Summary
The Supreme Court of Indiana considered whether misdemeanor battery constitutes an "infamous crime" under Article II, Section 8, of the Indiana Constitution. The court held that infamy depends on the nature of the offense rather than the punishment and that misdemeanor battery is not an infamous crime. It nevertheless concluded that the General Assembly has separate constitutional authority to cancel the voter registration of a person incarcerated following conviction for the duration of incarceration.
Topics
Practice areas
Questions Presented
- Whether Class A misdemeanor battery is an infamous crime under Article II, Section 8, of the Indiana Constitution.
- If misdemeanor battery is not an infamous crime, whether canceling Snyder's voter registration during his incarceration violated the Indiana Constitution.
- Whether the Indiana General Assembly has authority under its general police power to disenfranchise a person convicted of a crime and sentenced to an executed term of incarceration for the duration of that incarceration.
Holdings
- Whether an offense is an infamous crime depends on the nature of the offense, not the nature of the punishment imposed.
- An infamous crime is one involving an affront to democratic governance or the public administration of justice such that there is a reasonable probability that a person convicted of the crime poses a threat to the integrity of elections.
- Class A misdemeanor battery, as defined by Indiana law, is not an infamous crime under Article II, Section 8, of the Indiana Constitution.
- The General Assembly may, under its general police power, disenfranchise persons incarcerated following conviction of a crime for the duration of their incarceration.
- The Indiana Constitution was not violated when Snyder's voter registration was canceled during his incarceration following conviction of Class A misdemeanor battery.
Key quotations
“We hold that an infamous crime is one involving an affront to democratic governance or the public administration of justice such that there is a reasonable probability that a person convicted of such a crime poses a threat to the integrity of elections.” (at 782)
“We hold that the Indiana General Assembly has authority under its general police power to disenfranchise persons incarcerated upon conviction of a crime, so long as the disenfranchisement lasts only for the duration of incarceration.” (at 786)
“The posture of this case has rendered review of this important question of state constitutional law difficult.” (at 788)
Factual background
David Snyder was convicted of Class A misdemeanor battery and sentenced to serve an executed term in the St. Joseph County Jail from March until May 2009. During his incarceration, the St. Joseph County Board of Voter Registration notified him that his voter registration had been canceled under Indiana law. After his release, Snyder did not attempt to re-register, although the statutes permitted him to do so, and instead brought a federal lawsuit challenging the cancellation.
Procedural history
Snyder was convicted of Class A misdemeanor battery and sentenced to incarceration in the St. Joseph County Jail from March through May 2009. His voter registration was canceled during his incarceration. He filed a federal action under 42 U.S.C. § 1983 and asserted federal statutory and constitutional claims, along with a claim under the Indiana Constitution. The federal district court certified a question to the Indiana Supreme Court under Indiana Appellate Rule 64, and the Indiana Supreme Court accepted, revised, and answered the question.
Remand instructions
The opinion answers the certified questions for the federal district court. It does not direct a specific remand disposition, but leaves Snyder's federal statutory and constitutional claims, including his Equal Protection Clause claim, for resolution by the federal district court.