American Civil Rights Union v. Snipes, No. 18-11808 (11th Cir. 2019)Annotate this Case
The ACRU filed suit alleging that defendant, the former Broward County Supervisor of Elections, failed to satisfy her list-maintenance obligations under the National Voter Registration Act (NVRA).
The Eleventh Circuit held that, under the NVRA, the states and their subsidiaries are required to conduct a general program of list maintenance that makes a reasonable effort to remove voters who become ineligible on account of death or change of residence, and only on those two accounts. The court also held that nothing in the Help America Vote Act (HAVA) changes what is required by the NVRA. Finally, the court held that the NVRA sets forth an explicit safe-harbor procedure by which the states may fulfill their list-maintenance obligations as to voters who move. In this case, the district court did not clearly err by finding that defendant's Election Supervisor conducted a program reasonably designed to accomplish these tasks required under the NVRA. Accordingly, the court affirmed the judgment of the district court.