International Alliance of Theater Stage Employees Local 927 v. Lindsey, 1:23-cv-04929

The International Alliance of Theater Stage Employees Local 927 (the union) sued to enjoin enforcement of a Georgia law (S.B. 202) limiting the period for submitting absentee ballot applications to between 78 and 11 days before an election.
Plaintiff is a Georgia-based labor union whose members frequently travel for work and thus often rely on absentee voting.
The union alleges that the Georgia law's deadline (11 days before the election) violates Section 10502(d) of the Voting Rights Act, which permits absentee ballot applications up to 7 days prior.
The union sought a preliminary injunction to enjoin the contested provision before the upcoming presidential election.
The court considered standing (specifically associational standing’s “germaneness” prong) and whether relief was appropriate close to the election under the Purcell principle.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Associational standing – germaneness	Union’s mission includes supporting participation in democracy and elected officials who support labor; this makes voting rights germane.	Union’s core focus is labor rights, not voting rights or enforcement thereof.	Court found insufficient connection; voting rights not germane to union’s core mission.
Likelihood of success on merits	Union has members who will be harmed by the Georgia deadline, violating the VRA.	Union’s lack of standing defeats merits; no direct voting rights mission.	Union failed to show substantial likelihood of success due to lack of standing.
Preliminary injunction close to an election (Purcell)	Relief is urgent due to impending election; irreparable harm to members if law is enforced.	Courts should not alter election laws close to elections (Purcell principle).	Purcell bars injunction this close to election; election changes now risk confusion.
Timeliness (Delay in bringing suit)	Suit was brought before election; harm from law is imminent.	Law enacted 2+ years ago; union delayed in seeking injunctive relief.	Plaintiff’s delay weighed against granting relief under Merrill/Purcell.

Sofarelli v. Pinellas County, 931 F.2d 718 (Preliminary injunction standard in Eleventh Circuit)
Siegel v. LePore, 234 F.3d 1163 (Preliminary injunctions are an extraordinary remedy; movant must clearly establish prerequisites)
Friends of the Earth, Inc. v. Laidlaw Env’t Servs., 528 U.S. 167 (Established modern associational standing test)
Purcell v. Gonzalez, 549 U.S. 1 (Courts should avoid changing election procedures close to elections)
League of Women Voters of Fla., Inc. v. Florida Sec’y of State, 32 F.4th 1363 (Clarifies and applies the Purcell principle in the Eleventh Circuit)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (Constitutional requirements for standing)