Abdurrahman v. Dayton, No. 16-4551 (8th Cir. 2018)
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After plaintiff was appointed as a presidential elector during the 2016 presidential election, he was deemed to have vacated his position under Minnesota's Uniform Faithful Presidential Electors Act, Minn. Stat. 208.40-208.48, when he attempted to vote for candidates other than those to whom he was pledged. Plaintiff then filed suit challenging the constitutionality of the Minnesota statute and to enjoin Minnesota officials from counting the vote of the substitute elector.
The Eighth Circuit affirmed the district court's dismissal of the action as moot where Congress had counted the Minnesota elector votes, and denied plaintiff's motion to supplement the record and to remand for further proceedings on mootness. The court held that plaintiff failed to establish that his action fell within the mootness exception for cases that were capable of repetition yet evading review because plaintiff failed to file his action sooner.
Court Description: Colloton, Author, with Smith, Chief Judge, and Murphy, Circuit Judge] Civil case - Minnesota Uniform Faithful Presidential Electors Act. This opinion is issued by Chief Judge Smith and Judge Colloton under 8th Cir. R. 47E. After the State of Minnesota appointed plaintiff as a presidential elector in the 2016 presidential election, he attempted to vote for candidates other than those to whom he was pledged and Minnesota deemed him to have vacated his position and appointed a substitute elector. Plaintiff then brought this action to have the Minnesota Uniform Faithful Presidential Electors Act declared unconstitutional and to enjoin the counting of the vote of the substitute elector. Held, the district court properly dismissed the action as moot as Congress has counted the Minnesota elector votes; the action is not saved by the mootness exception for cases capable of repetition yet evading review; a party seeking to claim the exception on the ground the time was too short to fully litigate the claim must take advantage of legal avenues that would allow for litigation within the necessary time, something plaintiff failed to do.
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