Case: Baten v. Mcmaster

2:18-cv-00510 | U.S. District Court for the District of South Carolina

Filed Date: Feb. 21, 2018

Closed Date: Sept. 9, 2020

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Case Summary

This is a case challenging the state of South Carolina's process of awarding electoral votes. On February 21, 2018, six voters who had previously supported Democratic candidates brought a lawsuit challenging South Carolina's winner-take-all system ("WTA"), where the state allocated all its electoral votes in the Electoral College to whichever candidate received the most votes. Plaintiffs sued the Governor of the State of South Carolina, Secretary of State of the State of South Carolina, the Sou…

This is a case challenging the state of South Carolina's process of awarding electoral votes.

On February 21, 2018, six voters who had previously supported Democratic candidates brought a lawsuit challenging South Carolina's winner-take-all system ("WTA"), where the state allocated all its electoral votes in the Electoral College to whichever candidate received the most votes. Plaintiffs sued the Governor of the State of South Carolina, Secretary of State of the State of South Carolina, the South Carolina Election Commission, Chair of the Election Commission, and several members of the Election Commission. Since 1980, the South Carolina has allocated all of its electoral votes to candidates from the Republican party. The plaintiffs argued that the WTA system violated the Fourteenth Amendment’s Equal Protection Clause by diluting the votes of the political minority during the selection of electors. They claimed that discarding their ballots at the second, elector-based round of voting undermined the “one person, one vote” principle. They also contended that the system ran counter to the First and Fourteenth Amendments by burdening their freedom of association. Additionally, three of the plaintiffs, who were African American, claimed that the system violated Section 2 of the Voting Rights Act by preventing African American voters from having their preferred candidate represented in electoral votes. The case was assigned to Judge Honorable David C Norton.

On May 3, 2018, the defendants filed a motion to dismiss for failure to state a claim. 

On March 8, 2019, the District Court for the District of South Carolina dismissed all three claims. On the equal protection claim, the court relied on the Supreme Court’s summary affirmance of Williams v. Virginia State Board of Elections to conclude that there was no violation because the system did not unfairly elevate one person’s vote over another. Regarding the freedom of association claim, the court found that the plaintiffs’ argument conflated diminishing motivation to participate with a severe burden on the actual ability of people to participate in the voting process. The court also dismissed the Voting Rights Act claim, stating that the WTA system did not prevent Democratic voters, including African Americans, from participating equally in the political process.

On March 18, 2019, plaintiffs appealed the dismissal to the Fourth Circuit.

On September 9, 2020, the Fourth Circuit affirmed the district court’s dismissal of the challenge to South Carolina’s WTA system, exposing a settled doctrinal landscape in defense of the WTA approach. The decision suggested that efforts seeking WTA reform should focus on state-level political action rather than federal litigation.

The case is now closed. 

Summary Authors

Jiabao Xu (4/25/2024)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/6313416/parties/baten-v-mcmaster/


Judge(s)
Attorney for Plaintiff

Allen, Randall L (South Carolina)

Harpootlian, Richard A (South Carolina)

Johnson, Cassandra K (South Carolina)

Attorney for Defendant

Crum, Mary Elizabeth (South Carolina)

Hunter, Thomas Parkin (South Carolina)

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Documents in the Clearinghouse

Document
1

2:18-cv-00510

Complaint for Declaratory and Injunctive Relief

Feb. 21, 2018

Feb. 21, 2018

Complaint
14

2:18-cv-00510

Governor McMaster's Motion to Dismiss Plaintiffs' Complaint

May 3, 2018

May 3, 2018

Pleading / Motion / Brief
17

2:18-cv-00510

Motion to Dismiss

May 3, 2018

May 3, 2018

Pleading / Motion / Brief
37

2:18-cv-00510

Order

March 8, 2019

March 8, 2019

Order/Opinion

374 F.Supp.3d 563

42

2:18-cv-00510

Opinion

U.S. Court of Appeals for the Fourth Circuit

July 21, 2020

July 21, 2020

Order/Opinion

967 F.3d 345

44

2:18-cv-00510

Amended Opinion

U.S. Court of Appeals for the Fourth Circuit

July 27, 2020

July 27, 2020

Order/Opinion

967 F.3d 345

45

2:18-cv-00510

Order

U.S. Court of Appeals for the Fourth Circuit

Sept. 1, 2020

Sept. 1, 2020

Order/Opinion

2020 U.S.App.LEXIS 27880

Docket

See docket on RECAP: https://www.courtlistener.com/docket/6313416/baten-v-mcmaster/

Last updated Jan. 30, 2025, 3:25 p.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against Mark Benson, Marilyn Bower, E. Allen Dawson, Mark Hammond, Henry McMaster, South Carolina Election Commission, The, Billy Way, Jr, Nicole Spain White ( Filing fee $ 400 receipt number 0420-7624616.), filed by Charlette Plummer-Wooley, Eugene Baten, Chester Willis, Cory C Alpert, Benjamin Horne, Bakari Sellers. Service due by 5/22/2018. (egra, ) (Entered: 02/22/2018)

Feb. 21, 2018

Feb. 21, 2018

Clearinghouse
2

Summons Issued as to Mark Benson, Marilyn Bower, E. Allen Dawson, Mark Hammond, Henry McMaster, South Carolina Election Commission, The, Billy Way, Jr, Nicole Spain White. (Attachments: # 1 Exhibit Attachment to Summons) (egra, ) (Entered: 02/22/2018)

1 Exhibit Attachment to Summons

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Feb. 21, 2018

Feb. 21, 2018

PACER
4

Local Rule 26.01 Answers to Interrogatories by Cory C Alpert, Eugene Baten, Benjamin Horne, Charlette Plummer-Wooley, Bakari Sellers, Chester Willis. (egra, ) (Entered: 02/22/2018)

Feb. 21, 2018

Feb. 21, 2018

PACER
5

ACCEPTANCE OF SERVICE OF COMPLAINT by Charlette Plummer-Wooley, Eugene Baten, Chester Willis, Cory C Alpert, Benjamin Horne, Bakari Sellers. Henry McMaster served on 3/8/2018, answer due 3/29/2018. (Attachments: # 1 Exhibit A - Notice of Filing Acceptance of Service for Defendant Henry McMaster, in his official capacity as Governor of the State of South Carolina)(Kenney, Christopher) (Entered: 03/09/2018)

March 9, 2018

March 9, 2018

PACER
6

SUMMONS Returned Executed by Charlette Plummer-Wooley, Eugene Baten, Chester Willis, Cory C Alpert, Benjamin Horne, Bakari Sellers. Marilyn Bower served on 3/10/2018, answer due 4/2/2018; Mark Hammond served on 3/8/2018, answer due 3/29/2018; South Carolina Election Commission, The served on 3/8/2018, answer due 3/29/2018; Billy Way, Jr served on 3/8/2018, answer due 3/29/2018; Nicole Spain White served on 3/8/2018, answer due 3/29/2018. (Attachments: # 1 Exhibit A - Affidavit of Service of Marilyn Bower, in her official capacity as a Commission Member of the Election Commission, # 2 Exhibit B - Affidavit of Service of Mark Hammond, in his official capacity as Secretary of State of the State of South Carolina, # 3 Exhibit C - Affidavit of Service of Nicole Spain White, in her official capacity as Commission Member of the Election Commission, # 4 Exhibit D - Affidavit of Service of the South Carolina Election Commission, # 5 Exhibit E - Affidavit of Service of Billy Way, in his official capacity as a Chair of the Election Commission)(Kenney, Christopher) (Entered: 03/15/2018)

March 15, 2018

March 15, 2018

PACER
7

ACCEPTANCE OF SERVICE OF COMPLAINT by Charlette Plummer-Wooley, Eugene Baten, Chester Willis, Cory C Alpert, Benjamin Horne, Bakari Sellers. Mark Benson served on 3/17/2018, answer due 4/9/2018; E. Allen Dawson served on 3/16/2018, answer due 4/6/2018. (Attachments: # 1 Exhibit A - Affidavit of Service of E. Allen Dawson, in his official capacity as Commission Member of the Election Commission, # 2 Exhibit B -Affidavit of Service of Mark Benson, in his official capacity as Commission Member of the Election Commission)(Kenney, Christopher) (Entered: 03/21/2018)

March 21, 2018

March 21, 2018

PACER
8

NOTICE of Appearance by Thomas Ashley Limehouse, Jr on behalf of Henry McMaster (Limehouse, Thomas) (Entered: 04/16/2018)

April 16, 2018

April 16, 2018

PACER
9

Local Rule 26.01 Answers to Interrogatories by Henry McMaster.(Limehouse, Thomas) (Entered: 04/16/2018)

April 16, 2018

April 16, 2018

PACER
10

Consent MOTION for Extension of Time to Answer or Otherwise Respond to Plaintiffs' Complaint by Henry McMaster. Response to Motion due by 4/30/2018. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. Proposed order is being emailed to chambers with copy to opposing counsel.(Limehouse, Thomas) (Entered: 04/16/2018)

April 16, 2018

April 16, 2018

PACER
11

ORDER granting 10 Motion for Extension of Time. It is hereby ordered that the deadline by which Governor McMaster and Secretary Hammond must answer or otherwise respond to Plaintiffs Complaint is extended until May 3, 2018. Signed by Honorable Patrick Michael Duffy on 04/17/2018. (egra, ) (Entered: 04/17/2018)

April 17, 2018

April 17, 2018

PACER
12

ANSWER to 1 Complaint, by Mark Benson, Marilyn Bower, E. Allen Dawson, South Carolina Election Commission, The, Billy Way, Jr, Nicole Spain White.(Trinkley, Jane) (Entered: 04/18/2018)

April 18, 2018

April 18, 2018

PACER
13

Local Rule 26.01 Answers to Interrogatories by Mark Benson, Marilyn Bower, E. Allen Dawson, South Carolina Election Commission, The, Billy Way, Jr, Nicole Spain White.(Trinkley, Jane) (Entered: 04/18/2018)

April 18, 2018

April 18, 2018

PACER
14

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Henry McMaster. Response to Motion due by 5/17/2018. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: # 1 Memo in Support)No proposed order.(Limehouse, Thomas) Modified on 12/11/2018 to create linkage to 35 Supplement filed 12/10/2018 (jbry, ). Modified on 3/1/2019 to create linkage to 36 Supplement filed 2/28/2019 (jbry, ). (Entered: 05/03/2018)

1 Memo in Support

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May 3, 2018

May 3, 2018

Clearinghouse
15

NOTICE of Appearance by Karl S Bowers, Jr on behalf of Mark Hammond (Bowers, Karl) (Entered: 05/03/2018)

May 3, 2018

May 3, 2018

PACER
16

Local Rule 26.01 Answers to Interrogatories by Mark Hammond.(Bowers, Karl) (Entered: 05/03/2018)

May 3, 2018

May 3, 2018

PACER
17

MOTION to Dismiss by Mark Hammond. Response to Motion due by 5/17/2018. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. No proposed order.(Bowers, Karl) (Entered: 05/03/2018)

May 3, 2018

May 3, 2018

Clearinghouse
18

Consent MOTION to Appear Pro Hac Vice by Cassandra Kerkhoff Johnson ( Filing fee $ 250 receipt number 0420-7762880) by Cory C Alpert, Eugene Baten, Benjamin Horne, Charlette Plummer-Wooley, Bakari Sellers, Chester Willis. Response to Motion due by 5/18/2018. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: # 1 Exhibit A - Application/Affidavit for Pro Hac Vice Admission for Cassandra Kerkhoff Johnson)No proposed order.(Harpootlian, Richard) (Entered: 05/04/2018)

May 4, 2018

May 4, 2018

PACER
19

Consent MOTION to Appear Pro Hac Vice by Randall L. Allen ( Filing fee $ 250 receipt number 0420-7762902) by Cory C Alpert, Eugene Baten, Benjamin Horne, Charlette Plummer-Wooley, Bakari Sellers, Chester Willis. Response to Motion due by 5/18/2018. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. (Attachments: # 1 Exhibit A - Affidavit/Application for Pro Hac Vice Admission for Randall L. Allen)No proposed order.(Harpootlian, Richard) (Entered: 05/04/2018)

May 4, 2018

May 4, 2018

PACER
20

ORDER granting 19 Motion to Appear Pro Hac Vice by Randall L. Allen, Esquire. Signed by Honorable Patrick Michael Duffy on 5/7/18.(chub, ) (Entered: 05/07/2018)

May 7, 2018

May 7, 2018

PACER
21

ORDER granting 18 Motion to Appear Pro Hac Vice by Cassandra Kerkhoff Johnson, Esquire. Signed by Honorable Patrick Michael Duffy on 5/7/18.(chub, ) (Main Document 21 replaced on 5/8/2018) (egra, ). Modified on 5/8/2018 to replace with corrected order (egra, ). (Entered: 05/07/2018)

May 7, 2018

May 7, 2018

PACER
22

Consent MOTION for Extension of Time to File Response/Reply as to 14 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 17 MOTION to Dismiss by Cory C Alpert, Eugene Baten, Benjamin Horne, Charlette Plummer-Wooley, Bakari Sellers, Chester Willis. Response to Motion due by 5/29/2018. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. No proposed order.(Kenney, Christopher) (Entered: 05/14/2018)

May 14, 2018

May 14, 2018

PACER
23

ORDER granting 22 Motion for Extension of Time to File Response/Reply as to 14 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 17 MOTION to Dismiss. Response to Motion due by 5/31/2018. Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6 or Fed. R. Crim. P. 45. Signed by Honorable Patrick Michael Duffy on 05/14/2018. (egra, ) (Entered: 05/14/2018)

May 14, 2018

May 14, 2018

PACER
24

RESPONSE in Opposition re 14 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 17 MOTION to Dismiss Response filed by Cory C Alpert, Eugene Baten, Benjamin Horne, Charlette Plummer-Wooley, Bakari Sellers, Chester Willis.Reply to Response to Motion due by 6/7/2018 Add an additional 3 days only if served by mail or otherwise allowed under Fed. R. Civ. P. 6. (Attachments: # 1 Exhibit Ex. A - Plaintiffs Br. Before Hrg Upon the Merits, Williams v. Virginia State Board of Elections, C.A. No. 4768-A (E.D. Va. May 24, 1968), # 2 Exhibit Ex. B - Unpublished case law)(Harpootlian, Richard) (Entered: 05/31/2018)

1 Exhibit Ex. A - Plaintiffs Br. Before Hrg Upon the Merits, Williams v. Virginia

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2 Exhibit Ex. B - Unpublished case law

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May 31, 2018

May 31, 2018

PACER
25

SUPPLEMENT by Cory C Alpert, Eugene Baten, Benjamin Horne, Charlette Plummer-Wooley, Bakari Sellers, Chester Willis . (Attachments: # 1 Exhibit A - Supplemental Authority)(Kenney, Christopher) (Entered: 09/07/2018)

Sept. 7, 2018

Sept. 7, 2018

PACER
26

Case Reassigned to Judge Honorable David C Norton. Judge Honorable Patrick Michael Duffy no longer assigned to the case. (cwil, ) (Entered: 09/10/2018)

Sept. 10, 2018

Sept. 10, 2018

PACER
27

NOTICE of Hearing on Motions 17 MOTION to Dismiss, 14 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM : Motion Hearing set for Thursday, 11/1/2018 at 11:30 AM in Hon. Sol Blatt, Jr., Courtroom, J. Waties Waring Judicial Cntr, 83 Meeting St, Charleston before Honorable David C Norton. (jbry, ) (Entered: 10/10/2018)

Oct. 10, 2018

Oct. 10, 2018

PACER
28

SUPPLEMENT by Cory C Alpert, Eugene Baten, Benjamin Horne, Charlette Plummer-Wooley, Bakari Sellers, Chester Willis . (Attachments: # 1 Exhibit A - Order re: Defendants' Motion to Dismiss in Rodriguez v. Brown)(Kenney, Christopher) (Entered: 10/22/2018)

Oct. 22, 2018

Oct. 22, 2018

PACER
31

Minute Entry. Proceedings held before Honorable David C Norton: Motion Hearing held on 11/1/2018 re 14 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Henry McMaster, 17 MOTION to Dismiss filed by Mark Hammond. The Court will issue an order. Court Reporter Debbie Potocki. (cmur, ) (Entered: 11/01/2018)

Nov. 1, 2018

Nov. 1, 2018

PACER
32

NOTICE of Appearance by James Emory Smith, Jr on behalf of Mark Benson, Marilyn Bower, E. Allen Dawson, South Carolina Election Commission, The, Billy Way, Jr, Nicole Spain White (Smith, James) (Entered: 11/16/2018)

Nov. 16, 2018

Nov. 16, 2018

PACER
33

NOTICE of Appearance by Thomas Parkin C Hunter on behalf of Mark Benson, Marilyn Bower, South Carolina Election Commission, The, Billy Way, Jr, Nicole Spain White (Hunter, Thomas) (Main Document 33 replaced on 11/20/2018) (jbry, ). Modified on 11/20/2018 to replace incorrect document with corrected document as provided by filing user(jbry, ). (Entered: 11/19/2018)

Nov. 19, 2018

Nov. 19, 2018

PACER
34

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of motion hearing held on 11-1-18, before Judge David C. Norton. Court Reporter/Transcriber Debra Potocki, Telephone number/E-mail potockidebra@bellsouth.net. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Parties have 7 calendar days from the filing of the transcript to file with the court a Notice of Intent to Request Redaction.. Redaction Request due 12/19/2018. Redacted Transcript Deadline set for 12/31/2018. Release of Transcript Restriction set for 2/26/2019. (dpotocki, ) (Entered: 11/28/2018)

Nov. 28, 2018

Nov. 28, 2018

PACER
35

SUPPLEMENT by Henry McMaster to 14 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM . (Attachments: # 1 Exhibit A - Memorandum and Order - Lyman v. Baker, # 2 Exhibit B - Order of Dismissal - Lyman v. Baker)(Limehouse, Thomas) (Entered: 12/10/2018)

Dec. 10, 2018

Dec. 10, 2018

PACER
36

SUPPLEMENT by Henry McMaster to 14 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM . (Attachments: # 1 Exhibit Exhibit A - Order - LULAC v. Abbott)(Limehouse, Thomas) (Entered: 02/28/2019)

Feb. 28, 2019

Feb. 28, 2019

PACER
37

ORDER granting 14 Motion to Dismiss for Failure to State a Claim; granting 17 Motion to Dismiss Signed by Honorable David C Norton on March 8, 2019.(cban, ) (Entered: 03/08/2019)

March 8, 2019

March 8, 2019

Clearinghouse
38

JUDGMENT in favor of South Carolina Election Commission, The, Billy Way, Jr, E. Allen Dawson, Henry McMaster, Marilyn Bower, Mark Benson, Mark Hammond, Nicole Spain White against Bakari Sellers, Benjamin Horne, Charlette Plummer-Wooley, Chester Willis, Cory C Alpert, Eugene Baten (jbry, ) (Entered: 03/11/2019)

March 11, 2019

March 11, 2019

Clearinghouse
39

NOTICE OF APPEAL as to 37 Order on Motion to Dismiss for Failure to State a Claim, 38 Judgment, by Cory C Alpert, Eugene Baten, Benjamin Horne, Charlette Plummer-Wooley, Bakari Sellers, Chester Willis. - Filing fee $ 505, receipt number 0420-8331355. The Docketing Statement form, Transcript Order form and CJA 24 form may be obtained from the Fourth Circuit website at www.ca4.uscourts.gov (Harpootlian, Richard) (Entered: 03/18/2019)

March 18, 2019

March 18, 2019

PACER
40

Transmittal Sheet for Notice of Appeal to USCA re 39 Notice of Appeal, The Clerk's Office hereby certifies the record and the docket sheet available through ECF to be the certified list in lieu of the record and/or the certified copy of the docket entries. (jbry, ) (Entered: 03/19/2019)

March 19, 2019

March 19, 2019

PACER
42

USCA OPINION for 39 Notice of Appeal, filed by Eugene Baten, Charlette Plummer-Wooley, Benjamin Horne, Cory C Alpert, Bakari Sellers, Chester Willis. Decision of Appeals Court Affirming by published opinion the Decision of District Court. (jbry, ) (Entered: 07/21/2020)

July 21, 2020

July 21, 2020

Clearinghouse
43

AMENDING ORDER of USCA as to 39 Notice of Appeal, filed by Eugene Baten, Charlette Plummer-Wooley, Benjamin Horne, Cory C Alpert, Bakari Sellers, Chester Willis (jbry, ) (Entered: 07/27/2020)

July 27, 2020

July 27, 2020

PACER
44

USCA AMENDED OPINION for 39 Notice of Appeal, filed by Eugene Baten, Charlette Plummer-Wooley, Benjamin Horne, Cory C Alpert, Bakari Sellers, Chester Willis. Decision of Appeals Court Affirming by published opinion Decision of District Court. (jbry, ) (Entered: 07/27/2020)

July 27, 2020

July 27, 2020

Clearinghouse
45

ORDER of USCA as to 39 Notice of Appeal, filed by Eugene Baten, Charlette Plummer-Wooley, Benjamin Horne, Cory C Alpert, Bakari Sellers, Chester Willis. The court denies the petition for rehearing en banc. (jbry, ) (Entered: 09/03/2020)

Sept. 1, 2020

Sept. 1, 2020

Clearinghouse
46

USCA MANDATE and JUDGMENT as to 39 Notice of Appeal, filed by Eugene Baten, Charlette Plummer-Wooley, Benjamin Horne, Cory C Alpert, Bakari Sellers, Chester Willis (Attachments: # 1 Judgment)(jbry, ) (Entered: 09/09/2020)

1 Judgment

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Sept. 9, 2020

Sept. 9, 2020

PACER

Case Details

State / Territory: South Carolina

Case Type(s):

Election/Voting Rights

Special Collection(s):

Law Firm Antiracism Alliance (LFAA) project

Key Dates

Filing Date: Feb. 21, 2018

Closing Date: Sept. 9, 2020

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Minority voters

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Governor of the State of South Carolina, State

Secretary of State of South Carolina, State

South Carolina Election Commission (Columbia, Richland), State

Chair of Election Commission (Columbia, Richland), State

Commission Members of Election Commission (Columbia, Richland), State

Defendant Type(s):

Jurisdiction-wide

Facility Type(s):

Government-run

Case Details

Causes of Action:

Voting Rights Act, section 2, 52 U.S.C. § 10301 (previously 42 U.S.C. § 1973)

Constitutional Clause(s):

Due Process

Due Process: Substantive Due Process

Freedom of speech/association

Equal Protection

Available Documents:

Trial Court Docket

Complaint (any)

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Amount Defendant Pays: 0

Order Duration: 2019 - 2020

Issues

Voting:

Vote decision rules

Vote dilution