Justia Election Law Opinion Summaries

A voter in Sarasota County, Florida, who is not affiliated with any political party, challenged Florida's closed primary election system. He argued that the system forces him to either join a political party to have a meaningful vote or forfeit his right to vote in primary elections, which he claimed was unconstitutional. The district court dismissed his case, concluding that he lacked standing and failed to state a claim for relief.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court found that the voter had standing to sue the Sarasota County Supervisor of Elections because his exclusion from primary elections was traceable to the Supervisor and could be redressed by a court order. However, the court determined that the voter lacked standing to sue the Florida Secretary of State, as the Secretary did not have direct control over the Supervisor's actions.On the merits, the court applied the Anderson-Burdick framework to evaluate the voter's First and Fourteenth Amendment claims. The court concluded that the burdens imposed by Florida's closed primary system on the voter's rights were minimal. The court found that the state's interests in preserving political parties as viable and identifiable interest groups and enhancing candidates' electioneering efforts outweighed the minimal burdens on the voter's rights.The court vacated the district court's order and remanded the case with instructions to dismiss the claims against the Florida Secretary of State without prejudice and to dismiss the claims against the Sarasota County Supervisor of Elections with prejudice. View "Polelle v. Florida Secretary of State" on Justia Law

In 2010, Alabama made changes to its election law that impacted the ADC’s ability to raise and spend money in state elections. The ADC filed suit challenging Alabama Code 17-5-15(b) (the PAC-to-PAC transfer ban), which limited the ADC's fundraising abilities. On appeal, the ADC challenges the district court's final judgment in favor of the State, arguing that the PAC-to-PAC transfer ban is unconstitutional as applied because the ban violates the ADC’s First Amendment right to make independent expenditures. The court concluded that the State’s proffered interest in transparency ties into its interest in preventing corruption to justify regulating transfers between PACs. The court also concluded that the PAC-to-PAC transfer ban as applied to the ADC is sufficiently closely drawn to avoid unnecessary abridgment of associational freedoms. The ban had met the less rigorous "closely drawn" standard by being narrowly tailored to achieve Alabama's desired objective in preventing quid pro quo corruption (or its appearance) as applied to the ADC in this case. Accordingly, the court affirmed the district court's finding on the merits that the ban is constitutional as applied to ADC. View "The Alabama Democratic Conference v. Attorney General, State of Alabama" on Justia Law