Justia Election Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
by
The Minnesota Supreme Court ruled that the Legal Marijuana Now Party (LMNP) does not meet the requirements to be classified as a major political party under Minnesota law. The case was initiated by Ken Martin, the chair of the Democratic-Farmer-Labor Party, who filed a petition arguing that the LMNP failed to comply with certain requirements for major political parties. Specifically, Martin claimed that the LMNP did not maintain a state central committee subject to the state convention’s control, as required by Minnesota law.The case was referred to a referee, who concluded that the LMNP had indeed failed to meet the requirements to be a major political party. The LMNP objected to these findings and argued that the relevant statutes unconstitutionally infringed upon its First Amendment associational rights.The Minnesota Supreme Court rejected the LMNP's arguments. It found that the LMNP's single committee, The Head Council, was not subject to the control of the LMNP’s state convention, as required by law. The court also rejected the LMNP’s constitutional challenge, finding that the party failed to demonstrate how the statutory requirements specifically burdened its associational rights. As a result, the court held that the LMNP does not meet all the statutory requirements to maintain its status as a major political party for the upcoming state primary and general elections. View "Martin vs. Simon" on Justia Law

by
In Minnesota, a group of voters sought to prevent former President Donald Trump from appearing on the 2024 presidential primary and general election ballots, arguing that Section 3 of the Fourteenth Amendment of the U.S. Constitution, which disqualifies anyone from holding office who has engaged in insurrection or rebellion against the U.S., rendered him ineligible. The Minnesota Supreme Court held that it would not be an error to place Trump's name on the 2024 Republican Party presidential nomination primary ballot. The court reasoned that the nomination primary is an internal party election, and the state law does not prohibit a major political party from placing an ineligible candidate on the primary ballot. However, the court did not decide on the issue of Trump's name on the general election ballot, stating that the matter was not yet ripe for adjudication as it was not "about to occur" under the relevant state law. The court did not foreclose the possibility of petitioners bringing such a claim at a later date. View "Growe v. Simon" on Justia Law

by
The Supreme Court affirmed in part and reversed in part the decision of the court of appeals concluding that Minnesota Rule 8210.2450, subparts 2 and 3 (the rule) does not conflict with Minn. Stat. 203B.121 (the statute) and that the challenged rule was therefore invalid, holding that subpart 3 of the rule conflicted with subdivision 2(b)(3) of the statute.Appellants brought this declaratory judgment action seeking a prospective declaration that the administrative rule, which governed the acceptance of absentee ballots, was invalid because the rule subparts conflicted with the statute by infringing on discretion the legislature gave to ballot board members. The court of appeals determined that there was no conflict between the rule and the statute. The Supreme Court reversed in part, holding (1) Minn. R. 8210.2450, sub. 3, which authorized any ballot board member to review signatures in the event of an identification number mismatch, was invalid to the extent that the rule conflicted with Minn. Stat. 203B.121, subd.2(b)(3), which required that election judges conduct that review; and (2) the other challenged parts of the rule did not conflict with the statute. View "Minn. Voters Alliance v. Office of Minn. Secretary of State" on Justia Law

by
The Supreme Court affirmed the judgment of the district court concluding that an unconstitutional provision in a proposed charter amendment was not severable, holding that the provision was not severable from the remainder of the proposed charter amendment.On August 8, 2022, the Bloomington City Council voted to reject the entirety of a proposed charter amendment based on its conclusion that the last of the proposed amendment's four sections, section 4.08, was manifestly unconstitutional. Appellants filed a petition seeking declaratory and injunctive relief to sever section 4.08 and submit the remaining valid provisions to voters. The district court denied the petition, concluding that it would be improper to sever section 4.08 from the remainder of the proposed charter amendment. The Supreme Court affirmed, holding that section 4.08 could not properly be severed from the proposed city-charter amendment. View "Kranz v. City of Bloomington" on Justia Law

by
The Supreme Court granted a petition sought by Petitioner seeking an order authorizing Petitioner to send notices about errors on the for the Murray County ballot for the November 8, 2022 general election to all mail ballot voters and to all voters who had already requested an absentee ballot, holding that Petitioner was entitled to relief.The petition asserted that the ballot at issue incorrectly identified the district number for the Minnesota legislative officers as Senate District 22 and House District 22A. Petitioner did not seek to correct the errors on the ballot but sought to send notices regarding the errors and the authority to post the same notice in all Murray County polling places. The Supreme Court granted the petition, holding that Petitioner proposed an appropriate plan to remedy the ballot errors. View "In re Murray County Ballot" on Justia Law

by
The Supreme Court ordered that Petitioners shall correct the ballot for the November 8, 2022 general election because the general election ballot used by voters in Roseau County and Kittson County omitted information required by Minnesota law.Roseau and Kittson Counties filed petitions under Minn. Stat. 204B.44(a) to correct errors on the November 8, 2022 general election ballot, stating the the ballots in each county failed to include the political party affiliation for federal and state candidates and failed to include the word "incumbent" next to names of currently-serving judicial candidates. The Supreme Court ordered that the counties shall correct the ballot for the November 8, 2022 general election and that Petitioners shall resume delivery of ballots to voters after they receive corrected ballots from their vendors. View "In re Roseau County Ballot for the November 8, 2022 General Election" on Justia Law

by
The Supreme Court approved a plan proposed by Petitioner to correct an error on the November 8, 2022 general election ballot in this petition brought by the Ramsey County Elections Manager under Minn. Stat. 204B.44(a) with minor modifications.Due to a clerical error, Ramsey County ballots incorrectly listed Beverly Peterson, and not Scott Hesselgrave, as the Republican Party candidate for Minnesota House District 67A. Petitioner sought an order authorizing correction of the ballot for House District 67A, distribution of the corrected ballot, and procedures for counting these voters' ballots. The Supreme Court held that it was authorized to correct the ballot error and the Petitioner proposed an appropriate plan to remedy the error. View "In re 2022 General Election Ballot" on Justia Law

by
The Supreme Court denied this petition asking that the Court order removal of Torrey Westrom from the November 8, 2022 general election ballot as a candidate for Senate District 12, holding that Petitioner was not entitled to relief.Petitioner alleged that Westrom, the current state senator for District 12, was not eligible for reelection to that office because he could satisfy the residency requirement of the Minnesota Constitution. Specifically, Petitioner alleged that Westrom will not have resided in Senate District 12 for the required six-month period prior to the general election. A referee concluded that Petitioners failed to prove that Westrom was ineligible to run for state legislative office in District 12 in the November general election. The Supreme Court denied the petition and granted the Attorney General's request to be dismissed from the matter, holding that Petitioners' objections failed. View "Fischer v. Simon" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court dismissing the petitions for writs of mandamus filed by Minnesota Voters Alliance, et al. (collectively, the Alliance), holding that the Alliance failed to show the violation of a duty clearly established by law.In the mandamus petitions, the Alliance alleged that Ramsey County, Olmsted County, and other entities violated their statutory obligations for appointing members to absentee ballot board during the 2020 general election. Specifically, Alliance argued that the statutory requirements for election judges also apply to deputy county auditors. The district court dismissed the petitions, and the court of appeals affirmed. The Supreme Court affirmed, holding that the district court properly dismissed the Alliance's mandamus petitions. View "Minnesota Voters Alliance v. County of Ramsey" on Justia Law

by
The Supreme Court held that certain congressional districts were unconstitutional for purposes of the 2022 primary and general elections, enjoined their use in these elections, and adopted the congressional district boundaries as set forth in Appendices A and B to this order.Two sets of plaintiffs initiated actions in, respectively, Carver County District Court and Ramsey District Court alleging that the current congressional and legislative election districts were unconstitutionally malapportioned in light of the 2020 census. The Chief Justice appointed a panel to hear and decided the consolidated action and any other challenges to the congressional and legislative districts. The Supreme Court held that the existing congressional districts were unconstitutional and adopted the congressional district boundaries as set out in Appendices A and B to this order. View "Wattson v. Simon" on Justia Law