Snyder v. King
2011 Ind. LEXIS 1091
| Ind. | 2011Background
- David Snyder was convicted of Class A misdemeanor battery in Indiana and sentenced to a jail term in St. Joseph County in 2009.
- On March 4, 2009, Snyder's voter registration was canceled under Indiana law due to incarceration.
- Snyder was released from incarceration and did not attempt to re-register; he instead sued in federal court under Section 1983, alleging violations of NVRA, HAVA, Civil Rights Act, and First/Fourteenth Amendments, plus an Infamous Crimes Clause claim.
- The Indiana Infamous Crimes Clause grants the General Assembly power to disenfranchise those convicted of infamous crimes, without a durational limit, but the case questions whether misdemeanor battery is an infamous crime.
- The Supreme Court of Indiana certified a question to determine (a) whether misdemeanor battery is an infamous crime under Article II, § 8, and (b) if not, whether disenfranchisement of Snyder during incarceration violated the Indiana Constitution.
- The Court ultimately holds that misdemeanor battery is not an infamous crime by its nature, but the General Assembly has police-power authority to disenfranchise incarcerated individuals for the duration of incarceration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is misdemeanor battery an infamous crime under Article II, § 8? | Snyder contends misdemeanor battery is not infamous, so removal violates the Infamous Crimes Clause. | State argues infamous-crime status can be defined by legislative power to disenfranchise; historically some misdemeanors may be infamous. | No; misdemeanor battery is not by its nature an infamous crime. |
| Does the disenfranchisement of Snyder during incarceration violate the Indiana Constitution if the crime is not infamous? | If not infamous, disenfranchisement during incarceration would exceed constitutional authority. | Disenfranchisement during incarceration is permissible as a collateral consequence of incarceration under state police power. | Disenfranchisement during incarceration does not violate the Indiana Constitution; authority rests in the General Assembly’s police power for the duration of incarceration. |
| What is the proper scope of the Infamous Crimes Clause and the General Assembly's power to disenfranchise? | Infamous Crimes Clause limits disenfranchisement to crimes inherently infamous; Snyder argues broader interpretation is improper. | General Assembly may declare certain crimes as infamous and disenfranchise accordingly; modern interpretation should align with upholding electoral integrity. | Infamous crime is determined by the nature of the offense, not the punishment; however, the General Assembly can disenfranchise incarcerated individuals for the duration of incarceration. |
| Does the statute disenfranchising incarcerated individuals improperly rely on the Infamous Crimes Clause rather than police power? | Disenfranchisement must arise from Infamous Crimes Clause; using police power to disenfranchise may exceed constitutional authority. | Disenfranchisement as a collateral consequence of incarceration may be grounded in police power and does not require Infamous Crimes Clause. | The General Assembly may exercise police power to disenfranchise incarcerated persons for the duration of incarceration; citing Infamous Crimes Clause is not dispositive. |
Key Cases Cited
- Crum v. State, 148 Ind. 401, 47 N.E. 833 (1897) (Ind. 1897) (infamous-crime analysis tied to moral taint and disenfranchisement)
- Baum v. State, 157 Ind. 282, 61 N.E. 672 (1901) (Ind. 1901) (infamous crime punishment concept used to justify disenfranchisement)
- Crampton v. O'Mara, 193 Ind. 551, 139 N.E. 360 (1923) (Ind. 1923) (Grand Jury Clause and infamous-crime lineage acknowledged)
- Ashton v. Anderson, 258 Ind. 51, 279 N.E.2d 210 (1972) (Ind. 1972) (nine infamous crimes under Indiana law and related evidence rules)
- Ex parte Wilson, 114 U.S. 417 (1885) (U.S. 1885) (federal reference to infamous crimes doctrine in grand jury context)
- Bayh v. Sonnenburg, 573 N.E.2d 398 (Ind.1991) (Ind. 1991) (constitutional interpretation principles for Indiana)
- Lucas v. McAfee, 217 Ind. 534, 29 N.E.2d 588 (1940) (Ind. 1940) (discusses Infamous Crimes Clause context in Indiana history)