Justia Civil Procedure Opinion Summaries

Four registered voters and several non-profit organizations sued the Cobb County Board of Elections and Registration, alleging that the 2022 redistricting map for the Cobb County School Board was an unconstitutional racial gerrymander. They claimed the map packed Black and Latino voters into certain districts to dilute their political power and maintain a majority white School Board. The plaintiffs sought declaratory and injunctive relief to prevent the use of the 2022 map in future elections.The Cobb County School District intervened as a defendant and moved for judgment on the pleadings, arguing it was not liable for any constitutional violation because the Georgia General Assembly, not the School Board, enacted the map. The district court granted the School District’s motion based on Monell v. Department of Social Services of New York, but did not immediately enter judgment. The School District continued to participate in the case, prompting the court to formally terminate it as a party. The plaintiffs and the Election Defendants then entered a settlement, leading to a preliminary injunction against the 2022 map.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court dismissed the School District’s appeal for lack of jurisdiction, holding that the School District, as a nonparty, lacked standing to appeal the preliminary injunction. The court emphasized that only parties or those who properly become parties may appeal, and the School District had not sought to reintervene for purposes of appeal. The court also noted that the School District’s participation as an amicus did not grant it the right to appeal. View "Cobb County School District" on Justia Law

The case involves a challenge to the Re-Enfranchisement Act, which allows individuals convicted of felony-level offenses to vote once they are no longer incarcerated. The plaintiffs, individual taxpayers and the Minnesota Voters Alliance, argued that the Act violates the Minnesota Constitution by restoring only the right to vote rather than all civil rights. They also claimed that using public funds to educate and notify people about the new voting provision is unlawful if the Act itself is unconstitutional.The district court denied the petition, concluding that the plaintiffs lacked standing. The court determined that taxpayer standing requires a challenge to an illegal expenditure or waste of tax money, which the plaintiffs failed to demonstrate. The court also found that the Minnesota Voters Alliance lacked associational standing because its members did not have standing.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court clarified that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. The court held that the plaintiffs could not manufacture standing by pointing to incidental expenditures related to implementing the law. Since the plaintiffs' challenge was primarily against the substantive law itself and not the expenditures, they lacked the necessary standing. Consequently, the Minnesota Voters Alliance also lacked associational standing. The court did not address the merits of the case due to the lack of standing. View "Minnesota Voters Alliance vs. Hunt" on Justia Law

A nonpartisan candidate filed a complaint challenging the primary election ballot in Hawaii, arguing that the requirement for voters to select a political preference violated the Hawaii Constitution and various state statutes. The plaintiff sought an order to redesign the ballot and declare the current ballot invalid.The State of Hawaii, Office of Elections, and the Chief Election Officer moved to dismiss the complaint for failure to state a claim or lack of jurisdiction. The Supreme Court of Hawaii reviewed the case and found that the plaintiff's claims under HRS §§ 11-173.5, 11-174.5, and 91-14 were not valid because no election results had been posted, which is a prerequisite for these statutes. Additionally, the court found that the plaintiff did not have standing to challenge all statewide ballots under HRS § 11-172, as he was only a candidate in the Mayor's race in Honolulu. The court also determined that the plaintiff's complaint did not state a claim under HRS § 11-172 because the alleged ballot defects would not impact his nonpartisan race.The Supreme Court of Hawaii dismissed the election contest claims for failure to state a claim. The court also construed the complaint as a petition for a writ of mandamus but denied the petition, finding that the plaintiff did not establish a clear and indisputable right to the relief requested or a lack of other means to address the alleged wrong. The court entered judgment in favor of the defendants. View "Dicks v. State " on Justia Law

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

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

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

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

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

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

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