Justia Election Law Opinion SummariesArticles Posted in U.S. 8th Circuit Court of Appeals
Minnesota Voters Alliance, et al. v. Ritchie, et al.
Voters filed suit against Officials challenging the process by which Officials confirmed the eligibility of voters who register on election day (election day registrants or EDRs). Voters also challenged a provision of the Minnesota Constitution denying the right of persons under guardianship to vote, as well as the sufficiency of notice afforded to such persons under certain Minnesota statutes. The court concluded that Voters could not prevail on their 42 U.S.C. 1983 claims based on Officials' failure to verify EDR's voting eligibility before allowing EDRs to cast their votes where Voters raised no allegations of the "aggravating factors" identified in Pettengill v. Putnam County R-1 School District; alleged no discriminatory or other intentional, unlawful misconduct by Officials sufficient to implicate section 1983; and alleged no defects causing Minnesota's voting system to be so "fundamentally unfair" that relief under section 1983 would be appropriate. Further, Voters lacked standing to raise their remaining claims where the amended complaint failed to allege that any plaintiff has been denied the right to vote by a constitutional provision barring persons under guardianship from voting. Accordingly, the court affirmed the district court's dismissal of Voters claims and denial of their motion for summary judgment as moot. View "Minnesota Voters Alliance, et al. v. Ritchie, et al." on Justia Law
Iowa Right To Life Committee v. Tooker, et al.
IRTL challenged the constitutionality of several Iowa campaign-finance laws, an administrative rule, and two forms. The court concluded, inter alia, that IRTL lacked standing to challenge the definitions of "political committee" and "permanent organization" because it faced no credible threat or present or future prosecution; the first two sentences of Iowa Code subsection 68A.404(3), the second sentence of subsection 68A.404(3)(a), the entirety of subsection 68A.404(4)(a), the first and third sentences of Iowa Administrative Code rule 351-4.9(15), and Form Ind-Exp-O were constitutional as applied to IRTL and groups whose major purpose was not nominating or electing candidates; the first and third sentences of subsection 68A.404(3)(a), the second sentence of Iowa Administrative Code rule 351-4.9(15), the entirety of subsections 68A.404(3)(a)(1) and 68A.402B(3), and Form Dr-3 were unconstitutional as applied to IRTL and groups whose major purpose was not nominating or electing candidates; and Iowa Code section 68A.503 was constitutional under the First and Fourteenth Amendments. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Iowa Right To Life Committee v. Tooker, et al." on Justia Law
Minnesota Majority, et al v. Mansky, et al
Plaintiffs, groups interested in electoral and government reform, sued Minnesota, challenging the constitutionality of Minnesota's Election Day Policy and Minn. Stat. 211B.11, subd. 1, which banned the wearing of any political insignia to a polling place. On appeal, plaintiffs challenged the dismissal of their First Amendment and Equal Protection claims. The court held that plaintiffs have failed to state a facial claim under the First Amendment under Minn. Stat. 211B1.11, subd. 1. The court reversed and remanded the as-applied First Amendment claim to the district court so that it could properly analyze the motion as a request for summary judgment through application of the standards articulated in Rule 56 and to give the parties sufficient opportunity to create an acceptable record. The court held that plaintiffs have failed to allege that Minnesota caused selective enforcement of the facially neutral statute and Policy and has therefore failed to state an equal protection claim. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Minnesota Majority, et al v. Mansky, et al" on Justia Law
Carlson, et al. v. Justice David Wiggins, et al.
Plaintiffs filed a complaint and moved for a temporary restraining order and preliminary injunction, alleging section 16, article V, of the Iowa Constitution, as implemented by Iowa Code sections 46.2, 46.4-46.10, and 46.14, violated their Fourteenth Amendment right to equal protection under the laws. The court concluded that the State Judicial Nominating Commission was a "special limited purpose" entity for its sole function was to select the most qualified candidates for judicial appointments and forward the names of these candidates to the Governor for a final appointment. This narrow function had a disproportionate effect on a definable group of constituents - members of the Iowa Bar - over other voters in the state. Therefore, the election of the attorney members of the Commission was an election of special interest. Applying rational basis review, the court agreed that the district court's Iowa system of election for the Commission's attorney members by and from members of the Iowa Bar was rationally related to Iowa's legitimate interests. Therefore, Iowa's system did not violate plaintiffs' rights under the Equal Protection Clause. Accordingly, the court affirmed the judgment. View "Carlson, et al. v. Justice David Wiggins, et al." on Justia Law
Libertarian Party of ND, et al. v. Jaeger
Appellants, the Libertarian party and three candidates, challenged the constitutionality of North Dakota Century Code 16.1-11-36, contending that the statute as applied to them violated the First and Fourteenth Amendment and the Equal Protection Clause because it prevented appellants' names from appearing on the 2010 general election ballot despite their winning the party's primary. The court held that the burden imposed by the statute was not undue or excessive and the state had a compelling interest in having a minimum vote requirement before a candidate could appear on the general election ballot. Therefore, the court held that N.D.C.C. 16.1-11-36 was not unconstitutional on First or Fourteenth Amendment grounds. Furthermore, because the law applied equally to all candidates and did not result in unequal treatment, the court held that the statute did not violate the Equal Protection Clause. Accordingly, the court affirmed the district court. View "Libertarian Party of ND, et al. v. Jaeger" on Justia Law
Green Party of Arkansas, et al. v. Martin, et al.
Plaintiffs (Green Party) brought this action against the Arkansas Secretary of State pursuant to 42 U.S.C. 1983, seeking (1) a declaratory judgment that the Green Party was a political party and that Arkansas Code 7-1-101(21)(C) violated the Green Party's First and Fourteenth Amendment rights and (2) an injunction preventing Arkansas from enforcing section 7-1-101(21)(C). At issue on appeal was whether section 7-1-101(21)(C) severely interfered with the Green Party's right of association and therefore, impermissibly burdened the Green Party's First and Fourteenth Amendment rights. In light of compelling Supreme Court precedent, the many alternative paths Arkansas provided to the ballot, and the Green Party's own success in achieving ballot access, the court held that while the burdens imposed on the Green Party's rights did exist, they were significantly outweighed by Arkansas's important regulatory interests. Therefore, the court concluded that Arkansas's ballot access scheme did not impermissibly burden the Green Party's constitutional rights and the judgment was affirmed. View "Green Party of Arkansas, et al. v. Martin, et al." on Justia Law
MN Citizens Concerned for Life, et al v. Swanson, et al
Appellants, three Minnesota corporations seeking to advance their respective social and commercial interests, filed suit to enjoin Minnesota election laws on independent expenditures and corporate contributions to candidates and political parties and moved for a preliminary injunction. At issue was whether the district court erred in failing to grant a preliminary injunction because appellants failed to show a likelihood of success. The court held that the district court did not abuse its discretion in denying appellant's request for an injunction where appellants were unlikely to prevail on the issue of whether Minnesota functionally retained a ban on corporate independent expenditures; appellants were unlikely to prevail on their claim of improper tailoring; and appellants were unlikely to prevail on the direct-contribution issue or the independent-expenditure issue.
Constitution Party of SD, et al v. Chris Nelson
Appellants brought an action against appellee, in his official capacity as Secretary of State of South Dakota, claiming violations of the First and Fourteenth Amendments related to appellants' efforts to place a candidate for governor on the 2010 ballot in South Dakota and challenged the constitutionality of two statutory provisions related to that process. At issue was whether appellants had standing to challenge S.D. Codified Laws 12-5-3(9), which permitted only in-state residents to circulate the petitions at issue ("Count II"), and whether the court erred in failing to strike it down as unconstitutional. The court held that all appellants lacked standing to challenge the constitutionality of the relevant statute and vacated the district court's judgment and remanded with instructions to dismiss Count II without prejudice for lack of jurisdiction.
281 Care Committee, et al v. Ross Arneson, et al
Plaintiffs, three Minnesota-based grass roots advocacy organizations, challenged a Minnesota law that made it a crime to knowingly, or with reckless disregard for the truth, make a false statement about a proposed ballot initiative under the Minnesota Fair Campaign Practices Act ("FCPA"), Minn. Stat. 211.B06, subd.1. At issue was whether the district court erred when it dismissed plaintiffs' complaint for lack of jurisdiction; when it alternatively held that it would dismiss plaintiffs' complaint for failing to state a claim upon which relief could be granted; and when it denied plaintiffs' motion for summary judgment. The court held that plaintiffs' claims were justiciable and that subject matter jurisdiction was proper in federal court; that plaintiffs did allege First Amendment claims upon which relief could be granted; and that the district court's denial of plaintiffs' motion for summary judgment based on its findings of mootness was vacated. Therefore, the court remanded for additional development of arguments regarding whether section 211.b06 satisfied strict scrutiny.
Hilda L. Solis v. Amalgamated Transit Union
The United States Secretary of Labor ("Secretary") appealed the district court's grant of summary judgment to Amalgamated Transit Union, Local 1005 ("Local 1005) on the claim that Local 1005's November 2008 election procedures violated the "adequate safeguards" provision of the Labor Management Reporting and Disclosure Act ("LMRDA"), 29 U.S.C. 481(c). At issue was whether the district court applied the wrong legal standard in its analysis and whether the district erred when it determined that Local 1005 did not violate the "adequate safeguards provision" of the LMRDA. The court held that the district court did not apply the wrong legal standard where the district court found no violation of section 481(c). The court also affirmed summary judgment and held that Local 1005's actions regarding the accurate announcement of the sole requirement to stand for elected office, coupled with the fully accurate notices posted both on Local 1005's job site bulletin and boards, as well as on its website, amounted to "adequate safeguards" under the LMRDA.