644 S.W.3d 59
Tenn.2022Background
- After the 2020 census the Tennessee General Assembly enacted a new State Senate apportionment (Public Chapter 596). Plaintiffs (three registered voters) sued, alleging the plan violates Tenn. Const. art. II, § 3 by failing to consecutively number four Senate districts in Davidson County.
- A three-judge chancery panel heard the challenge; plaintiffs moved for a temporary injunction to enjoin the Senate plan, give the Legislature 15 days to fix the defect, impose an interim map if not remedied, and extend the statutory candidate filing deadline (April 7) to May 20 (later reduced by the panel to May 5).
- On April 6, 2022 the panel majority granted a mandatory temporary injunction enjoining the Senate plan, gave the General Assembly 15 days to correct the defect, and extended the senatorial candidate filing deadline to May 5; one judge dissented, urging a full evidentiary hearing.
- Defendants (Governor, Secretary of State, Coordinator of Elections) sought extraordinary appellate review; the Tennessee Supreme Court assumed jurisdiction and expedited the appeal.
- The Secretary of State and several county election administrators submitted affidavits detailing extensive, time-sensitive tasks tied to the April 7 qualifying deadline (MOVE Act compliance, ballot proofing/printing, precinct adjustments, voter notice, candidate database setup, training), arguing any delay would harm election administration and risk voter confusion.
- The Tennessee Supreme Court vacated the injunction, holding the trial court failed to adequately weigh the injury to election officials and the public interest; it remanded and provided a limited, equitable extension of the filing deadline to April 14, 2022 at 4:00 p.m.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a mandatory temporary injunction enjoining the Senate plan was appropriate pending final judgment | Moore: plan likely violates consecutive-numbering requirement; injunctive relief and 15-day legislative cure plus interim map necessary to prevent irreparable harm to plaintiffs' voting rights | Lee: injunction disrupts election machinery, harms State and public, and an extension of the statutory filing deadline would impede MOVE Act compliance and ballot preparation | Trial court abused discretion by granting the injunction because it failed adequately to weigh harm to election officials and public interest; injunction vacated |
| Whether the trial court properly balanced irreparable harm to plaintiffs against harm to defendants and public | Moore: alleged irreparable injury (right to vote in consecutively numbered districts) warrants injunction | Lee: affidavits show substantial, concrete harms to election administration and voters from altering deadlines and maps so close to elections | Court held plaintiffs' claimed harm was outweighed by significant administrative/public harm; balance favored denying injunction |
| Whether altering the statutory candidate filing deadline was permissible relief | Moore: extension (originally to May 20; panel set May 5) necessary if plan enjoined | Lee: statutory deadline (first Thursday in April) and tied deadlines make late extension highly disruptive | Court rejected the extended deadline granted by the panel; instead ordered a narrow, equitable extension to April 14, 4 p.m. |
| Standing to bring constitutional challenge | Moore: qualified voters suing to enforce constitutional numbering requirement | Lee: argued plaintiffs lacked standing (challenged below) | Court did not resolve standing on interlocutory review and declined to decide; decision rests on failure to weigh harms properly |
Key Cases Cited
- Fisher v. Hargett, 604 S.W.3d 381 (Tenn. 2020) (standard of review and injunction factors; abuse-of-discretion framework)
- Lee Med., Inc. v. Beecher, 312 S.W.3d 515 (Tenn. 2010) (discretionary decisions require consideration of guiding factors)
- Purcell v. Gonzalez, 549 U.S. 1 (2006) (courts should be cautious about changing election rules near an election due to voter confusion and integrity concerns)
- Republican Nat'l Comm. v. Democratic Nat'l Comm., 140 S. Ct. 1205 (2020) (reinforcing limits on altering election rules on the eve of elections)
- Diaz v. Silver, 932 F. Supp. 462 (E.D.N.Y. 1996) (public interest may weigh against injunction where election machinery is already engaged)
- State ex rel. Lockert v. Crowell, 656 S.W.2d 836 (Tenn. 1983) (Tennessee court experience showing restraint in enjoining reapportionment plans where disruption to elections is significant)