Justia Election Law Opinion Summaries

The Idaho Attorney General filed a petition seeking to prevent an initiative from appearing on the 2024 general election ballot. The initiative, proposed by Idahoans for Open Primaries, aims to replace Idaho’s closed party primary system with a non-partisan "top four primary" and implement ranked-choice voting for the general election. The Attorney General argued that the signatures supporting the initiative were obtained through false statements, violating Idaho Code section 34-1815, and that the initiative violated the single-subject rule of the Idaho Constitution by proposing two distinct changes to election laws.The Idaho Supreme Court dismissed the Attorney General’s petition on procedural grounds. The court held that allegations of fraud in the signature-gathering process must first be adjudicated in the district court. The court emphasized that its original jurisdiction to issue writs of prohibition and mandamus is limited and that the Secretary of State has no clear legal duty to invalidate signatures based on alleged fraud without a prior judicial determination. The court also found that the Attorney General’s challenge to the initiative on the grounds that it violated the single-subject rule was not ripe for review, as the initiative had not yet been approved by voters.The Idaho Supreme Court concluded that the Secretary of State’s role in the initiative process is ministerial and does not include adjudicating the validity of signatures based on alleged misrepresentations. The court dismissed the petition, allowing the initiative to proceed to the ballot, but noted that the Attorney General could pursue his claims in the appropriate district court. View "Labrador v. Idahoans for Open Primaries" on Justia Law

The Idaho Attorney General filed a petition seeking to prevent an initiative from appearing on the 2024 general election ballot. The initiative, proposed by Idahoans for Open Primaries, aims to replace Idaho’s closed party primary system with a non-partisan “top four primary” and implement ranked-choice voting for the general election. The Attorney General argued that the signatures supporting the initiative were obtained through false statements and material omissions, violating Idaho Code section 34-1815, and that the initiative violated the single-subject rule of the Idaho Constitution by proposing two distinct changes to election laws.The Idaho Supreme Court dismissed the Attorney General’s petition on procedural grounds. The court held that allegations of fraud in the signature-gathering process must first be adjudicated in the district court. The court emphasized that its original jurisdiction to issue writs of prohibition and mandamus is limited and that such writs are proper only when a state actor has a clear legal duty to act. The court found that the Secretary of State had no clear legal duty to invalidate the signatures based on the Attorney General’s allegations and that the Secretary’s role in the initiative process is ministerial, not adjudicatory.The court also addressed the Attorney General’s claim that the initiative violated the single-subject rule. It concluded that this issue was not ripe for review because the initiative had not yet been approved by voters. The court stated that substantive challenges to an initiative’s constitutionality are not justiciable before the initiative becomes law. The court’s decision does not preclude the Attorney General from pursuing his claims in the district court. View "Labrador v. Idahoans for Open Primaries" on Justia Law

The Attorney General of California drafted language for the ballot title, summary, and label for Proposition 5, a proposed amendment to the California Constitution that would allow certain local bonds to be approved by 55 percent of voters instead of the current two-thirds requirement. Jon Coupal and the Howard Jarvis Taxpayers Association challenged the ballot label, arguing it was misleading because it did not mention the existing two-thirds approval requirement. They claimed this omission failed to inform voters of the measure's true purpose.The Superior Court of Sacramento County agreed with the challengers, finding that the ballot label did not adequately inform voters of the measure's chief purpose. The court ordered the Attorney General to revise the ballot label to include the current two-thirds approval requirement. The Attorney General then filed a petition for writ of mandate in the Court of Appeal of the State of California, Third Appellate District, challenging the Superior Court's decision.The Court of Appeal concluded that the ballot label drafted by the Attorney General accurately and concisely described Proposition 5 and was not misleading. The court emphasized that the Attorney General is afforded considerable discretion in drafting ballot materials and that the label's language was factually accurate. The court found that the Superior Court failed to accord the proper discretion to the Attorney General and that there was no clear and convincing evidence that the ballot label was misleading. Consequently, the Court of Appeal issued a peremptory writ of mandate directing the Superior Court to deny the challengers' petition and allow the Attorney General's original ballot label to be used. View "Bonta v. Super. Ct." on Justia Law

Four registered voters and several non-profit organizations sued the Cobb County Board of Elections and Registration, alleging that the 2022 redistricting map for the Cobb County School Board was an unconstitutional racial gerrymander. They claimed the map packed Black and Latino voters into certain districts to dilute their political power and maintain a majority white School Board. The plaintiffs sought declaratory and injunctive relief to prevent the use of the 2022 map in future elections.The Cobb County School District intervened as a defendant and moved for judgment on the pleadings, arguing it was not liable for any constitutional violation because the Georgia General Assembly, not the School Board, enacted the map. The district court granted the School District’s motion based on Monell v. Department of Social Services of New York, but did not immediately enter judgment. The School District continued to participate in the case, prompting the court to formally terminate it as a party. The plaintiffs and the Election Defendants then entered a settlement, leading to a preliminary injunction against the 2022 map.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court dismissed the School District’s appeal for lack of jurisdiction, holding that the School District, as a nonparty, lacked standing to appeal the preliminary injunction. The court emphasized that only parties or those who properly become parties may appeal, and the School District had not sought to reintervene for purposes of appeal. The court also noted that the School District’s participation as an amicus did not grant it the right to appeal. View "Cobb County School District" on Justia Law

In a special election for Chatham County Commissioner, Jeffry L. Miller, an elector, filed a pro se petition against several Chatham County election officials and candidate Malinda Jane Scott Hodge. Miller contested the election results, arguing that Hodge was ineligible due to residency requirements and her former position on the Chatham County Board of Elections. He also claimed that the use of a QR code on the ballot was illegal and that the election officials failed to provide proper notice of redistricting.The trial court held an evidentiary hearing but did not issue a ruling before the runoff election. Miller did not call any witnesses or present new evidence at the hearing. The runoff election proceeded, and the trial court later dismissed Miller's petition, ruling that Hodge was eligible and that the special election results were valid. The court also found that Miller's petition was moot due to the subsequent runoff election. Miller appealed to the Supreme Court of Georgia.The Supreme Court of Georgia dismissed the appeal, citing long-standing precedent that election challenges must be resolved with dispatch before a subsequent election occurs. The court emphasized that Miller failed to seek an expedited ruling or a stay of the runoff election. The court clarified that while the occurrence of a subsequent election does not necessarily moot an election contest, prudential reasons and statutory framework require swift resolution of such disputes. The court concluded that Miller's delay and failure to utilize available procedures warranted dismissal of the appeal. View "Miller v. Hodge" 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 challenge to Arizona's voter registration law, specifically A.R.S. § 16-121.01(C), which requires documentary proof of citizenship (DPOC) for voter registration. Plaintiffs, including various advocacy groups and individuals, argued that this law conflicts with a prior consent decree (LULAC Consent Decree) that allows voter registration without DPOC for federal elections. The district court issued an injunction barring the enforcement of the law, leading to an appeal by the Intervenors-Defendants-Appellants, including the Republican National Committee and Arizona state legislators.The United States District Court for the District of Arizona ruled in favor of the plaintiffs, finding that the new law violated the LULAC Consent Decree. The court issued an injunction preventing the enforcement of A.R.S. § 16-121.01(C). The Intervenors-Defendants-Appellants filed an emergency motion to stay the district court's judgment, which was partially granted by a motions panel of the Ninth Circuit Court of Appeals. The motions panel stayed the injunction concerning A.R.S. § 16-121.01(C) but left the rest of the district court's judgment intact.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court granted the plaintiffs' emergency motion for reconsideration of the partial stay. The Ninth Circuit vacated the motions panel's order that had stayed the district court's injunction against enforcing A.R.S. § 16-121.01(C). The court found that the Intervenors-Defendants-Appellants did not demonstrate a strong likelihood of success on the merits or a high degree of irreparable injury. The court emphasized the importance of maintaining the status quo in election cases to avoid voter confusion and potential disenfranchisement, citing the Supreme Court's decision in Purcell v. Gonzalez. The court concluded that the balance of hardships and public interest favored vacating the stay. View "MI FAMILIA VOTA, V. MAYES" on Justia Law

A nonpartisan candidate filed a complaint challenging the primary election ballot in Hawaii, arguing that the requirement for voters to select a political preference violated the Hawaii Constitution and various state statutes. The plaintiff sought an order to redesign the ballot and declare the current ballot invalid.The State of Hawaii, Office of Elections, and the Chief Election Officer moved to dismiss the complaint for failure to state a claim or lack of jurisdiction. The Supreme Court of Hawaii reviewed the case and found that the plaintiff's claims under HRS §§ 11-173.5, 11-174.5, and 91-14 were not valid because no election results had been posted, which is a prerequisite for these statutes. Additionally, the court found that the plaintiff did not have standing to challenge all statewide ballots under HRS § 11-172, as he was only a candidate in the Mayor's race in Honolulu. The court also determined that the plaintiff's complaint did not state a claim under HRS § 11-172 because the alleged ballot defects would not impact his nonpartisan race.The Supreme Court of Hawaii dismissed the election contest claims for failure to state a claim. The court also construed the complaint as a petition for a writ of mandamus but denied the petition, finding that the plaintiff did not establish a clear and indisputable right to the relief requested or a lack of other means to address the alleged wrong. The court entered judgment in favor of the defendants. View "Dicks v. State " on Justia Law

The Stark County Board of Elections considered and voted to purchase Dominion Voting Systems equipment during four meetings. These discussions and decisions occurred in executive sessions, which are closed to the public. Look Ahead America and Merry Lynne Rini filed a complaint alleging that the board violated Ohio’s Open Meetings Act by not limiting its executive-session discussions to matters where premature disclosure would give an unfair competitive or bargaining advantage.The Stark County Court of Common Pleas upheld the board’s actions, interpreting R.C. 121.22(G)(2) to mean that the premature-disclosure clause applied only to the last-listed reason for entering executive session, not to the purchase of property. The Fifth District Court of Appeals affirmed this decision, agreeing with the trial court’s interpretation.The Supreme Court of Ohio reviewed the case and disagreed with the lower courts. The court held that the premature-disclosure clause in R.C. 121.22(G)(2) applies to all the permissible reasons listed for entering executive session, not just the last one. The court reversed the Fifth District’s judgment and remanded the case to the trial court for a new trial applying this interpretation. View "Look Ahead Am. v. Stark Cty. Bd. of Elections" on Justia Law