716 F.Supp.3d 1236
N.D. Fla.2024Background
- Plaintiffs, including the League of Women Voters of Florida, challenged amendments to Florida’s Election Code made by S.B. 90, focusing on provisions regulating drop box voting and third-party voter registration organizations (3PVROs).
- After a two-week bench trial in 2022, the District Court ruled on the merits, but the Eleventh Circuit reversed in part, affirmed in part, and remanded for a limited determination under the First and Fourteenth Amendments.
- The Eleventh Circuit required the District Court to apply the Anderson-Burdick test to the drop-box restrictions and registration-delivery requirements.
- The Eleventh Circuit made certain factual findings, including asserting that voter fraud had “plagued” Florida elections, and found justifications for the state’s new voting restrictions.
- On remand, the District Court was bound by the Eleventh Circuit’s factual and legal findings, even when differing from its previous conclusions after trial.
- Ultimately, the District Court found that while the provisions imposed some burdens, they did not unduly burden the right to vote and entered judgment for Defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Drop-box restrictions under S.B. 90 | Restrictions on monitored and limited hours for drop boxes severely burden those who rely on after-hours voting, especially marginalized groups. | Restrictions are justified to prevent fraud and maintain election integrity; voting remains available by other means. | Modest burden that does not unduly burden the right to vote; state’s interests deemed weighty enough to justify. |
| Registration-delivery requirements (3PVROs) | Imposes significant obstacles on 3PVROs and voters who rely on them, especially Black voters; increases costs and limits voter registration opportunities. | Requirements are legitimate, non-discriminatory, and ensure the integrity and timely processing of registrations. | Indirect burden outweighed by state’s legitimate interests; not an undue burden on voting rights. |
| Disparate Impact/Race | Restrictions were intentionally racially discriminatory, as they targeted modalities disproportionately used by Black voters. | Laws are facially neutral, and motivations were not intentionally discriminatory as per the Eleventh Circuit's finding. | No intentional discrimination found for Anderson-Burdick claims; disparate impact considered but not dispositive. |
| Anderson-Burdick balancing standard | Severe burdens invoke strict scrutiny, and balancing should favor protection of access to all voting modalities affected by the law. | Regulations impose only minor or incidental burdens, justifiable by regulatory interests such as fraud prevention. | Applied Anderson-Burdick; found burdens not severe, state interests sufficient, so restrictions are constitutional. |
Key Cases Cited
- Burdick v. Takushi, 504 U.S. 428 (U.S. 1992) (establishes the Anderson-Burdick balancing test for election law burdens)
- Anderson v. Celebrezze, 460 U.S. 780 (U.S. 1983) (sets out the balancing framework for evaluating voting restrictions under the Constitution)
- Crawford v. Marion Cnty. Election Bd., 553 U.S. 181 (U.S. 2008) (emphasizes that even minor burdens on voting must be justified by legitimate state interests)