Case: The Republican State Committee of Delaware v. The State of Delaware Department of Elections

2020-0685-SG | Delaware state trial court

Filed Date: Aug. 19, 2020

Closed Date: Sept. 29, 2020

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Case Summary

This case concerns the constitutionality of Delaware's House Bill 346 ("HB 346"), which established a universal vote-by-mail system for the 2020 general election in response to the COVID-19 pandemic. On August 19, 2020, the Republican State Committee of Delaware (the "RSC"), along with individual plaintiffs John Foltz and Paula Manolakos, filed a lawsuit in the Court of Chancery of the State of Delaware against the State of Delaware Department of Elections and State Election Commissioner Anthon…

This case concerns the constitutionality of Delaware's House Bill 346 ("HB 346"), which established a universal vote-by-mail system for the 2020 general election in response to the COVID-19 pandemic.

On August 19, 2020, the Republican State Committee of Delaware (the "RSC"), along with individual plaintiffs John Foltz and Paula Manolakos, filed a lawsuit in the Court of Chancery of the State of Delaware against the State of Delaware Department of Elections and State Election Commissioner Anthony J. Albence. The plaintiffs were represented by Klein LLC, while the defendants were represented by the Delaware Department of Justice and Connolly Gallagher LLP. Vice Chancellor Sam Glasscock III was the presiding judge.

The RSC sought a permanent injunction to prevent the implementation of HB 346 and a declaratory judgment that the law violated Article V, § 4A of the Delaware Constitution, which enumerates specific and exhaustive grounds for absentee voting. They argued that the new law improperly expanded absentee voting beyond constitutional limits by allowing all registered voters to vote by mail without meeting the conditions outlined in Art. V, § 4A, of the state constitution. They further contended that the General Assembly exceeded its authority by relying on Article XVII, § 1, which permits emergency legislation to ensure governmental continuity, asserting that the COVID-19 pandemic did not justify such measures since in-person voting remained available, and the Delaware Constitution already permits those sick or with physical disability to vote absentee - and the State previously announced that it would interpret this language to include any voter who has an at-risk condition or is caring for an at-risk person. The RCS claims that they and other Republican State Committee members will be irreparably harmed by HB 346 as the “vote by mail” system is rife with potential problems and pitfalls, as evidenced by the 5.2% rejection rate of ballots mailed in for the Delaware presidential primary and untimely delivery of ballots.

The Department of Elections maintained that HB 346 was a temporary, emergency measure necessary to protect public health and ensure election integrity during the pandemic. They contended that Article XVII, § 1 provided a constitutional basis for the law, as it allowed for legislative action to ensure the continuity of government in times of emergency. They stated that “due to the highly contagious nature of COVID–19 and the need to protect the electors and polling workers in this State from infection of COVID–19, voting by mail is necessary and proper for [e]nsuring the continuity of governmental operations, and to conform to the requirements of Article V, § 4A, would be impracticable.”

On September 28, 2020, Vice Chancellor Glasscock issued a Memorandum Opinion denying the RSC's request for injunctive relief. The court held that HB 346 was constitutionally valid under Article XVII, § 1, as the General Assembly had appropriately determined that expanded vote-by-mail was necessary to preserve government continuity during the public health crisis. The court further emphasized that legislation enjoys a presumption of constitutionality, and the RSC failed to provide clear and convincing evidence that HB 346 violated the Delaware Constitution.

As of the date of the decision, the case was concluded, with the court upholding HB 346 as a lawful emergency measure applicable only to the 2020 election cycle.

Summary Authors

Sierra Winokur (2/6/2025)

People


Judge(s)

Glasscock, Sam (Delaware)

Attorney for Plaintiff
Attorney for Defendant

Boyer, Matthew F (Delaware)

Broujos, Frank (Delaware)

Goldstein, Aaron R. (Delaware)

Hall, Trisha W (Delaware)

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Documents in the Clearinghouse

Document

Verified Complaint

Aug. 19, 2020

Aug. 19, 2020

Complaint

2020-0685-SG

Memorandum Opinion

Sept. 24, 2020

Sept. 24, 2020

Order/Opinion

Resources

Docket

Last updated March 10, 2024, 1:46 p.m.

ECF Number Description Date Link Date / Link
86463498

Complaint for Injunctive Relief and Declaratory Judgment

Aug. 19, 2020

Aug. 19, 2020

86463503

Plaintiffs' Motion to Expedite Proceedings

Aug. 19, 2020

Aug. 19, 2020

86463505

Exhibits A through G to Verified Complaint

Aug. 19, 2020

Aug. 19, 2020

86471244

Summons Instruction Letter to Issue Summons to Special Process Server Reliable Companies to Serve Defendants pursuant to 10 Del. C. § 3103(c) and Court of Chancery Rule 4

Aug. 20, 2020

Aug. 20, 2020

86471564

Issued one original and two copies of summonses pursuant to 10 Del. C. 3101(c). Sent via Fed Ex to Special Process Server, per Counsel's request.

Aug. 20, 2020

Aug. 20, 2020

86476096

Summons Directed to Defendants (pursuant to 10 Del. C. § 3103(c)) and Affidavit of Service by Special Process Server Reliable Companies of Summons, Verified Complaint, and Motion to Expedite

Aug. 21, 2020

Aug. 21, 2020

86502780

Letter to Counsel scheduling teleconference 9-2-20 at 10:00 a.m.

Aug. 28, 2020

Aug. 28, 2020

86517239

Order

Sept. 1, 2020

Sept. 1, 2020

86521968

Judicial Action Form completed by Juli LaBadia, Court Reporter. Motion to Expedite held telephonically on 9-2-20. Motion to expedite granted. Opening brief due 9-9-20. Answering brief due 9-16-20. Reply due 9-21-20. Hearing scheduled for 9-24-20 at 9:30 a.m. via Zoom. See transcript.

Sept. 2, 2020

Sept. 2, 2020

86522228

Letter from Julia B. Klein (DE 5198) Submitting Order Granting Plaintiffs' Motion to Expedite and Setting Oral Argument

Sept. 2, 2020

Sept. 2, 2020

86524355

Granted (Order [Proposed] Implementing the Court's Ruling on Plaintiff's Motion for Expedited Proceedings and Setting Oral Argument)

Sept. 2, 2020

Sept. 2, 2020

86524855

Entry of Appearance of Allison J. McCowan on behalf of Defendants State of Delaware, Department of Elections and Anthony J. Albence, State Election Commissioner

Sept. 3, 2020

Sept. 3, 2020

86547304

Please enter the appearance of Max B. Walton, Esq., Matthew F. Boyer, Esq., and Trisha W. Hall, Esq., of Connolly Gallagher LLP, on behalf of the Defendants as co-counsel with the Department of Justice, with Certificate of Service

Sept. 9, 2020

Sept. 9, 2020

86552219

Plaintiffs' Opening Brief in Support of their Motion for Summary Judgment

Sept. 10, 2020

Sept. 10, 2020

86553292

Defendants' Motion to Consolidate

Sept. 10, 2020

Sept. 10, 2020

86553988

Entry of Appearance of Frank N. Broujos and Ilona M. Kirshon on behalf of Defendants State of Delaware, Department of Elections and Anthony J, Albence

Sept. 10, 2020

Sept. 10, 2020

86557318

Letter to The Honorable Same Glasscock, III, from Max B. Walton, providing a letter outlining the briefing and argument dates per the Court's request

Sept. 11, 2020

Sept. 11, 2020

86562972

Judicial Action Form completed by Dennel Niezgoda, Court Reporter. Teleconference held 9-11-20 regarding logistics of Oral Argument via Zoom. Counsel agreed to use services of CourtScribes for upcoming oral argument. Coordination of testing will be done prior to proceeding.

Sept. 11, 2020

Sept. 11, 2020

86585173

Defendants' Answering Brief in Opposition to Plaintiffs' Motion for Summary Judgment, with Certificate of Service

Sept. 17, 2020

Sept. 17, 2020

86587101

Affidavit of Anthony J. Albence

Sept. 17, 2020

Sept. 17, 2020

86602673

Entry of Appearance of Attorney General Kathleen M. Jennings and State Solicitor Aaron R. Goldstein on behalf of Defendants State of Delaware Department of Elections and Anthony J. Albence with Certificate of Service.

Sept. 21, 2020

Sept. 21, 2020

86604374

Plaintiffs' Reply Brief in Further Support of their Motion for Summary Judgment

Sept. 22, 2020

Sept. 22, 2020

86610377

Defendants' Corrected Answering Brief in Opposition to Plaintiffs' Motion for Summary Judgment with Certificate of Service

Sept. 22, 2020

Sept. 22, 2020

86622447

Judicial Action Form completed by Debi Donnelly, Court Reporter. Oral Argument held 9-24-20 on Motion for Summary Judgment. Taken under advisement. See transcript.

Sept. 24, 2020

Sept. 24, 2020

86620710

Letter from Julia B. Klein (DE 5198) to the Honorable Sam Glasscock Regarding Clarification of Statement on the Record at September 24, 2020, Hearing

Sept. 25, 2020

Sept. 25, 2020

86623128

Letter to the Honorable Sam Glasscock, III from Allison J. McCowan, Deputy Attorney General regarding follow up information related to oral argument.

Sept. 25, 2020

Sept. 25, 2020

86635443

Opinion

Sept. 28, 2020

Sept. 28, 2020

86640159

Letter from Julia B. Klein (DE 5198) to the Honorable Sam Glasscock Enclosing Consensual Implementing Order

Sept. 30, 2020

Sept. 30, 2020

86644048

Granted (Enclosure to Letter from Julia B. Klein (DE 5198) to the Honorable Sam Glasscock Enclosing Consensual Implementing Order)

Sept. 30, 2020

Sept. 30, 2020

86552205

Plaintiffs' Motion for Summary Judgment

Oct. 15, 2020

Oct. 15, 2020

87012372

Letter to Counsel

Dec. 31, 2020

Dec. 31, 2020

Case Details

State / Territory: Delaware

Case Type(s):

Election/Voting Rights

Special Collection(s):

COVID-19 (novel coronavirus)

Healthy Elections COVID litigation tracker

Law Firm Antiracism Alliance (LFAA) project

Key Dates

Filing Date: Aug. 19, 2020

Closing Date: Sept. 29, 2020

Case Ongoing: No

Plaintiffs

Plaintiff Description:

The Republican State Committee of Delaware and two residents of Delaware who are registered to vote in the state of Delaware

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

State of Delaware, State

Delaware State Election Commissioner, State

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

State law

Available Documents:

Complaint (any)

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

Voting:

Election administration

Voting: General & Misc.

Voting: Physical/Effective Access