Common Cause Indiana v. Connie Lawson

Summary

The Seventh Circuit granted a stay and summarily reversed a preliminary injunction that had blocked Indiana's 2019 election code amendments restricting who may seek court-ordered extensions of polling hours. The court held the amendments did not unconstitutionally burden the right to vote under the Anderson-Burdick balancing test, did not violate the Supremacy Clause because they only created a state-law cause of action and did not limit § 1983 claims, and did not violate procedural due process. Additionally, the injunction violated the Purcell principle by altering election rules too close to Election Day, and the plaintiff's year-long delay in challenging the statutes weighed against equitable relief.

Holdings

1. The amendments do not place a burden on the right to vote; the district court erred in concluding they do.
2. The amendments do not violate the Supremacy Clause because they are reasonably read to apply only to the state-law cause of action, not to § 1983 claims.
3. The amendments do not deprive voters of any constitutionally protected interest; even if they have a liberty interest in statutory poll hours, the amendments have not deprived them of that interest.
4. The injunction falls within Purcell's ambit because it was issued on the eve of the election, and the plaintiff waited over a year to challenge the amendments.

Questions Presented

1. Whether the 2019 amendments to Indiana's election code governing extensions of poll hours unconstitutionally burden the fundamental right to vote under the Anderson-Burdick test.
2. Whether the amendments violate the Supremacy Clause by divesting state courts of jurisdiction to hear § 1983 claims.
3. Whether the amendments deprive voters of procedural due process.
4. Whether the district court's injunction was barred by the Purcell principle because it was issued too close to the election.

Disposition

reversed