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Common Cause Ind. v. Lawson

Citation: 327 F. Supp. 3d 1139Docket: Case No. 1:17-cv-03936-TWP-MPB

Court: District Court, S.D. Indiana; June 8, 2018; Federal District Court

Narrative Opinion Summary

The case involves a legal challenge by Common Cause Indiana against Indiana Senate Enrolled Act 442 (SEA 442), which amends voter registration laws, alleging it violates the National Voter Registration Act (NVRA) of 1993. Common Cause, a nonprofit advocating for voting rights, claims that SEA 442 undermines NVRA procedural safeguards by allowing voter registration cancellations without written confirmation or proper notice, potentially disenfranchising eligible voters. The organization seeks a preliminary injunction to prevent the enforcement of SEA 442, arguing that the law contravenes federal requirements for maintaining voter rolls and risks wrongful disenfranchisement. Common Cause asserts standing based on the diversion of resources necessitated by the law's implications on its mission and potential harm to its members. The court grants the preliminary injunction, concluding that Common Cause demonstrates a likelihood of success on the merits, irreparable harm, and that the injunction serves the public interest, outweighing any harm to the state. The decision emphasizes the importance of protecting voting rights and adherence to NVRA standards, while noting that SEA 442 lacks uniformity and sufficient procedural safeguards.

Legal Issues Addressed

Balancing Equities in Injunction Requests

Application: The court determines that the balance of equities favors granting the injunction to prevent disenfranchisement over the state's interest in enforcing SEA 442.

Reasoning: The Court finds that the balance of equities strongly supports granting an injunction to Common Cause.

Irreparable Harm in Voting Rights Cases

Application: The court finds irreparable harm in the potential disenfranchisement of voters, emphasizing that voting rights violations cannot be remedied post-election.

Reasoning: The imminent risk of wrongful disenfranchisement constitutes irreparable harm. Common Cause argues that the Defendants' reliance on a 'fail-safe' voting procedure to justify SEA 442 is incorrect.

National Voter Registration Act Compliance

Application: The NVRA mandates procedures for voter roll maintenance, including written confirmation of address changes or specific notice requirements, which SEA 442 allegedly contravenes.

Reasoning: The NVRA mandates that states must adhere to specific procedures when maintaining voter registration rolls, particularly regarding the removal of voters due to change of residence.

Preliminary Injunction Standards

Application: The court grants a preliminary injunction when the plaintiff demonstrates a likelihood of success, irreparable harm, favorable balance of equities, and that the injunction serves the public interest.

Reasoning: The legal standard for granting a preliminary injunction requires the moving party to demonstrate a likelihood of success on the merits, potential for irreparable harm, a favorable balance of equities, and that the injunction serves the public interest.

Standing in Voter Registration Cases

Application: Common Cause has standing to challenge SEA 442 based on resource diversion and potential voter disenfranchisement resulting from the law's implementation.

Reasoning: Common Cause has established standing to seek declaratory and injunctive relief related to SEA 442, having demonstrated that it has diverted resources in response to the law's implementation, which poses imminent injury to its mission.