Chamness v. Maldonado, No. 11-56303 (9th Cir. 2013)
Annotate this CasePlaintiffs challenged the constitutionality of certain sections of California Senate Bill 6 (SB 6). SB 6, implementing California's Proposition 14 (Prop. 14), fundamentally changes the California election system by eliminating party primaries and general elections with party-nominated candidates, and substituting a nonpartisan primary and a two-candidate runoff. The court concluded that it had jurisdiction over the appeal; Plaintiff Chamness' case was not moot where his claim was capable of repetition because future election administrators would deny him the ability to use the designation "Independent" on the primary ballot; Plaintiffs Frederick's and Wilson's appeal were moot because they only sought declaratory relief affecting future elections; and Intervenor Galacki's claims regarding his write-in candidacy and the vote he cast for himself in the general election were moot. In Case No. 11-56449, the court held that Chamness failed to establish that SB 6 severely burdened his rights, and upheld the constitutionality of the statute as reasonably related to furthering the state's important interest in efficiently regulating elections. In Case No. 56303, the court held that the trial court acted well within its discretion in concluding that allowing Galacki to intervene would entail substantial delays and inefficiencies resolving the case, and in therefore denying Galacki's motion as untimely. Accordingly, the court affirmed the trial court's order granting defendants summary judgment and denying Galacki's motion to intervene.
Court Description: Civil Rights. The panel affirmed the district court’s order granting defendants summary judgment and denying a motion to intervene in this action brought by plaintiffs challenging the constitutionality of certain sections of California Senate Bill 6, legislation which, implementing California’s Proposition 14, changed the California election system by eliminating party primaries and general elections with party-nominated candidates, and substituting a nonpartisan primary and a two- candidate runoff. The panel first dismissed as moot the appeal by two of the plaintiffs and the claims of a potential intervenor which challenged the counting of write-in ballots, noting that the California Elections Code has been amended to clarify that voters are not permitted to cast write-in ballots in top-two general elections. The panel then rejected the claim brought by the third plaintiff alleging that his First Amendment rights had been violated because in the special congressional primary election in which he wished to participate, he was prohibited from using the ballot label “Independent” and was instead forced to choose between a preferred party designation, “No Party Preference,” or a blank space on that part of the ballot. The panel held that plaintiff failed to establish that SB 6 severely burdened his rights, noting that plaintiff failed to present any evidence to support his claim that there was a difference between “Independent” and “No Party Preference.” The panel held that the law in this case represented a reasonable, nondiscriminatory restriction that imposed a slight burden on speech and was sufficiently supported by the state’s important regulatory interests. The panel held that the district court did not abuse its discretion in denying the motion to intervene by Julius Galacki, who attempted to run as a write-in candidate in a July 12, 2011, general election for a congressional district. The panel noted that Galacki knew of the law he wished to challenge, and the effects it would have, well before the time he filed his motion and therefore the district court acted within its discretion in denying the motion as untimely.
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