Justia Civil Procedure Opinion Summaries

Articles Posted in Election Law
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A group of citizens in the Town of Bel Air, Maryland, submitted a document to the town's Board of Commissioners, purporting to be a petition for a referendum on a comprehensive rezoning ordinance. The document, however, did not meet the requirements of the town's charter for such a petition. The Board of Commissioners determined that the document was invalid and did not send it to the Board of Election Judges for verification of signatures. The citizens filed a complaint in the Circuit Court for Harford County, seeking a declaratory judgment that the Board of Commissioners' determination was invalid and an order directing the town to verify the signatures on the document. The circuit court ruled in favor of the citizens, declaring the Board of Commissioners' determination invalid and ordering the town to verify the signatures.The Supreme Court of Maryland reversed the circuit court's decision. The court held that the Board of Commissioners correctly determined that the document did not meet the requirements of the town's charter to be considered a valid petition for a referendum. The court also held that the Board of Commissioners was not required to send the document to the Board of Election Judges for verification of signatures before making this determination. The court remanded the case to the circuit court with instructions to enter a declaratory judgment consistent with its opinion. View "Town of Bel Air v. Bodt" on Justia Law

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The case involves the Tennessee Conference of the National Association for the Advancement of Colored People (NAACP) challenging a state policy that requires some convicted felons to submit additional documentation to confirm their eligibility to vote. The NAACP argued that this policy violated the National Voter Registration Act (NVRA). A district court agreed with the NAACP and permanently enjoined the policy in the middle of the 2024 election cycle. Tennessee's Secretary of State and Coordinator of Elections appealed this decision and sought a stay of the injunction pending appeal.The district court's decision was based on the finding that the NAACP had standing to challenge the policy and that the policy violated the NVRA. The court held that the policy was unnecessary for determining the eligibility of those with felony convictions as the state had other information at its disposal to make that decision.The United States Court of Appeals for the Sixth Circuit granted the stay for two reasons. First, the injunction triggered the Supreme Court’s “Purcell principle,” which instructs federal courts not to disrupt state election rules close to an election. Second, the court found that the NAACP likely did not present enough evidence to prove its standing to challenge the Documentation Policy. The court concluded that the NAACP's claim that the policy forced it to divert its resources to help those convicted of felonies track down the records they need to register was not supported by specific facts. View "Tennessee Conference of the NAACP v. Lee" on Justia Law

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The case involves a challenge to two Delaware voting statutes: one allowing absentee voters to request "permanent absentee" status, and the other authorizing qualified, registered voters to vote in person at least 10 days before an election. The plaintiffs, a citizen who plans to serve as an election inspector and a Delaware State Senator, argued that these statutes conflict with the Delaware Constitution's provisions governing elections and voting.The case was initially filed in the Court of Chancery, which dismissed it on jurisdictional grounds. The plaintiffs then pursued their claims in the Superior Court. The Superior Court found that the plaintiffs had standing to bring the case and ruled in their favor, declaring the challenged statutes unconstitutional.On appeal, the Supreme Court of the State of Delaware reversed the Superior Court's decision. The Supreme Court found that neither plaintiff had standing to challenge the statutes. The court held that the State Senator, who was not up for re-election until 2026, did not face an imminent or particularized harm. The court also found that the citizen, who planned to serve as an election inspector, did not have standing because his role as an inspector did not give him the authority to turn away lawful voters based on his personal belief that the challenged statutes were invalid. Finally, the court rejected the plaintiffs' claim that they had standing as registered voters, finding that their alleged injury was a generalized grievance shared by all voters, not a particularized harm. As a result of these findings, the court did not address the merits of the plaintiffs' constitutional claims. View "Albence v. Mennella" on Justia Law

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The case involves a group of civil rights organizations, voters, and an election official who sought to challenge recent amendments to Texas's election code, alleging that these amendments violated the United States Constitution and several federal statutes. The defendant was the District Attorney for Harris County, sued in her official capacity. The district court denied the District Attorney's motion to dismiss, holding that she was not immune from the plaintiffs' constitutional claims and that the plaintiffs had standing to bring their claims against her.The United States Court of Appeals for the Fifth Circuit held that it had jurisdiction to hear the appeal and that the district court should have dismissed the plaintiffs' constitutional claims as barred by sovereign immunity. The court did not reach the issue of standing. The court reversed in part, vacated in part, and remanded the case for further proceedings.The court's decision was based on the principle of sovereign immunity, which generally protects state officials from being sued in their official capacities. However, there is an exception to this rule, known as the Ex parte Young exception, which allows federal courts to enjoin state officials from enforcing unconstitutional state statutes. The court found that the District Attorney did not have a sufficient connection to the enforcement of the challenged laws to fall within this exception. Therefore, the court concluded that the District Attorney was immune from the plaintiffs' constitutional claims. View "Mi Familia Vota v. Ogg" on Justia Law

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The case involves the Arizona Republican Party (ARP) and its attorneys, who challenged the manner in which Maricopa County election officials conducted a mandatory hand count of ballots following the 2020 general election. The ARP argued that the hand count should have been based on precincts rather than voting centers, as prescribed by the Election Procedures Manual (EPM). The trial court dismissed the ARP's complaint and awarded attorney fees against the ARP and its attorneys under A.R.S. § 12-349(A)(1) and (F), which provides for such fees if a claim is groundless and not made in good faith. The court of appeals affirmed the trial court's rulings.The Supreme Court of the State of Arizona held that the attorney fees award was improper because the ARP's claim was not groundless, thus there was no need to determine whether the claim was made in the absence of good faith. The court found that the ARP's claim was more than "barely" colorable, as there was a plain-language conflict between § 16-602(B), which requires a precinct hand count, and the 2019 EPM, which permits a voting center hand count. The court also disagreed with the lower courts' rulings that the ARP's claim was groundless due to the unavailability of remedies, the applicability of the election-law time bar on post-election challenges to pre-election procedures, and laches. The court vacated the trial court’s and the court of appeals’ attorney fees awards. View "ARIZONA REPUBLICAN PARTY v RICHER" on Justia Law

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In this case, Quinton Lucas, a registered voter, challenged the approval of Amendment No. 4 in the November 2022 general election. The amendment authorized laws that increased minimum funding for a police force established by a state board of police commissioners. Lucas claimed that the fiscal note summary printed on every ballot cast in the election materially misstated the fiscal note for the measure.The Supreme Court of Missouri, which was reviewing the case, had previously overruled the state's motion to dismiss Lucas' claim. The state had argued that Lucas' contest was time-barred, that the city lacked standing as a voter, and that the statutes providing remedies if an election contest succeeds were unconstitutional.The Supreme Court of Missouri found that the fiscal note summary was both materially inaccurate and seriously misleading. The court held that this constituted an "irregularity" of sufficient magnitude to cast doubt on the validity of the election. As a result, the court ordered a new election on the question to be conducted as part of the statewide general election on November 5, 2024. View "Lucas vs. Ashcroft" on Justia Law

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The case involves Dr. Eric Coomer, the former director of product strategy and security at Dominion Voting Systems, who filed a lawsuit against Make Your Life Epic LLC (doing business as ThriveTime Show) and its podcast host, Clayton Clark. The defendants had published and repeated false claims about Dr. Coomer, alleging that he was a member of "Antifa" and had rigged the 2020 presidential election in favor of Joseph R. Biden and against Donald J. Trump. Dr. Coomer's lawsuit asserted claims for defamation, intentional infliction of emotional distress, and civil conspiracy.The defendants filed a "special motion to dismiss" the lawsuit under Colorado’s anti-SLAPP (Strategic Lawsuit Against Public Participation) statute. The District Court for the District of Colorado denied this motion, determining that Dr. Coomer would likely prevail on the merits of all three of his claims. The defendants appealed this decision, asking the United States Court of Appeals for the Tenth Circuit to reverse the district court’s order.The Tenth Circuit dismissed the defendants' appeal for lack of appellate jurisdiction. The court held that the proposed interlocutory appeal fell outside of the collateral-order doctrine, which provides appellate jurisdiction over a small class of collateral rulings that, although they do not end the litigation, are appropriately deemed final. The court found that the district court's order denying the special motion to dismiss under Colorado’s anti-SLAPP statute was not completely separate from the merits of the case and thus did not meet the requirements of the collateral-order doctrine. View "Coomer v. Make Your Life Epic" on Justia Law

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The plaintiffs, Reverend Kenneth Simon, Reverend Lewis W. Macklin, II, and Helen Youngblood, collectively known as the "Simon Parties," filed a lawsuit against the Ohio Redistricting Commission and several of its members. They alleged that Ohio's congressional districts violated section 2 of the Voting Rights Act, the First Amendment, the Fourteenth Amendment, and the Fifteenth Amendment. The Simon Parties requested a three-judge court under 28 U.S.C. § 2284, which the Ohio Redistricting Commission opposed, and moved to dismiss the complaint.The district court denied the motion to convene a three-judge court and granted the motions to dismiss. The court also denied all other pending motions. The Simon Parties appealed this decision.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The court found that the district court incorrectly determined that the Simon Parties' Fourteenth Amendment claim did not raise a substantial federal question for jurisdictional purposes. The court stated that the Simon Parties' allegations on this claim were sufficient to establish federal jurisdiction. The court concluded that the district court lacked jurisdiction as a single judge to adjudicate any other pending motion because it was required to convene a three-judge court under 28 U.S.C. § 2284.The court reversed the district court's order denying the motion for a three-judge court, vacated the district court's orders granting the motions to dismiss and denying the motion for temporary restraining order and motion for class certification, and remanded the case to the district court with instructions for it immediately to initiate the procedures to convene a three-judge court under 28 U.S.C. § 2284. View "Simon v. DeWine" on Justia Law

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The case revolves around a contested municipal general election for the Ward 4 Alderman seat in Coldwater, Mississippi. Levon Hayes was declared the winner, but his opponent, Alice Thomas, filed an election contest, suspecting irregularities in the vote count. Hayes was served with the contest and a Rule 4 summons but did not respond or appear in court. Almost a year later, Thomas applied for a default judgment, which the Tate County Circuit Court granted, declaring Thomas the winner and ordering her immediate swearing in.The case was initially heard in the Tate County Circuit Court, where Thomas applied for a default judgment due to Hayes' failure to respond to the election contest. The court granted the default judgment, declared Thomas the winner, and ordered her immediate swearing in.The case was then brought to the Supreme Court of Mississippi. The court was tasked with determining whether a default judgment was permissible in this general election contest under Mississippi Code Section 23-15-951 and the Mississippi Rules of Civil Procedure. The court found that a default judgment was not permissible and that Thomas's failure to diligently prosecute her contest required its dismissal with prejudice. The court reversed the default judgment and remanded the case to the circuit court to dismiss Thomas's contest with prejudice and to reinstate Hayes as the elected candidate. The court also noted that the Rule 4 summons served to Hayes was improper and that Thomas's delays in prosecuting her contest violated the public's interest in having elections promptly decided. View "In Re: Contest of the Municipal General Election for the Ward 4 Alderman Seat" on Justia Law

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The case involves the Arkansas Voter Integrity Initiative, Inc., and Conrad Reynolds (appellants) who filed a complaint against John Thurston, the Arkansas Secretary of State, the Arkansas State Board of Election Commissioners, and Election Systems and Software, LLC (appellees). The appellants claimed that the voting machines approved by the state did not comply with the Arkansas Code and the Help America Vote Act of 2002 (HAVA) because voters could not independently verify their selections on the ballot before casting their votes. They argued that the machines printed ballots with both bar codes and the voter's selections in English, but the vote tabulator only scanned the bar codes. Since most voters cannot read bar codes, the appellants claimed that voters were unable to verify their votes as required by state and federal law. They also alleged that the appellees committed an illegal exaction by using public funds for the purchase and maintenance of these machines and that Election Systems and Software, LLC violated the Arkansas Deceptive Trade Practices Act and committed fraud by claiming that its machines complied with state and federal law.The Pulaski County Circuit Court dismissed the appellants' complaint. The court found that the voting machines complied with the Arkansas Code and HAVA. The court also denied the appellants' motion for recusal and their motion for a new trial. The appellants appealed these decisions.The Supreme Court of Arkansas affirmed the lower court's decision. The court found that the voting process complied with the Arkansas Code and HAVA. The court also found that the appellants failed to demonstrate evidence of bias or prejudice sufficient to warrant the recusal of the circuit court judge. Finally, the court found that the appellants were not deprived of their right to a jury trial and that the circuit court did not err by denying their motion for a new trial. View "ARKANSAS VOTER INTEGRITY INITIATIVE, INC., AND CONRAD REYNOLDS v. JOHN THURSTON, IN HIS OFFICIAL CAPACITY AS ARKANSAS SECRETARY OF STATE; THE ARKANSAS STATE BOARD OF ELECTION COMMISSIONERS, IN ITS OFFICIAL CAPACITY; AND ELECTION SYSTEMS AND SOFTWARE, LLC" on Justia Law