Minnesota Voters Alliance, et al. v. Ritchie, et al., No. 12-2946 (8th Cir. 2013)
Annotate this CaseVoters filed suit against Officials challenging the process by which Officials confirmed the eligibility of voters who register on election day (election day registrants or EDRs). Voters also challenged a provision of the Minnesota Constitution denying the right of persons under guardianship to vote, as well as the sufficiency of notice afforded to such persons under certain Minnesota statutes. The court concluded that Voters could not prevail on their 42 U.S.C. 1983 claims based on Officials' failure to verify EDR's voting eligibility before allowing EDRs to cast their votes where Voters raised no allegations of the "aggravating factors" identified in Pettengill v. Putnam County R-1 School District; alleged no discriminatory or other intentional, unlawful misconduct by Officials sufficient to implicate section 1983; and alleged no defects causing Minnesota's voting system to be so "fundamentally unfair" that relief under section 1983 would be appropriate. Further, Voters lacked standing to raise their remaining claims where the amended complaint failed to allege that any plaintiff has been denied the right to vote by a constitutional provision barring persons under guardianship from voting. Accordingly, the court affirmed the district court's dismissal of Voters claims and denial of their motion for summary judgment as moot.
Court Description: Civil case - Civil rights. In a Section 1983 action challenging the process by which Minnesota election officials confirm the eligibility of voters who register on election day and a provision of the Minnesota Constitution denying the right of persons under guardianship to vote, the district court did not err in finding that plaintiffs failed to state a claim under Section 1983 with respect to their registration issues as their allegations did not raise any of the aggravating factors this court identified in Pettengill v. Putnam County R-1 School District, 472 F.2d 121 (8th Cir. 1973), any discriminatory or other intentional misconduct or any defect that would cause Minnesota's system to be fundamentally unfair; with respect to the guardianship claims, plaintiffs failed to show they had standing to raise them as they failed to allege that any plaintiff had been denied the right vote under the provision.
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