, if any, were minimal and justified by recognized factors. The Supreme Court of Missouri affirmed the circuit court’s judgment, upholding the constitutionality of the 2025 Map. View "Healey vs. State" on Justia Law

Two Georgia voters, William T. Quinn and David Cross, independently analyzed Georgia’s voter registration list by comparing it with the United States Postal Service’s National Change of Address database. Believing they had found evidence that the Secretary of State was not properly maintaining the voter rolls as required by the National Voter Registration Act of 1993 (NVRA) and state law, they notified the Secretary, requesting that potentially ineligible voters be flagged and notified. When the Secretary did not respond, the plaintiffs filed suit, asserting that this alleged failure undermined their confidence in the election process and risked diluting their votes.The United States District Court for the Northern District of Georgia dismissed the case for lack of Article III standing. The district court found that the plaintiffs’ claimed injuries—undermined confidence in elections and risk of vote dilution—were generalized grievances common to all Georgia voters, not injuries particularized to the plaintiffs themselves. The court reasoned that any voter could express similar concerns based on the state’s alleged noncompliance with the NVRA, and that such concerns were too speculative to confer standing.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The Eleventh Circuit held that the plaintiffs’ alleged injuries were not particularized, as the supposed harm—loss of confidence in the electoral process—equally affected all Georgia voters. The court concluded that merely discovering or believing in government error, even after personal investigation, does not transform a generalized grievance into a particularized injury sufficient for federal court standing. Thus, the plaintiffs lacked standing, and the dismissal was affirmed. View "Quinn v. Secretary of State, State of Georgia" on Justia Law

The case concerns the process by which a proposed constitutional amendment, authorizing partisan gerrymandering of congressional districts in Virginia, was submitted to the voters. The General Assembly approved the proposed amendment during a disputed special session in October 2025, after voting in the general election for the House of Delegates had already begun. Approximately 1.3 million votes had been cast before the General Assembly’s first vote on the amendment. The General Assembly then approved the proposal again in the 2026 regular session, and the amendment was put to a popular vote, ultimately passing by a narrow margin. The new map, contingent on the amendment’s approval, would have significantly shifted the partisan balance of Virginia’s congressional delegation.The Circuit Court of Tazewell County reviewed challenges to the constitutional amendment process, focusing on whether the requirements of Article XII, Section 1 of the Virginia Constitution, which governs the procedure for amending the state constitution, were properly followed. The central issue was whether the intervening general election required by the Constitution occurred after the General Assembly’s first vote on the amendment but before the second, thus giving voters the intended opportunity to influence the process.The Supreme Court of Virginia held that the legislative process used to advance the proposed amendment violated Article XII, Section 1 of the Virginia Constitution because the first legislative vote occurred after voting in the general election had already begun. The court concluded that the “general election” includes the entire period when votes are cast, not just Election Day, and strict compliance with the constitutionally mandated procedure is required. As a result, the referendum and the amendment were declared null and void. The court affirmed that the existing, nonpartisan congressional maps remain in effect for the upcoming elections. View "Scott v. McDougle" on Justia Law

This case involves challenges to the ballot title certified by the Oregon Attorney General for Initiative Petition 64 (2026), which proposes to add a provision to the Oregon Constitution. Under current law, individuals charged with crimes who are found unfit to aid and assist in their defense cannot proceed to trial and may be committed for restoration of fitness, but such commitment is limited to a maximum period based on the seriousness of the charge. The proposed measure would require these individuals, if found to require a hospital level of care due to public safety concerns, to be committed to a secure state-funded facility until a court determines they are fit or no longer require such care—removing the current statutory limit on the duration of their commitment.After the Attorney General certified the ballot title, petitioners—both as Oregon electors and as the chief petitioner for IP 64—filed timely challenges. They argued that the caption and the “yes” result statement of the certified ballot title were inaccurate and misleading. Specifically, they contended that the language incorrectly stated that such defendants “cannot be prosecuted,” when, in reality, prosecution is merely paused during the restoration process, and that the ballot title failed to inform voters that the measure would eliminate statutory time limits on commitment, allowing for potentially indefinite detention.The Supreme Court of the State of Oregon agreed with the petitioners. The court found that the caption and the “yes” result statement did not substantially comply with the requirements of ORS 250.035(2), as they mischaracterized the status of prosecution and failed to identify a major effect of the measure. The court referred the ballot title back to the Attorney General for modification. View "Paden v. Rayfield" on Justia Law

A candidate for the South Windsor town council in the November 2025 municipal election challenged the town clerk’s decision regarding the application of revisions to the town charter. During the same election in which council members were chosen, voters also approved, by referendum, changes to the charter that altered the party composition rules for the council, reducing the maximum number of members who could be from the same political party from six to five. The town clerk determined that these new limits applied immediately to the 2025 election, even though meeting minutes from the Charter Revision Commission indicated the changes would not take effect until 2027. As a result, the clerk declared a Republican candidate, rather than the plaintiff (a Democrat who otherwise would have won under the prior rules), as the winner of the final council seat.A lawsuit was filed in the Superior Court for the judicial district of Hartford under statutes providing expedited review for those aggrieved by rulings of election officials in municipal elections. The plaintiff argued that the clerk’s decision to apply the new charter revisions to the 2025 election was erroneous. The trial court dismissed the action, concluding it lacked subject matter jurisdiction because the clerk’s decision was not a “ruling of an election official” within the meaning of the relevant statutes.On appeal, the Connecticut Supreme Court addressed whether the clerk’s determination constituted a “ruling of an election official” for the purposes of the statutes governing election disputes. The court held that the town clerk’s decision to apply the newly adopted charter provisions to the current election was indeed a ruling of an election official. The Supreme Court reversed the trial court’s dismissal and remanded the case for further proceedings. The decision clarified that applying or interpreting laws affecting the determination of election outcomes falls within the statutory jurisdiction for expedited election challenges. View "Amadasun v. Armstrong" on Justia Law

A bond measure election was conducted by a school district to fund improvements, requiring 60% approval to pass. On election day, due to a ballot distribution mistake at one precinct, ballots including the bond measure were given to all voters, including those residing outside the district. Later, officials corrected the error, but evidence indicated that up to 70 ballots with the measure were cast by unqualified voters. The measure ultimately passed with 61.3% approval.Following the election, the contest was brought before the Washington County Election Contest Board (“contest court”) based on the allegation of “illegal votes.” The contest court rejected the challenge, reasoning that even if all votes from the affected precinct were excluded, the bond measure would still pass by the required majority. The contestants appealed to the Iowa District Court for Washington County, where the district court found that the contest was not based on misconduct by precinct officials but on illegal votes, and concluded the contestants failed to comply with Iowa Code section 62.5(2)(e), which requires a statement naming the persons alleged to have voted illegally.The Iowa Supreme Court reviewed the district court’s interpretation of the statutory requirements for election contests. The court held that under Iowa law, the right to contest an election is strictly statutory, and contestants must strictly comply with the statutory provisions necessary to confer jurisdiction. Because the appellants did not provide the names of the persons alleged to have voted illegally as required by Iowa Code section 62.5(2)(e), their election contest could not proceed. The Iowa Supreme Court affirmed the district court’s ruling. View "In re: Election Contest of Highland School Bond Referendum" on Justia Law

After the 2020 census, Louisiana redrew its congressional districts, enacting a map (HB1) with only one majority-black district. Plaintiffs challenged this map in the United States District Court for the Middle District of Louisiana, arguing that it diluted black voting power in violation of Section 2 of the Voting Rights Act. The court agreed, finding a likely Section 2 violation and ordering the state to add a second majority-black district. To avoid a court-imposed map, the legislature enacted a new map (SB8) with a second majority-black district, which connected distant black populations across the state.The new SB8 map was then challenged as an unconstitutional racial gerrymander in the United States District Court for the Western District of Louisiana (a three-judge court). The court found that race predominated in the drawing of SB8’s District 6 and that the state could not justify its actions under the Equal Protection Clause. The court concluded that the state had failed to show that Section 2 of the Voting Rights Act required the creation of an additional majority-black district or that compliance with the Act was a compelling interest. The court therefore held SB8 unconstitutional.On direct appeal, the Supreme Court of the United States addressed whether compliance with Section 2 of the Voting Rights Act can ever justify intentional race-based districting. The Court held that Section 2, properly interpreted, requires liability only when there is a strong inference of intentional discrimination, not merely disparate impact. The Court also clarified that a plaintiff’s illustrative maps must satisfy all the state’s legitimate districting goals without using race as a predominant factor and that evidence of racially polarized voting must be disentangled from partisan affiliation. The Supreme Court affirmed the district court’s ruling, holding that Louisiana’s SB8 map was an unconstitutional racial gerrymander because Section 2 did not require a second majority-black district, and no compelling interest justified the use of race. The case was remanded for further proceedings. View "Louisiana v. Callais" on Justia Law

A resident of Lebanon County submitted a request under Pennsylvania’s Right-to-Know Law (RTKL) to obtain the cast vote records (CVRs) for each precinct and the central tabulator used in the 2020 General Election in Lycoming County. The Lycoming County Office of Voter Services denied the request, asserting that CVRs constituted the “contents of ballot boxes and voting machines,” which are exempt from public disclosure under Section 308 of the Election Code. Following administrative appeal, the Office of Open Records upheld the denial based on affidavits that characterized CVRs as the digital equivalent of individual ballots.The case was then appealed to the Lycoming County Court of Common Pleas. The trial court determined that the original requester lacked standing but allowed three Lycoming County voters to intervene. The court found that “contents of ballot boxes and voting machines” referred only to physical ballots and the mechanical workings of voting machines, not to digital data or CVRs. It ordered disclosure of the CVRs, finding no violation of ballot secrecy, especially given data randomization. The Department of State and Voter Services appealed, and the Commonwealth Court reversed. The Commonwealth Court concluded that CVRs fell within the meaning of “contents” and that voting machines, as used in the Election Code, included electronic systems like those in Lycoming County.The Supreme Court of Pennsylvania reviewed the case and reversed the Commonwealth Court. It held that CVRs are not the “contents of ballot boxes and voting machines” as those terms are used in Section 308 of the Election Code. Therefore, CVRs are not exempt from disclosure and are required to be made public under the Election Code’s provisions for public access to election records. The Court clarified that disclosure of CVRs, as randomized in Lycoming County, does not violate the constitutional requirement of ballot secrecy. View "Honey v. Lycoming Co. Offices of Voter Svcs." on Justia Law

A nonprofit organization focused on election integrity requested that Hawaii’s State Elections Office provide a statewide list of registered voters, citing a provision in the National Voter Registration Act of 1993 (NVRA) that allows for public inspection of certain election records. Hawaii’s State Elections Office declined to provide the statewide list and recommended that the organization seek separate county-level lists from each of the four County Clerks, as the Office does not maintain or distribute such a combined list. After receiving this response, the organization sought injunctive and declaratory relief in federal court, arguing that the NVRA entitled it to the statewide voter list.The United States District Court for the District of Hawaii dismissed the action, holding that the organization’s claim was not ripe because it had not first requested the information from the counties. The court found there was no Article III jurisdiction, as the organization had not suffered a concrete injury and could still pursue county-level records. The district court allowed time for the organization to amend its complaint if its claims became ripe, but the organization declined, maintaining that the NVRA required disclosure by the State. Final judgment was entered, and the organization appealed.The United States Court of Appeals for the Ninth Circuit reviewed the case and determined that the organization did have standing, as the denial of information requested under the NVRA constitutes a sufficient injury for Article III purposes. The appellate court also found the claim to be ripe, as the State had made clear it would not provide the requested information. However, on the merits, the Ninth Circuit held that the NVRA does not require disclosure of a statewide voter list, as such a list is not a record “concerning the implementation” of list-maintenance programs under the statute. The court therefore affirmed dismissal, but on the merits, and remanded with instructions to dismiss the claim with prejudice. View "PUBLIC INTEREST LEGAL FOUNDATION, INC. V. NAGO" on Justia Law

Three individuals, Barbara Moore, Vanessa Reed, and Christine Burrell, served as members of the Lipscomb City Council, each representing a different district. After a city council meeting in May 2025, the council rejected a proposed redistricting plan and resolved to keep district boundaries unchanged. However, in the August 2025 municipal election, the election was conducted using the rejected redistricting map. Despite this, the three council members were sworn into office for their respective districts under the original boundaries. Mayor Robin Sims, claiming the council members no longer met residency requirements due to the district lines used in the election, filed for a temporary restraining order (TRO), a permanent injunction, and a writ of quo warranto, seeking their removal from office.The Jefferson Circuit Court, Bessemer Division, issued the TRO, then granted the writ of quo warranto and the permanent injunction, finding that the council members did not meet the statutory residency requirements and declaring their seats vacant. The court denied the council members’ motion to dismiss and their subsequent postjudgment motion, holding that they were unlawfully occupying their seats. The court also denied their request to stay enforcement of its judgment pending appeal.On appeal, the Supreme Court of Alabama reviewed whether the trial court had subject-matter jurisdiction. The Supreme Court held that the trial court lacked subject-matter jurisdiction because the statutory requirement that an informant provide security for costs at the commencement of a quo warranto action was not satisfied. The bond posted was solely for the injunction, not for the quo warranto proceeding. Because this requirement is jurisdictional, the trial court’s judgment was void. The Supreme Court of Alabama reversed the judgment and remanded the case with instructions for the trial court to vacate its judgment. View "Moore v. State of Alabama ex rel. Mayor Sims" on Justia Law