Florida Democratic Party v. Scott
215 F. Supp. 3d 1250
N.D. Fla.2016Background
- Plaintiff (a political party) sued Florida officials seeking to enjoin enforcement of the October 11, 2016 voter registration deadline after Hurricane Matthew impeded registration methods (in-person and mail).
- The emergency prevented many prospective voters (especially those who would register in the final week) from registering, effectively disenfranchising them for the 2016 election.
- Plaintiff requested a temporary restraining order (TRO) and interim relief extending registration; the Court considered standing and proper parties before reaching the merits.
- Court held the party had organizational standing to vindicate members’ voting rights without naming specific affected voters.
- The Court found the Florida Secretary of State (Detzner) a proper defendant for injunctive relief but concluded the Governor (Scott) likely lacked statutory authority to extend registration and therefore was not a proper defendant.
- The Court concluded Florida’s statutory scheme (no emergency extension of registration) severely burdened prospective voters and granted a TRO extending the deadline to October 12, 2016 at 5:00 p.m., pending a preliminary-injunction hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to sue | Party can assert members’ rights; specific named members not required | N/A | Party has standing to challenge deadline enforcement |
| Proper defendants | Governor and Secretary of State can be enjoined to protect registration | Governor lacked authority to extend registration; Secretary is chief election officer | Secretary Detzner is proper defendant; Governor Scott likely is not |
| Constitutional burden of deadline | Hurricane made registration impossible for many; statute thus severely burdens right to vote and fails strict scrutiny | State asserts other voting options (early/mail/Election Day) and interest in fixed deadlines | Court: statute severely burdens aspiring voters; fails strict scrutiny and alternative Anderson-Burdick review; unconstitutional |
| TRO factors (irreparable harm, balance, public interest) | Denial would permanently disenfranchise voters; minimal administrative burden to state; public interest favors enfranchisement | State interest in administrability and fixed deadlines | TRO granted: deadline extended to Oct 12, 2016 5:00 p.m.; hearing set on preliminary injunction |
Key Cases Cited
- Wesberry v. Sanders, 376 U.S. 1 (recognized the fundamental importance of voting)
- Ex parte Young, 209 U.S. 123 (suits against state officials for prospective injunctive relief permitted)
- Burdick v. Takushi, 504 U.S. 428 (Anderson-Burdick balancing test for election regulations)
- Anderson v. Celebrezze, 460 U.S. 780 (framework for evaluating burdens on voting rights)
- Harper v. Virginia State Board of Elections, 383 U.S. 663 (voting is a fundamental right)
- Washington State Grange v. Washington State Republican Party, 552 U.S. 442 (state election laws must not unconstitutionally burden voting)
- Arcia v. Florida Secretary of State, 772 F.3d 1335 (organizational standing in election cases)
- Common Cause/Georgia v. Billups, 554 F.3d 1340 (state interests must be sufficiently weighty to justify voting restrictions)
- League of Women Voters of North Carolina v. North Carolina, 769 F.3d 224 (permanent disenfranchisement cannot be remedied post-election)