Filed Date: June 3, 2021
Closed Date: July 13, 2025
Clearinghouse coding complete
In this case, Michigan voters alleged that the City of Hamtramck violated the Voting Rights Act Section 203’s bilingual language assistance requirements; the case was settled by consent decree shortly after the complaint was filed.
On June 3, 2021, a voters’ organization (Detroit Action) and a Bengali-speaking voter alleged that the City of Hamtramck had failed to provide Bengali-translated election materials and support for Bengali-speaking, Bangladeshi-American voters. Specifically, the complaint made § 1983 claims against state defendants (the City of Hamtramck, Office of the City Clerk, and the City Clerk in his/her official capacity), alleging the city had violated Section 203 of the Voting Rights Act between 2011 and 2020 because the city: (a) failed to provide “accurate” 2020 General Election sample ballots (claiming the ballots were in the incorrect dialect and contained misspellings); (b) provided incorrect Bengali instructions for straight-party voting; (c) failed to provide Bengali Democratic ballots at an election site between 7am to 6pm in the 2020 Primary Election; (d) failed to hire sufficient Bengali interpreters, resulting in numerous sites not having a Bengali-speaking interpreter able to assist voters; (e) failed to provide Bengali signage at and around polling places; and (f) failed to translate the Clerk’s website from English to Bengali (from April 2020 to May 2021).
According to the Complaint, Hamtramck was required to follow Section 203’s requirements since October 13, 2011, the date the Director of the Census Bureau designated Hamtramck as a covered jurisdiction for Bengali language assistance based on the 2010 census, and the infractions listed above violated those requirements.
The Complaint sought a declaration that Hamtramck had failed to provide election materials translated to Bengali, as required by Section 203. It further sought to enjoin the city from “failing to provide” translated voting materials or information and requiring the city to implement a remedial plan to ensure compliance with Section 203.
On July 13, 2021, a little more than a month after filing, United States District Judge Mark A. Goldsmith of the Eastern District of Michigan signed a Consent Decree, which closed the case subject to Court oversight. The Consent Decree did not contest the application of Section 203 to Hamtramck nor the underlying facts of the lawsuit. The Decree required Hamtramck to “provide in Bengali ‘registration or voting notices, forms, instructions, assistance or other materials or information relating to the electoral process’ that it provides in English, as required by Section 203 of the Voting Rights Act of 1965.” The city was required to provide this voting material in the “‘most widely used’ Bengali dialects,” which, at the time of the Decree, were Bangla/Shuddo. The city was also required to provide Bengali translations to its website, a sufficient number of trained Bengali-speaking personnel three weeks before and after an election, and Section 203 training to all poll workers. A Program Coordinator and Advisory Group were also created to help implement the Consent Decree. No paper is on the docket after this July 13, 2021 Consent Decree. By its terms, the Consent Decree expired July 13, 2025, four years after it was signed.
Summary Authors
LFAA (8/13/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/59959492/parties/detroit-action-v-city-of-hamtramck/
Goldsmith, Mark Allan (Michigan)
Lorenzo-Giguere, Susana (Michigan)
Prescott, Sarah (Michigan)
Vattamala, Jerry (Michigan)
See docket on RECAP: https://www.courtlistener.com/docket/59959492/detroit-action-v-city-of-hamtramck/
Last updated Aug. 16, 2025, 3:04 a.m.
State / Territory: Michigan
Case Type(s):
Special Collection(s):
Law Firm Antiracism Alliance (LFAA) project
Key Dates
Filing Date: June 3, 2021
Closing Date: July 13, 2025
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Voters organization (Detroit Action) and Bengali-speaking voter (Rahima Begum).
Plaintiff Type(s):
Non-profit NON-religious organization
Attorney Organizations:
Asian American Legal Defense & Educ. Fund (AALDEF)
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
City of Hamtramck (Hamtramck), City
City Clerk of Hamtramck (Hamtramck), City
Defendant Type(s):
Case Details
Causes of Action:
Ex parte Young (federal or state officials)
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Court Approved Settlement or Consent Decree
Content of Injunction:
Provide antidiscrimination training
Order Duration: 2021 - 2025
Issues
Discrimination Basis:
Affected Language(s):
Affected National Origin/Ethnicity(s):
Voting: