Lacasa v. Townsley
883 F. Supp. 2d 1231
S.D. Fla.2012Background
- Plaintiffs seek to vote in the August 14, 2012 Democratic Primary for Miami-Dade State’s Attorney; the race has two declared Democrats and two write-ins with mixed party designations.
- Universal Primary Amendment Florida Const. art. VI, §5(b) purportedly allows all qualified electors to vote in a primary if all candidates share the same party affiliation and there is no opposition.
- Two write-in candidates qualified for the general election: Samaroo (Democrat) and Malone (Republican), creating a potential ‘opposition’ in the general election.
- The State closed the Democratic Primary due to the write-ins; Plaintiffs allege this infringes their voting rights as non-Democrats.
- Plaintiffs file a Second Amended Complaint and emergency injunction; court later dismisses Count II for lack of standing and declines jurisdiction over Count I.
- Court notes that the Florida Democratic Party did not take a position on open vs. closed primaries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Plaintiffs have standing to challenge the primary | Mazzilli has a right to vote; Lacasa’s rights are implicated. | No concrete injury; no redressable harm given statutory scheme. | Plaintiffs lack standing; Count II dismissed. |
| Whether Plaintiffs have a First Amendment associational interest to vote in a non-party primary | Non-party voters have associational rights to vote in a party primary. | No meaningful association beyond casting a ballot; interests limited and not constitutionally protected. | Associational interest not cognizable; Count II dismissed. |
| Whether the Universal Primary Amendment is unambiguous and governs whether the primary should be open | Write-ins do not constitute opposition; primary should be open. | Amendment is unambiguous; write-ins constitute opposition; primary may be closed. | Amendment unambiguous; write-ins constitute opposition; primary properly closed. |
| Whether the court should exercise supplemental jurisdiction over state-law claims | State-law claims are tied to federal questions and should be heard. | Novel state-law issues; court should decline supplemental jurisdiction. | Declines supplemental jurisdiction; Count I dismissed. |
Key Cases Cited
- California Democratic Party v. Jones, 530 U.S. 567 (2000) (non-party voters' associational rights depend on surrounding interests)
- Clingman v. Beaver, 544 U.S. 581 (2005) (state interests can justify closed primaries; protects party integrity)
- Tashjian v. Republican Party of Connecticut, 479 U.S. 208 (1987) (party interests may override non-party participation in primaries)
- Rosario v. Rockefeller, 410 U.S. 752 (1973) (registration timing to prevent party raiding; state interest in election integrity)
- Jones v. United States, 530 U.S. 2402 (2000) (not provided in the original text; placeholder removed)
- United States v. Classic, 313 U.S. 299 (1941) (right to vote in a party primary subject to regulation)
- Nader v. Schaffer, 417 F. Supp. 837 (1976) (federal courts should defer to democratic processes over judicial fiat)