City of Memphis, Tennessee v. Tre Hargett, Secretary of State, 414 S.W.3d 88

Background

In 2011 Tennessee enacted a voter ID law requiring photographic identification for in-person voting; acceptable IDs included photo IDs "issued by an entity of the State of Tennessee."
The Memphis Public Library began issuing photo ID cards; state election officials refused to accept those library IDs for the August 2012 primary.
Two Shelby County voters (Turner-Golden and Bell) and the City of Memphis sued state election officials seeking declaratory and injunctive relief; preliminary federal relief was denied and the suit proceeded in state court.
The trial court dismissed/denied relief; the Court of Appeals held plaintiffs had standing, upheld constitutionality, and ruled library IDs met the statute; this Court granted review.
While the appeal was pending the General Assembly amended the statute (2013) to narrow acceptable photo IDs and expressly exclude municipal/library IDs, which rendered issues about the library IDs moot.
The Tennessee Supreme Court held the City lacked standing, the individual plaintiffs had standing, and upheld the 2012-version photo ID requirement as constitutional (facially and as-applied) under the standard the Court assumed (strict scrutiny).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness of library-issued IDs	Library IDs are valid under the 2012 statute and courts should rule on their validity	2013 amendments removed the contested statutory language; renders dispute moot	Moot — statutory amendment excluded municipal/library IDs; no meaningful relief possible
Standing — City of Memphis	City may sue to vindicate its statutory right to issue IDs	City lacks a concrete, personal injury because voting rights belong to individuals	City lacks constitutional standing; cannot assert residents' individual voting rights
Standing — Individual voters	Turner-Golden and Bell were denied effective in-person voting and face future application of the law	Defendants say alternative remedies (free ID, absentee ballots, indigency affidavit) negate standing	Individuals have constitutional standing: distinct, traceable, redressable injuries
Undue-burden (facial and as-applied)	Photo ID imposes substantial burdens, may be poll-tax-like and prevents voting	State argues compelling interest in election integrity; requirement is narrowly tailored with exemptions/alternatives	Upheld: law survives strict-scrutiny assumption; facial challenge fails; as-applied claims fail — time/travel burdens not "impossible or oppressive"
Additional voting qualification	Photo ID is an extra, constitutionally prohibited qualification	Photo ID is a regulatory method to verify existing qualifications, allowed to secure ballot integrity	Not a forbidden additional qualification; it is a regulatory verification mechanism
Equal protection (in-person vs absentee)	Treating in-person and absentee voters differently violates equal protection/class-legislation clause	In-person and absentee voters are not similarly situated; different verification methods are necessary	Upheld: classes are not similarly situated; differing rules permissible

Key Cases Cited

Burdick v. Takushi, 504 U.S. 428 (U.S. 1992) (balancing framework for assessing burdens on voting rights)
Crawford v. Marion Cnty. Election Bd., 553 U.S. 181 (U.S. 2008) (upheld state photo-ID law under balancing analysis)
Munro v. Socialist Workers Party, 479 U.S. 189 (U.S. 1986) (states need not show existing fraud before enacting prophylactic election regulations)
Bemis Pentecostal Church v. State, 731 S.W.2d 897 (Tenn. 1987) (recognizing strong state interest in regulating elections and protecting ballot integrity)
Baker v. Carr, 369 U.S. 186 (U.S. 1962) (individual voters have standing to challenge election statutes)
Cook v. State, 16 S.W. 471 (Tenn. 1891) (Tennessee standard that legislative election regulations must not impose "impossible or oppressive" conditions on suffrage)