League of Women Voters of Fla., Inc. v. Detzner

Citation: 354 F. Supp. 3d 1280Docket: Case No. 4:18-CV-251-MW/CAS

Court: District Court, N.D. Florida; July 24, 2018; Federal District Court

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Defendant's motion to abstain and alternative motion to dismiss has been denied by the court. Plaintiffs, consisting of six Florida college students and two organizations, allege that the Defendant, Florida's Secretary of State, violated their First, Fourteenth, and Twenty-Sixth Amendment rights by interpreting state law to exclude college-related facilities as early voting sites. Defendant's argument for abstention was based on the Pullman doctrine, which allows federal courts to defer to state court resolution on unsettled state law questions that could impact constitutional issues. However, the court emphasized that abstention is discretionary and generally inappropriate when federal rights, particularly First Amendment and voting rights, are at stake. The court referenced Supreme Court precedents establishing that abstention is not suitable in cases involving violations of fundamental rights. The Eleventh Circuit also supports this stance, reinforcing that such constitutional rights should be adjudicated in federal court.

Courts must consider the nature of the controversy and the significance of the right claimed to be violated, particularly in voting rights cases, which are deemed inappropriate for abstention as established by Eleventh Circuit precedent. The circuit's clear stance is that federal courts are not to abstain when voting rights are at issue, especially when a constitutional violation is alleged. Thus, granting a motion to abstain would contradict longstanding legal principles. The District Court did not abuse its discretion by refusing to abstain, as doing so would lead to delays that could hinder immediate resolution of voting rights issues, especially with upcoming elections.

Defendant's arguments for abstention based on the doctrine of constitutional avoidance lack merit, as abstention does not facilitate a faster resolution. The Defendant’s claim that the Court should dismiss the case due to lack of subject matter jurisdiction and failure to state a cause of action is also unpersuasive. Specifically, the Defendant questions the standing of the Plaintiffs, suggesting that they cannot demonstrate "redressability" and that the appropriate defendants are county election supervisors, not himself. He further argues that the remedies sought are speculative and that the organizational Plaintiffs lack standing. The Court will address each of these claims sequentially.

Defendant is identified as the appropriate party in this case, with the potential to remedy Plaintiffs' injuries through the invalidation of Defendant's Opinion, which allegedly restricts election supervisors' ability to designate early voting sites. Plaintiffs assert that this Opinion limits local supervisors' discretion, thereby seeking to restore that discretion. Although Defendant contends that Plaintiffs should have included the supervisors in the lawsuit, the court must assess whether the amended complaint presents sufficient factual grounds for relief, as established in Ashcroft v. Iqbal. There is a reasonable inference that Defendant's Opinion has curtailed the discretion afforded to supervisors under Florida law, as these officials typically regard the Division's written opinions as authoritative unless contradicted by a court or statutory directive.

The argument that Plaintiffs should sue individual supervisors is deemed implausible, as it contradicts their claim that these officials have been stripped of discretion. Defendant, as Florida's chief election officer, is therefore the proper defendant. A favorable ruling could address Plaintiffs' injuries by restoring the discretion of election supervisors, which has allegedly been limited by the Opinion. Defendant's assertion that the Opinion only affects the Alachua County supervisor is challenged on multiple fronts: several Plaintiffs are Alachua County voters directly impacted by the Opinion; its language suggests a broader application beyond specific campuses; and the requirement for uniformity in election law interpretation indicates that a prohibition affecting only Alachua County is inconsistent with statewide standards. Additionally, the expectation is that election supervisors across Florida will follow Defendant's Opinion, reinforcing the need for its invalidation.

Plaintiffs assert that their proposed relief is substantiated and not speculative. They present sufficient evidence indicating that public universities are likely to host early voting sites if the Court invalidates the Defendant's Opinion. Specifically, the Alachua County Board of County Commissioners, Gainesville City Commission, and the University of Florida's Student Senate have all passed supportive resolutions, including financial commitments for an early voting site on the University of Florida campus. A spokesperson from the University of Florida stated that the university is not opposed to hosting early voting but believes state law currently prohibits it.

The strong backing from local officials suggests that the elected supervisor of elections could align with this support, reinforcing the likelihood that the requested relief could address the alleged injury. The Court can determine from the record that the relief sought is likely to redress the injury, as supported by precedents like Hollywood Mobile Estates and Steele v. Nat'l Firearms Act Branch. Unlike past cases, where discretion was restored to local boards without mandating specific actions, Plaintiffs aim to return discretion to Florida's election supervisors regarding early voting site locations, providing evidence that indicates this relief is plausible rather than speculative.

Organizational plaintiffs, specifically the League of Women Voters and the Andrew Goodman Foundation, have standing to pursue their claims. While the defendant argues that some individual plaintiffs, particularly Dillon Boatner, lack standing due to not being registered to vote in Alachua County, Boatner's intention to change his registration and his significant time spent in the county establishes sufficient standing. This also grants associational standing to the League of Women Voters. The Andrew Goodman Foundation similarly holds associational standing, as individual plaintiffs Megan Newsome and Jamie Roy are members. The court need not determine whether these organizations have independent standing, as their members’ standing suffices. 

The defendant also contends that the plaintiffs have not stated a claim by failing to demonstrate actionable burdens under the Anderson-Burdick balancing test, arguing that no voter has been proven unable to vote due to a 2014 Advisory Opinion. However, the court clarifies that plaintiffs do not need to show effective disenfranchisement to state a claim; the burden imposed on voting rights must simply be weighed against the state's justifications for that burden. The plaintiffs' allegations regarding the absence of early-voting sites on public university campuses are sufficient to meet the requirements for a 12(b)(6) motion, indicating that they have adequately stated a claim.

Defendant's argument hinges on whether his Opinion disenfranchised voters, which the court finds to be a narrow interpretation of the Anderson, Burdick test. Pullman abstention is deemed inappropriate, as Defendant is the right party, and nullifying his Opinion could remedy Plaintiffs' claims. The court concludes that Plaintiffs have standing and their alleged injuries are more than speculative. Consequently, Defendant's motion to dismiss is denied.

The court emphasizes that Plaintiffs are asserting violations of the U.S. Constitution and are not seeking guidance on state law compliance. Previous case law, specifically the Eleventh Circuit's decision in Hand v. Scott, is distinguished as irrelevant, particularly concerning the application of Pennhurst principles. The court maintains that remedies are based on federal law, not state law.

Addressing abstention, the court notes historical precedent against its application in voting rights disputes, agreeing with dissenting judges in Siegel v. LePore. Defendant's reference to Obama for America v. Husted is countered by the court's assertion that the relevant standard is the burden on voting rights, not actual disenfranchisement of voters. The court reiterates that even minimal burdens must be justified by significant state interests, referencing legal standards from Crawford v. Marion County Election Board and Norman v. Reed. The court also acknowledges that the Twenty-Sixth Amendment's analysis falls under the Anderson, Burdick framework, and it will address the merits of the First and Fourteenth Amendment claims in its Preliminary Injunction Order.