Justia Election Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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In this case involving a Minnesota voter's request for access to information in Minnesota's statewide voter registration list the Supreme Court held that registered Minnesota voters have access to "public information lists" as defined by law, as well as to information provided by the secretary of state, but the Legislature has restricted access to the other information sought. A statewide voter registration list is contained in the Statewide Voter Registration System (SVRS). The Secretary of State is responsible for administering the SVRS, and the Legislature has allowed some of the information in the SVRS to be made available for inspection in the form of a "public information list." Plaintiff sought access to non-private government data"from the SVRS. The Secretary informed Plaintiff that he was entitled to information in the SVRS related to currently registered Minnesota voters but declined to produce SVRS information on voter status and other issues. The district court ordered the Secretary to produce the requested data. The court of appeals affirmed. The Supreme Court reversed, holding that the relevant provisions of the Minnesota Government Data Practices Act and the Minnesota Election Law provides that access to the voter registration list contained in the SVRS is limited to "public information lists" and to information provided by the Secretary. View "Cilek v. Office of Minnesota Secretary of State" on Justia Law

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The Supreme Court denied Petitioners' petition filed under Minn. Stat. 204B.44(a) asking that the Supreme Court direct the Minnesota Secretary of State to include Roque De La Fuente's name as a candidate for The Republican Party of Minnesota's nomination for United States President on the ballot for the Minnesota presidential nomination primary election on March 3, 2020, holding that Petitioners' claims failed. Petitioners argued that the procedure established by Minn. Stat. 207A.13, which allows a major political party to determine which candidates' names will be on the ballot for a statewide presidential nomination primary, was unconstitutional. The Supreme Court disagreed, holding that section 207A.13 does not violate (1) the prohibition against special privileges because the Legislature had a rational basis for classifying political parties based on a party's participation in a national convention to nominate the party's presidential candidate; (2) the Presidential Eligibility Clause because requiring a political party to identify the candidates for the ballot to be used in a presidential nomination primary is not a condition of eligibility to serve as President of the United States; and (3) Petitioners' rights of free association because any burden imposed on those rights by the ballot preparation procedures is outweighed by the associational rights of political parties and the State's regulatory interests. View "De La Fuente v. Simon" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals holding that a proposed charter amendment was not manifestly unconstitutional but was an improper referendum, holding that the proposed amendment was not an improper exercise of the charter amendment power and was not manifestly unconstitutional. After the City of Bloomington changed from a system of open trash collection to a system of organized collection a group of residents attempted, through an amendment to the City Charter, to require that voters pre-approve a change in the method of trash collection. The City refused to put the proposed charter amendment on the ballot. In the original appeal, the Supreme Court remanded the case to the court of appeals for decision on whether the proposed amendment would violate the Contract Clauses of the United States and Minnesota Constitutions and whether it was an attempt to exercise the voter referendum power through an improper means. On remand, the court of appeals concluded that the proposed amendment was an improper referendum but was not unconstitutional. The Supreme Court reversed in part, holding that the proposed charter amendment was not an improper referendum and did not violate the Contract Clauses. View "Jennissen v. City of Bloomington" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting summary judgment in favor of the City of Saint Paul and dismissing Appellant's petition asserting that the City erred by refusing to put his proposed amendment to the City Charter before the voters in the next election, holding that Appellant did not meet his burden to prove that his petition met statutory requirements. In rejecting the petition, the City relied on the statewide voter registration system (SVRS) in concluding that Appellant's petition did not have the requisite number of signatures. In his petition, Appellant argued that the City erred by relying on the SVRS to invalidate signatures and in refusing to put his proposed charter amendment before voters. The Supreme Court affirmed, holding (1) the City did not err by relying on the SVRS to determine eligibility and rejecting signatures of those who were registered to vote at an address outside the City; and (2) Appellant did not meet his burden to show that the City erred in rejecting the petition signatures. View "Butler v. City of Saint Paul" on Justia Law

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The Supreme Court affirmed the order of the district court directing the City of Saint Paul to put a referendum question regarding the City's ordinance that established organized waste collection in the City on the ballot for the next municipal election, concluding that holding a referendum on the issue will not unconstitutionally impair the City's contract with haulers that provide organized waste collection. The City refused to put the referendum question on the ballot, concluding that the referendum was preempted by state statutes that govern solid waste collection, conflicts with state policy, and would by an unconstitutional interference with the City's contract with the haulers. Respondents with filed a petition challenging the City's refusal. The district court granted the petition. The Supreme Court affirmed, holding that the City has not demonstrated that a substantial impairment of its contractual obligation will occur with the referendum vote, and therefore, the Court need not address the other two factors. View "Clark v. City of Saint Paul" on Justia Law

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State law did not preempt a proposal to amend the charter of the City of Bloomington to require voter approval before the City can implement organized collection of solid waste. Appellants petitioned the City for a ballot initiative seeking the enactment of an ordinance that would require voter approval before the City could implement organized waste collection. The City declined to place Appellants’ proposed amendment on a ballot on the ground that Minn. Stat. 115A.94 preempted the field of regulation by the process by which a city organizes waste collection. The district court granted summary judgment for the City. The court of appeals affirmed. The Supreme Court reversed, holding (1) the legislature did not intend to occupy the field of regulation of the process of organizing collection of solid waste; and (2) therefore, Appellants’ proposed charter amendment was not preempted by state law. View "Jennissen v. City of Bloomington" on Justia Law

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Appellants, members of a Minneapolis citizen group, submitted a petition to the Minneapolis City Council for consideration of a question regarding a proposed amendment to the Minneapolis City Charter. The proposed amendment would require City police officers to obtain and maintain professional liability insurance coverage and would impose other conditions for coverage and indemnification. Concluding that the proposed insurance amendment conflicted with and was preempted by state law, the City Council directed the City Clerk not to include the amendment question on the ballot for the November 2016 election. Appellants filed a petition to challenge that decision. The district court agreed with the City Council and dismissed the petition. The Supreme Court affirmed, holding that the proposed insurance amendment conflicts with state law, and therefore, the district court properly dismissed Appellants’ petition. View "Bicking v. City of Minneapolis" on Justia Law

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After declaring his write-in candidacy for President of the United States for the 2016 general election, Steve Carlson filed a request with the Secretary of State asking him to count the votes cast for his candidacy. The Secretary of State refused to accept the request because Carlson did not “include the name of a candidate for vice-president of the United States” with the request pursuant to Minn. Stat. 204B.09, subdivision 3(b). Carlson then filed this petition with the Supreme Court asking the Court to direct the Secretary of State to accept his request because requiring him to name a vice-presidential candidate burdens the First Amendment associational rights of write-in candidates and the voters who support those candidates. The Supreme Court denied the petition, holding that the requirement for write-in candidates to designate a vice-presidential candidate does not violate the associational rights protected by the First Amendment. View "Carlson v. Simon" on Justia Law

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Petitioner filed a petition pursuant to Minn. Stat. 204B.44 requesting an order directing the Minnesota Secretary of State (Respondent) to remove the name of Robert Barrett from the ballot for State Representative for Legislative District 32B at the general election held in November 2016, alleging that Barrett did not reside in the district for the six months immediately preceding the 2016 general election. The referee to whom the matter was referred found that the evidence supported removing Barrett’s name from the ballot. The Supreme Court granted the petition to the extent it sought an order declaring that Barrett was ineligible to hold the office he sought but denied the petition to the extent it sought an order declaring that Barrett’s name be removed from the 2016 general election ballot for the same office, as Minnesota does does not provide for the removal of a candidate’s name from the ballot under the circumstances of this case. View "Monaghen v. Simon" on Justia Law

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Respondents submitted a petition to the Minneapolis Charter Commission to amend the City Charter to establish a local minimum-wage standard in the City of Minneapolis. The City Clerk certified that the petition met the statutory signature requirements. Reasoning that the minimum-wage amendment was legislature in nature and that the City Charter does not provide for voter initiatives for the passage of ordinances by a ballot referendum, the City Attorney recommended that the City Council decline to place the provision on the November 2016 general election ballot. Thereafter, the City Council voted not to include the wage amendment on the ballot for the general election. Respondents filed a petition asking the district court to order the City Council to place the proposed charter amendment before the voters on the ballot, arguing that the City had a duty to put the proposed amendment on the ballot. The district court granted the petition, concluding that the proposed charter amendment was the proper subject of a citizen initiative. The Supreme Court reversed, holding that the district court erred in granting the petition because Minneapolis residents do not have legislative and policymaking authority under the City Charter. View "Vasseur v. City of Minneapolis" on Justia Law