Narrative Opinion Summary
The case involves appellants challenging the constitutionality of Indiana's voting provisions under both the Indiana and U.S. Constitutions. Gallagher and Mouser, representing voters who moved either within or between counties shortly before an election, argue that the restrictions placed on their voting rights violate Indiana Constitution Article 2, Section 2, and the Equal Protection Clause of the U.S. Constitution. The trial court upheld the voting provisions, but the appellate court reversed this decision, applying strict scrutiny given the fundamental nature of voting rights. The court found that the statutory scheme lacked a compelling state interest to justify the differential treatment of voters based on recent precinct changes. The court also dismissed the Election Board's argument of administrative convenience as insufficient, thus ruling the provisions unconstitutional under both strict and lesser scrutiny standards. The case was remanded for further proceedings, including consideration of additional relief for the plaintiffs. The ruling enjoins the Election Board from enforcing the contested provisions, marking a significant decision in election law regarding voter residency requirements.
Legal Issues Addressed
Administrative Convenience and State Interestsubscribe to see similar legal issues
Application: The court found no legitimate state interest in differentiating between voters moving within the same county and those moving between counties regarding voter registration transfers, rejecting administrative convenience as insufficient.
Reasoning: The Election Board justified the distinction between intra-county and inter-county voter registration transfers by citing administrative convenience... The court found no legitimate state interest to support this differentiation.
Equal Protection Clause of the U.S. Constitutionsubscribe to see similar legal issues
Application: The court determined that differential voting rights based on residency changes within thirty days of an election violate the Equal Protection Clause, requiring strict scrutiny due to the fundamental nature of voting rights.
Reasoning: Gallagher and Mouser contend that the voting rights granted to their subclasses under the statutory scheme... violate the Equal Protection Clause of the U.S. Constitution.
Interpretation of Indiana Constitution Article 2, Section 2subscribe to see similar legal issues
Application: The court examined whether the Constitution's requirement for residing in a precinct for thirty days before an election supports a voter's right to vote based on past residency, regardless of subsequent moves.
Reasoning: Gallagher and Mouser contend that the relevant Indiana Code provisions infringe upon their voting rights as articulated in Indiana Constitution Article 2, Section 2, which states that a citizen aged eighteen or older must reside in a precinct for thirty days immediately preceding an election to vote in that precinct.
Scrutiny Level for Voting Rightssubscribe to see similar legal issues
Application: The court applied strict scrutiny to assess the constitutionality of voting restrictions, as the right to vote is fundamental and no compelling state interest justified the provisions.
Reasoning: The court concludes that strict scrutiny is appropriate, citing the right to vote as fundamental and requiring that the distinctions in voting rights must serve a compelling state interest.