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Case: Dhillon v. Wobensmith

1:20-cv-02197 | U.S. District Court for the District of Maryland

Filed Date: July 28, 2020

Case Ongoing

Clearinghouse coding complete

Case Summary

This is a case challenging Maryland’s mayoral signature gathering requirements in light of COVID-19. On July 28th, 2020, a prospective, unaffiliated candidate for mayor of Baltimore filed this lawsuit in the United States District Court for the District of Maryland seeking to relax Maryland’s signature-gathering requirements for the upcoming November 2020 election.  Represented by private counsel, the prospective candidate sued the Secretary of State for Maryland under 42 U.S.C. § 1983 seeking …

This is a case challenging Maryland’s mayoral signature gathering requirements in light of COVID-19. On July 28th, 2020, a prospective, unaffiliated candidate for mayor of Baltimore filed this lawsuit in the United States District Court for the District of Maryland seeking to relax Maryland’s signature-gathering requirements for the upcoming November 2020 election.  Represented by private counsel, the prospective candidate sued the Secretary of State for Maryland under 42 U.S.C. § 1983 seeking a preliminary injunction allowing him to satisfy a lower burden (0.1% of the Baltimore City population, or about 400 signatures) than the current election laws permit (0.5% or about 2000 signatures), and an order that his name be placed on the ballot for the 2020 General Election. 

The prospective candidate was unsuccessful in his bid to get an injunction to change the signature requirements. The court denied his motion for preliminary injunction on July 31st, 2020. In a memorandum opinion, the court cited already relaxed requirements (i.e. changing the requirement from “wet” signatures to digital signatures in April 2020 and halving the total requirement from 1% to 0.5% in July 2020) as rationale for denying the injunction. On balance, the court concluded that further relaxing of the requirements would not benefit the public interest and that the plaintiff’s complaint was unlikely to succeed on the merits. 

After the injunction was denied, the plaintiff settled with the Secretary of State out of court in a private agreement. Despite the settlement agreement, the plaintiff did not appear on the November 2020 ballot.The case is now closed.

Summary Authors

Brendan Sullivan (2/13/2022)

People

For PACER's information on parties and their attrorneys, see: https://www.courtlistener.com/docket/17391039/parties/dhillon-v-wobensmith/


Judge(s)

Bennett, Richard D. (Maryland)

Attorneys(s) for Plaintiff

Chhabra, Mandeep S. (Maryland)

Greenberg, Lawrence S. (Maryland)

Attorneys(s) for Defendant

Trento, Andrea William (Maryland)

Judge(s)

Bennett, Richard D. (Maryland)

Attorneys(s) for Plaintiff

Chhabra, Mandeep S. (Maryland)

Greenberg, Lawrence S. (Maryland)

Attorneys(s) for Defendant

Trento, Andrea William (Maryland)

Documents in the Clearinghouse

Document

1:20-cv-02197

Docket [PACER]

Aug. 28, 2020

Aug. 28, 2020

Docket
1

1:20-cv-02197

Verified Complaint for Emergency Declaratory and Preliminary Injunctive Relief

July 28, 2020

July 28, 2020

Complaint
10

1:20-cv-02197

Memorandum Opinion

July 31, 2020

July 31, 2020

Order/Opinion
12

1:20-cv-02197

Settlement Order

Aug. 28, 2020

Aug. 28, 2020

Order/Opinion

Resources

Docket

See docket on RECAP: https://www.courtlistener.com/docket/17391039/dhillon-v-wobensmith/

Last updated Dec. 1, 2022, 3:14 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against All Defendants ( Filing fee $ 400 receipt number 0416-8778640.), filed by Kahan Dhillon. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit, # 3 Summons, # 4 Summons)(Greenberg, Lawrence) (Entered: 07/28/2020)

1 Civil Cover Sheet

View on PACER

2 Exhibit

View on PACER

3 Summons

View on PACER

4 Summons

View on PACER

July 28, 2020

July 28, 2020

Clearinghouse
2

Emergency MOTION for Preliminary Injunction by Kahan Dhillon (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order, # 3 Affidavit)(Greenberg, Lawrence) (Entered: 07/29/2020)

1 Memorandum in Support

View on RECAP

2 Text of Proposed Order

View on PACER

3 Affidavit

View on PACER

July 29, 2020

July 29, 2020

PACER
3

NOTICE of Appearance by Andrea William Trento on behalf of Linda H Lamone, John C Wobensmith (Trento, Andrea) (Entered: 07/29/2020)

July 29, 2020

July 29, 2020

PACER
4

ORDER confirming the results of the teleconference held on 7/29/2020. Signed by Judge Richard D. Bennett on 7/29/2020. (krs, Deputy Clerk) (Entered: 07/29/2020)

July 29, 2020

July 29, 2020

PACER
5

RESPONSE in Opposition re 2 Emergency MOTION for Preliminary Injunction filed by Linda H Lamone, John C Wobensmith.(Trento, Andrea) (Entered: 07/29/2020)

July 29, 2020

July 29, 2020

PACER

Case reassigned to Judge Richard D. Bennett. Judge Catherine C. Blake no longer assigned to the case. (cags, Deputy Clerk)

July 29, 2020

July 29, 2020

PACER
6

NOTICE of Appearance by Mandeep Singh Chhabra on behalf of Kahan Dhillon (Chhabra, Mandeep) (Entered: 07/30/2020)

July 30, 2020

July 30, 2020

PACER
7

REPLY to Response to Motion re 2 Emergency MOTION for Preliminary Injunction filed by Kahan Dhillon. (Attachments: # 1 Exhibit, # 2 Text of Proposed Order)(Greenberg, Lawrence) (Entered: 07/30/2020)

July 30, 2020

July 30, 2020

PACER
8

Summons Issued 21 days as to Linda H Lamone, John C Wobensmith.(krs, Deputy Clerk) (Entered: 07/30/2020)

July 30, 2020

July 30, 2020

PACER
9

Preliminary Injunction Hearing held on 7/30/2020 re 2 Emergency MOTION for Preliminary Injunction filed by Kahan S. Dhillon, Jr. before Judge Richard D. Bennett.(Court Reporter: Ronda Thomas) (J. Herndons, Deputy Clerk) (Entered: 07/31/2020)

July 30, 2020

July 30, 2020

PACER
10

MEMORANDUM OPINION. Signed by Judge Richard D. Bennett on 7/31/2020. (krs, Deputy Clerk) (Entered: 07/31/2020)

July 31, 2020

July 31, 2020

Clearinghouse
11

ORDER denying 2 Motion for Preliminary Injunction. Signed by Judge Richard D. Bennett on 7/31/2020. (krs, Deputy Clerk) (Entered: 07/31/2020)

July 31, 2020

July 31, 2020

PACER
12

ORDER DISMISSING case with each party to bear its own costs unless otherwise agreed without prejudice to the right of a party to move for good cause to reopen this action if settlement is not consummated. Signed by Judge Richard D. Bennett on 8/28/2020. (dass, Deputy Clerk) (Entered: 08/28/2020)

Aug. 28, 2020

Aug. 28, 2020

PACER

Case Details

State / Territory: Maryland

Case Type(s):

Election/Voting Rights

Special Collection(s):

COVID-19 (novel coronavirus)

Healthy Elections COVID litigation tracker

Key Dates

Filing Date: July 28, 2020

Closing Date: Aug. 28, 2020

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

Prospective Mayoral Candidate

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Secretary of State, State

Case Details

Causes of Action:

State law

Constitutional Clause(s):

Due Process: Procedural Due Process

Due Process: Substantive Due Process

Freedom of speech/association

Availably Documents:

Trial Court Docket

Complaint (any)

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Form of Settlement:

Private Settlement Agreement

Voluntary Dismissal

Order Duration: 2020 - 2020

Issues

General:

Voting

COVID-19:

Mitigation Requested

Voting:

Candidate qualifications

Election administration