Justia Election Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The Supreme Court affirmed the order of the district court dismissing Plaintiff's election contest filed under Minn. Stat. 209.021, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) Plaintiff was not prejudiced by the delay in providing notice of the election contest to the Chief Justice; (2) Plaintiff's claim asserting a violation of her civil rights under the Voting Rights Act, 52 U.S.C. 10101, was not properly asserted on appeal; and (3) the district court did not err in dismissing Plaintiff's election contest for failure to state a legally sufficient claim upon which relief could be granted. View "Bergstrom v. McEwen" on Justia Law

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The Supreme Court dismissed the petition filed by Petitioners asking the Supreme Court to temporarily restrain the State Canvassing Board from certifying the results of the November 3, 2020 general election held in Minnesota and to require a full recount of the federal and state offices on the ballot, holding that the petition must be dismissed.Petitioners asserted three claims in their petition. Counts I and II rested on challenges to consent decrees entered by the district court that suspended the witness requirement for absentee and mail ballots for the 2020 general election. Count III challenged the processes used in some counties for conducting the post-election review. The Supreme Court dismissed the petition, holding (1) Counts I and II were barred by laches; and (2) because Petitioners did not file proof that the petition was served in compliance with Minn. Stat. 204B.44, Count III must be dismissed. View "Kistner v. Simon" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court temporarily enjoining the Secretary of State from taking steps to enforce or require compliance with voter-assistance and ballot-collection limits, holding that the district court correctly found that a likelihood of success on the merits was shown on the claim that the voter-assistance limit in Minn. Stat. 204C.15, subd. 1, for ballot marking, was preempted but otherwise erred.At issue was the limits in Minnesota Statutes on the number of voters that an individual may assist in marking a ballot and the number of completed absentee ballots the an individual may collect and deliver. In a complaint, two Democratic committees brought a number of challenges to the limits. The district court concluded that the Democratic committees were likely to succeed on the merits of the claims and had demonstrated that a temporary injunction was warranted. The Supreme Court affirmed the district court's decision on the preemption claim as to the limit on the number of voters that may be assisted in marking a ballot but otherwise reversed, holding that the district court abused its discretion in finding that a likelihood of success on the merits was shown on Plaintiffs' remaining claims. View "DSCC v. Simon" on Justia Law

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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