Lyman v. Baker, 352 F. Supp. 3d 81

Plaintiffs are three Massachusetts voters (two Republicans, one Libertarian) who consistently vote for non-Democratic presidential candidates and challenge Massachusetts’ winner-take-all (WTA) elector allocation statute as unconstitutional.
Massachusetts awards all its presidential electors to the statewide plurality winner under Mass. Gen. Laws ch. 54, § 118; plaintiffs say votes for losing candidates are effectively discarded and weaken minority-party influence.
Plaintiffs assert two constitutional claims: (1) a "one person, one vote" violation under the Equal Protection Clause; and (2) a First Amendment freedom-of-association/associational-harm claim. They seek declaratory and injunctive relief and an order requiring the state to adopt a proportional allocation method.
Defendants (Governor and Secretary of the Commonwealth, sued in official capacities) moved to dismiss under Fed. R. Civ. P. 12(b)(1) and 12(b)(6); the court analyzed the merits under Rule 12(b)(6) and considered standing as overlapping with the merits.
The district court concluded Massachusetts’ WTA system is constitutional, dismissing both claims and holding plaintiffs failed to allege cognizable constitutional injuries; it also noted federalism and Article II limits on courts ordering a particular state elector-allocation method.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether WTA violates "one person, one vote"	WTA discards minority votes and dilutes equal voting weight; requires proportional allocation	Williams and Supreme Court precedent permit WTA; WTA does not arbitrarily weight votes	Court: Dismiss — Williams controls; WTA does not violate one person, one vote
Whether doctrinal changes (e.g., Bush) nullify Williams	Bush and later cases allow challenge where votes are arbitrarily valued	Bush is limited; Williams still binding; no demonstrated doctrinal overruling	Court: Dismiss — Williams remains binding; no material doctrinal shift alters result
Whether WTA imposes First Amendment associational harm	WTA burdens association by depriving minority parties of electoral voice and weakening party viability	WTA does not target groups by viewpoint; disadvantage flows from electoral losses, not state-imposed disfavor	Court: Dismiss — no alleged purposeful, view-based burden; First Amendment claim fails
Redressability / remedy: Can court order proportional allocation	Plaintiffs seek injunction requiring proportional or district-based allocation	State has plenary Article II authority; courts lack constitutional power to dictate allocation method; remedy would implicate federalism and likely require constitutional amendment	Court: Dismiss — proposed relief not properly ordered by federal court; claim unredressable

Lujan v. Defs. of Wildlife, 504 U.S. 555 (standing elements: injury, causation, redressability)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for Rule 12(b)(6))
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards applied to constitutional claims)
Gray v. Sanders, 372 U.S. 368 (discussing electoral college and one person, one vote)
Reynolds v. Sims, 377 U.S. 533 (one person, one vote principle)
Williams v. Va. State Bd. of Elections, 393 U.S. 320 (per curiam) (summary affirmance upholding state WTA elector selection)
Bush v. Gore, 531 U.S. 98 (limited holding on equal treatment of votes; state authority over electors discussed)
McPherson v. Blacker, 146 U.S. 1 (state legislatures’ plenary power to appoint electors)
Roman v. Sincock, 377 U.S. 695 (equal protection requires non-arbitrary population-based representation)
City of Mobile v. Bolden, 446 U.S. 55 (rejection of claim that Constitution guarantees proportional representation)
Whitcomb v. Chavis, 403 U.S. 124 (multimember districts with winner-take-all aspects do not per se violate Equal Protection)
Gill v. Whitford, 138 S. Ct. 1916 (standing and discussion of partisan gerrymandering; Justice Kagan’s concurrence on associational harm)
Vieth v. Jubelirer, 541 U.S. 267 (Kennedy concurrence on First Amendment as relevant forum for partisan-gerrymander-type harms)
California Democratic Party v. Jones, 530 U.S. 567 (First Amendment protection of political association)