Madison Cawthorn v. Barbara Lynn Amalfi, No. 22-1251 (4th Cir. 2022)
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North Carolina law allows “[a]ny qualified voter registered in the same district as the office for which [a] candidate has filed or petitioned” to file a challenge with the state board of elections asserting “that the candidate does not meet the constitutional or statutory qualifications for the office.” N.C. Gen. Stat. Sections 163-127.1, -127.2. A group of voters in Representative Cawthorn’s district filed such a challenge. According to the voters, Representative Cawthorn encouraged the violent mob that disrupted the peaceful transition of power by invading the United States Capitol on January 6, 2021, and that encouragement constituted “insurrection” and disqualifies Representative Cawthorn for further service in Congress. Seeking to stop the challenge process from going forward, Representative Cawthorn sued the members of the state board of elections in federal district court.
The Fourth Circuit reversed the district court’s grant of injunctive relief and remanded for further proceedings. The court held that consistent with the statutory text and context, the 1872 Amnesty Act removed the Fourteenth Amendment’s eligibility bar only for those whose constitutionally wrongful acts occurred before its enactment. The court concluded that the district court erred in construing the Act as a sweeping removal of all future Fourteenth Amendment disabilities. Thus, because the district court’s ruling was based solely on its view of the 1872 Amnesty Act, the court reversed its decision and vacated the permanent injunction.
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