Filed Date: Nov. 26, 2019
Closed Date: April 27, 2020
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This case is about a constitutional challenge to a Minnesota election law, Minnesota Election Code § 207A.13, subd. 2(a), that provides that candidates seeking the 2020 Republican presidential nomination could only appear on Minnesota's primary election ballot if the candidate was selected by the party and the chair of the party submitted the candidate's name to the secretary of state no later than 63 days before the presidential nomination primary. On November 26, 2019, a member of the Republican Party and declared candidate for the 2020 presidential nomination of the Republican National Convention filed this lawsuit in the United States District Court for the District of Minnesota. The plaintiff sued Steve Simon in his official capacity as the Secretary of State of Minnesota under 42 U.S.C. § 1983. Represented by private counsel, the plaintiff sought declaratory and injunctive relief against the defendant's continued enforcement of the election law. He claimed that the election law impermissibly imposed an additional qualification on him as a candidate, as he was otherwise qualified to appear on Minnesota's 2020 Republican presidential primary election ballot. The case was assigned to Senior Judge David S. Doty.
In his complaint, the plaintiff alleged that presidential Qualifications Clause of Article II, Section 1, Clause 5 of the United States Constitution provides the exclusive list of qualifications for an individual to be eligible to seek the Office of President of the United States, and therefore, the only qualifications for presidency are being a natural born citizen or a citizen of the United States, at least thirty-five years old, and a resident within the United States for at least fourteen years. The plaintiff met these constitutional requirements. The plaintiff alleged that the State of Minnesota did not have authority to impose additional requirements on eligible citizens, such as himself, to hold the Office of President and thus Minnesota Election Code § 207A.13, subd. 2(a) was unconstitutional. Specifically, the plaintiff argued that the challenged statute's language that "[e]ach party must determine which candidates are to be placed on the presidential nomination primary ballot for that party" and "[t]he chair of each party must submit to the secretary of state the names of the candidates to appear on the ballot for that party no later than 63 days before the presidential nomination primary" added an additional requirement that went against the exclusive list detailed in the Constitution. The plaintiff's name was not provided by the Minnesota Republican Party for inclusion on the 2020 Minnesota Republican presidential election ballot, and therefore, he was not set to appear on the 2020 primary ballot. In October 2019, the Republican Party of Minnesota submitted its authorized list of candidates for the 2020 presidential nomination primary in a letter to the defendant and the sole candidate listed was Donald Trump. According to the plaintiff, the challenged statute’s only purpose was to prevent otherwise eligible citizens from being able to compete for the Office of President in their party’s primary election who are not provided permission by a small group of party officials. Accordingly, the plaintiff sought declaratory and injunctive relief against the defendant's continued enforcement of Minnesota Election Code § 207A.13, subd. 2(a) because of its alleged imposition of an additional qualification on the plaintiff's presidential candidacy. He also alleged that the law violated his First Amendment right to freedom of association.
On December 23, 2019, the defendant filed a motion to dismiss the plaintiff's complaint, and a hearing date was set for March 6, 2020. The date of the hearing was then moved to March 24, 2020. Despite the fact that Minnesota’s presidential primary was set to occur on March 3, 2020, the plaintiff did not request an earlier hearing date.
Meanwhile, in December, the plaintiff and a Minnesota resident who claimed he desired to vote for the plaintiff in the primary filed a ballot-error petition in the Minnesota Supreme Court, listing the defendant in this action as the respondent. The petition repeated the constitutional claims alleged in this lawsuit and asked the state court to order the plaintiff's name be placed on the Republican primary ballot. On January 9, 2020, the Minnesota Supreme Court ruled against the plaintiff on the merits and denied the petition.
Shortly thereafter, on January 24, 2020, the defendant filed a memorandum of law in support of his motion to dismiss the plaintiff's complaint. First, he argued that the because the Minnesota Supreme Court rejected the plaintiff's claims on the merits, res judicata barred the plaintiff from now proceeding with the claims in a different forum. Second, the defendant argued that the candidate restrictions imposed by the statute passed constitutional muster because they were reasonable, nondiscriminatory, and justified by an important regulatory interest of the state. Specifically, the defendant argued as follows: (1) that the restrictions were reasonable because they did not bar the plaintiff from running for President or prevent any eligible individual from voting for him; (2) that they were nondiscriminatory because they granted each political party the authority to determine the list of candidates it agrees to associate with for the purposes of a presidential nomination primary, and (3) that the restrictions were precisely tailored to serve the state’s compelling interest in protecting the parties’ right to free association. Finally, the defendant argued that the state’s need to both protect that right and avoid “laundry list” ballots constituted an important regulatory interest.
On March 3, 2020, the plaintiff filed his memorandum in partial opposition to the defendant's motion to dismiss. The plaintiff first conceded that the claims in his complaint had been rendered moot. On February 2, 2020, the plaintiff announced that he would stand as an independent candidate for the office of President of the United States and would therefore petition to secure access to the state general election ballots for the 2020 presidential election. Furthermore, on that same date, the 2020 Minnesota presidential primary election took place with the ballot having been printed in January. Accordingly, the plaintiff admitted in his brief that the claims raised in his complaint had been rendered moot and should be dismissed without prejudice. However, the plaintiff requested the court's permission to permit him to file an amended complaint. Specifically, he sought to amend his complaint to challenge an entirely different part of the Minnesota Election Code for an entirely different reason: the plaintiff intended to challenge the state residency requirement on presidential electors as a violation of the United State Constitution. On March 10, 2020, the defendant filed a reply brief in support of his motion to dismiss. In this brief, the defendant first agreed with the plaintiff that his case was moot. In addition, the defendant argued that the plaintiff should not be granted leave to amend his complaint, pointing to the prejudice to the defendant and the fact that the amended complaint that plaintiff sought would involve entirely new legal claims directed at a different Minnesota statute, which would simply be a brand-new pleading initiating an unrelated lawsuit.
On April 24, 2020, the court dismissed the plaintiff's complaint with prejudice and denied his request for leave to amend. The court agreed that the plaintiff's claim in his complaint was moot. The court also agreed with the defendant that the plaintiff did not seek to amend his complaint so much as he sought to commence an entirely different new lawsuit against the defendant. For this reason, the request for leave to amend was denied; however, the court held that the plaintiff was not precluded from asserting these new claims in a new lawsuit. This case is now closed.
Summary Authors
(11/12/2024)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/16527523/parties/de-la-fuente-v-simon/
Doty, David Singleton (Minnesota)
Kaardal, Erick G (Minnesota)
Rossi, Paul A (Minnesota)
Hartshorn, Nathan J (Minnesota)
See docket on RECAP: https://www.courtlistener.com/docket/16527523/de-la-fuente-v-simon/
Last updated Nov. 12, 2024, 11:12 a.m.
State / Territory: Minnesota
Case Type(s):
Special Collection(s):
Law Firm Antiracism Alliance (LFAA) project
Key Dates
Filing Date: Nov. 26, 2019
Closing Date: April 27, 2020
Case Ongoing: No
Plaintiffs
Plaintiff Description:
A registered voter and a member of the Republican Party that was a declared candidate for the 2020 presidential nomination of the Republican National Convention.
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Minnesota Secretary of State, State
Defendant Type(s):
Case Details
Causes of Action:
Ex parte Young (federal or state officials)
Constitutional Clause(s):
Available Documents:
Outcome
Prevailing Party: Defendant
Nature of Relief:
Source of Relief:
Issues
Voting: