Justia Election Law Opinion Summaries

In the 2023 Republican primary election for the District 6 seat on the Columbus City Council, no candidate ran, prompting the Bartholomew County Republican Party to hold a caucus to select a nominee. Joseph Foyst was chosen, but Ross Thomas, the chairman of the Bartholomew County Democratic Party, sued for a declaratory judgment claiming the Republican Party missed the statutory deadline for choosing its nominee. The suit was unresolved before the election, which Foyst won. After the election, the Bartholomew Circuit Court denied Thomas’s claim, but the Court of Appeals reversed, holding that the Republican Party missed the deadline and declared Foyst’s candidacy void, instructing that Bryan Muñoz, the second-place finisher, be declared the winner.The Indiana Supreme Court granted transfer and remanded to the circuit court to dismiss the case as moot. The court noted that the Indiana General Assembly created two distinct avenues for election disputes: pre-election candidacy challenges and post-election contests. Thomas did not file an election contest, which is the only statutory remedy for declaring the second-place finisher the winner when the first-place finisher’s nomination is invalid. Since Thomas only brought a pre-election challenge, his request to prohibit Foyst from appearing on the ballot became moot after the election occurred and Foyst appeared on the ballot.The Indiana Supreme Court held that Thomas must follow the statutory requirements for an election contest to set aside election results. The court emphasized the importance of adhering to the General Assembly’s rules for challenging elections and concluded that Thomas’s failure to file an election contest rendered his claim moot. The court vacated the Court of Appeals decision and remanded the case to the circuit court with instructions to dismiss it as moot. View "Thomas v. Foyst" on Justia Law

Christopher Nardi submitted an APRA request to the Indiana Election Division for documents related to Indiana’s voter-registration system. He requested three specific documents: the latest standard operating procedures, build notes, and the latest contract with third-party vendors. The Division denied the requests, citing security concerns, but directed Nardi to an online portal for the contract, which he accessed but failed to save. Nardi then filed a complaint with Indiana’s Public Access Counselor (PAC), which recommended partial disclosure. The Division refused, leading Nardi to file a lawsuit in Marion Superior Court.The Marion Superior Court conducted an in-camera review and ordered the Division to provide a redacted version of the contract but denied the other requests. Nardi petitioned for attorney’s fees, claiming he substantially prevailed. The trial court awarded him one-third of the requested fees, reasoning he prevailed on one of three requests. Both parties appealed. The Indiana Court of Appeals affirmed the partial summary judgment but reversed the fee award, concluding Nardi did not substantially prevail.The Indiana Supreme Court reviewed the case, holding that Nardi substantially prevailed by obtaining a wrongfully withheld public record. The Court found that the trial court did not abuse its discretion in this determination. However, the Supreme Court reversed the trial court’s mechanical reduction of attorney’s fees to one-third. The case was remanded for the trial court to recalculate the fees, considering the time spent on the successful claim and whether the time spent on unsuccessful claims was indivisible from the successful claim. The Indiana Supreme Court emphasized that APRA should be liberally construed to promote transparency and accountability in government. View "Nardi v. King" on Justia Law

In a case before the Indiana Supreme Court, John Rust sought the Republican nomination for U.S. Senator for Indiana in 2024. Rust was concerned that he may be denied access to the primary ballot because he did not meet the state's Affiliation Statute's criteria. The Affiliation Statute required that a candidate either have voted for the party in the two most recent primary elections in which they voted or have party affiliation certified by the county party chair. Rust had not met either of these conditions. A lower court blocked enforcement of the law, deeming it unconstitutional.The Indiana Supreme Court reversed the lower court's ruling, finding that the Affiliation Statute was constitutionally sound. The court determined that the law imposed a minor, reasonable, and non-discriminatory restriction on Rust's First Amendment rights. It held that the law reasonably balanced the rights of candidates and parties, enabling the Republican Party to limit its candidates, protect its identifiability, and ensure stability in the political system. The court also rejected Rust's arguments that the law violated the Seventeenth Amendment, was vague and overbroad, improperly amended the Indiana Constitution, or allowed for invalid use of discretion under the Affiliation Statute. View "Morales v. Rust" on Justia Law

The Supreme Court agreed with Plaintiffs in this declaratory judgment action, holding that Ind. Code 3-9-2-3 to -6 prohibits or otherwise limits corporate contributions to political action committees (PACs) or other entities that engage in independent campaign-related expenditures.Plaintiffs filed suit against several state officials responsible for enforcing Indiana's election laws, arguing that Ind. Code 3-9-2-4 and 3-9-2-5 were unconstitutional as applied. The district court dismissed the lawsuit for lack of standing, concluding that Plaintiffs had not suffered an injury. The United States Court of Appeals for the Seventh Circuit certified to the Supreme Court the question of whether sections 3-9-2-3 to -6 prohibit corporate contributions to Super PACs like the fund at issue. The Court of Appeals answered by holding that sections 3-9-2-3 to -6 prohibit corporate contributions to PACs earmarked for independent campaign-related expenditures. View "Indiana Right to Life Victory Fund v. Morales" on Justia Law