Ernest Falls v. Mark Goins, 673 S.W.3d 173

Ernest Falls, convicted of involuntary manslaughter in Virginia (1986), moved to Tennessee in 2018 and admitted he was disenfranchised when he moved.
Virginia Governor granted individualized clemency in February 2020 restoring Falls’s citizenship rights, including the right to vote under Virginia law.
Falls attempted to register to vote in Grainger County, TN, in June 2020; his application was denied as having "Incomplete/Insufficient Document(s)."
Falls sued state election officials seeking a declaration that Tenn. Code Ann. § 2-19-143(3) automatically restored his Tennessee voting rights when Virginia restored his rights; defendants relied on Tenn. Code Ann. § 40-29-202 requiring proof of payment of restitution, court costs, and current child support to regain suffrage.
Trial court granted summary judgment to state officials; the Court of Appeals affirmed; the Tennessee Supreme Court affirmed, holding that persons in Falls’s circumstances must satisfy both § 2-19-143(3) and § 40-29-202.
The Court limited its holding to the specific fact that Falls’s Virginia restoration occurred after he established Tennessee residency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 2-19-143(3) self-executes to immediately restore voting rights in Tennessee when another state’s governor restores citizenship rights	Falls: restoration in Virginia automatically re-enfranchised him in Tennessee without additional Tennessee requirements	State: Falls must also satisfy Tennessee’s re-enfranchisement procedures (§ 40-29-202) before voting rights are restored	Court: Must comply with both § 2-19-143(3) and § 40-29-202; § 2-19-143(3) is not self-executing in these facts; summary judgment for defendants affirmed
Whether applying Tennessee’s re-enfranchisement requirements to out-of-state restorations violates the Full Faith and Credit Clause	Amicus: Tennessee must give effect to other states’ restorations and cannot impose additional conditions	State: A State may legislate its own qualifications for suffrage and need not adopt other states’ policies	Court: No Full Faith and Credit violation; States may apply their own suffrage laws and conditions

In re Kaliyah S., 455 S.W.3d 533 (Tenn. 2015) (statutes relating to same subject construed in pari materia to give effect to both)
Lovlace v. Copley, 418 S.W.3d 1 (Tenn. 2013) (specific statutory provisions prevail over general ones)
Franchise Tax Bd. of Cal. v. Hyatt, 578 U.S. 171 (2016) (States are not required to substitute other states’ statutes for their own)
Crutchfield v. Collins, 607 S.W.2d 478 (Tenn. Ct. App. 1980) (universal suffrage is self-executing; exceptions are not)
Gaskin v. Collins, 661 S.W.2d 865 (Tenn. 1983) (affirming Crutchfield principles)
Wesley v. Collins, 791 F.2d 1255 (6th Cir. 1986) (states may constitutionally disenfranchise convicted felons)