Case: Constitution Party of North Carolina v. Strach

3:18-cv-00006 | U.S. District Court for the Western District of North Carolina

Filed Date: Jan. 3, 2018

Closed Date: Aug. 28, 2018

Clearinghouse coding complete

Case Summary

This case is about the Constitution Party of North Carolina’s ability to be recognized as a political party for the 2018 general election and defendant's placement of limitations on Constitution Party of North Carolina’s ability to accept supporters' contributions and on its supporters giving donations and contributions. Constitution Party of North Carolina alleged that the limitations on donor contributions, as set by the defendant, severely burdened its efforts to satisfy the requirements to …

This case is about the Constitution Party of North Carolina’s ability to be recognized as a political party for the 2018 general election and defendant's placement of limitations on Constitution Party of North Carolina’s ability to accept supporters' contributions and on its supporters giving donations and contributions. Constitution Party of North Carolina alleged that the limitations on donor contributions, as set by the defendant, severely burdened its efforts to satisfy the requirements to be recognized as a political party pursuant to NCGS §163A-950.

On January 3, 2018, the plaintiff filed a lawsuit in the U.S. District Court for the Western District of North Carolina against the Executive Director of the North Carolina State Board of Elections and Ethics Enforcement. The plaintiff claimed that defendant Strach’s limitations on plaintiff accepting contributions and in plaintiff’s supporters in giving donations and contributions severely burdened plaintiff’s efforts to satisfy the requirements of NCGS §163A-950 because in order to satisfy the number of signatures required to be gathered by statute is rarely successful unless the plaintiff employed a professional organization to help gather signatures, which is a costly endeavor. Furthermore, plaintiff alleged that its inability to raise adequate funds to conduct a successful petition signature collection effort constructively denies plaintiff the ability to become a recognized political party by satisfying the requirements of NCGS §163A-950. Represented by private counsel, the plaintiff sought a declaratory judgment declaring its rights and enjoining the enforcement of NCGS §163A-950 and reasonable attorneys’ fees and costs. The case was assigned to Judge Graham C. Mullen. 

On June 19, 2018, the defendant filed a motion to dismiss the matter pursuant to Rule 12(b)(1) and (h)(3) or to grant judgment on the pleadings pursuant to Rule 12(c) for lack of subject matter jurisdiction. Additionally, the defendant asserted that plaintiff’s claims are moot because plaintiff is recognized as one of North Carolina’s official political parties pursuant to NCGS §163A-950. The defendant also filed a motion to stay the matter pending the Court’s resolution of its jurisdiction.

On June 22, 2018, the court ordered the matter to be stayed, excepting the deadlines for filing responses to defendant’s motion to dismiss.

On August 28, 2018, the court ordered that defendant’s motion to dismiss be granted. The court held that plaintiff’s alleged injury was moot, as it successfully petitioned for political party recognition and was no longer subject to the contribution and receipt limitations. Moreover, plaintiff failed to establish an exception to the ripeness rule. 

This case is closed.

Summary Authors

Leilani Argersinger (4/12/2024)

Madilynn O'Hara (8/21/2024)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/6285720/parties/constitution-party-of-north-carolina-v-strach/


Judge(s)

Mullen, Graham Calder (North Carolina)

Attorney for Plaintiff

Henkle, S. Mark (North Carolina)

Attorney for Defendant

Jr, James Bernier (North Carolina)

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Documents in the Clearinghouse

Document
1

3:18-cv-00006

Complaint

Jan. 3, 2018

Jan. 3, 2018

Complaint

2018 WL 4101516

9

3:18-cv-00006

Motion to Dismiss (Fed. R. Civ. P. 12(b)(1), (c), (h)(3))

June 19, 2018

June 19, 2018

Pleading / Motion / Brief
11

3:18-cv-00006

Defendant's Motion to Stay Proceedings

June 19, 2018

June 19, 2018

Pleading / Motion / Brief
12

3:18-cv-00006

Order

June 22, 2018

June 22, 2018

Order/Opinion
15

3:18-cv-00006

Order

Aug. 28, 2018

Aug. 28, 2018

Order/Opinion

2018 WL 4101516

16

3:18-cv-00006

Judgment in Case

Aug. 28, 2018

Aug. 28, 2018

Order/Opinion

Docket

See docket on RECAP: https://www.courtlistener.com/docket/6285720/constitution-party-of-north-carolina-v-strach/

Last updated Aug. 8, 2025, 7:37 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against Kim Westbrook Strach ( Filing fee $ 400 receipt number 0419-3554398), filed by Constitution Party of North Carolina.(Henkle, S. Mark) (Entered: 01/03/2018)

Jan. 3, 2018

Jan. 3, 2018

Clearinghouse

Case Assigned/Reassigned

Jan. 3, 2018

Jan. 3, 2018

PACER

Case assigned to Senior Judge Graham Mullen. Notice: You must click this link to retrieve the Case Assignment Packet. This is your only notice - you will not receive a separate document.(brl)

Jan. 3, 2018

Jan. 3, 2018

PACER
2

Summons Issued Electronically as to Kim Westbrook Strach. NOTICE: Counsel shall print the summons and serve with other case opening documents in accordance with Fed.R.Civ.P.4 . (brl) (Entered: 01/03/2018)

Jan. 3, 2018

Jan. 3, 2018

PACER
3

MOTION for Extension of Time to Answer re: 1 Complaint by Kim Westbrook Strach. (Attachments: # 1 Proposed Order)(Bernier, James) (Entered: 01/24/2018)

Jan. 24, 2018

Jan. 24, 2018

PACER
4

NOTICE of Appearance by James Bernier, Jr on behalf of Kim Westbrook Strach (Bernier, James) (Entered: 01/24/2018)

Jan. 24, 2018

Jan. 24, 2018

PACER
5

ORDER Granting 3 Motion for Extension of Time to Answer re: 1 Complaint . Kim Westbrook Strach answer due 2/28/2018. Signed by Senior Judge Graham Mullen on 1/24/2018. (jaw) (Entered: 01/24/2018)

Jan. 24, 2018

Jan. 24, 2018

PACER
6

ANSWER to 1 Complaint by Kim Westbrook Strach.(Bernier, James) (Entered: 02/27/2018)

Feb. 27, 2018

Feb. 27, 2018

PACER

NOTICE pursuant to Local Rule 16.1 you are required to conduct an Initial Attorney's Conference within 14 days. At the conference, the parties are required to discuss the issue of consent to jurisdiction of a magistrate judge in accordance with Local Rules 16.1(A) and 73.1(C). The Certificate of Initial Attorneys Conference, and if applicable, the Joint Stipulation of Consent to Exercise jurisdiction by a US Magistrate Judge, should be filed within 7 days of the conference. If appropriate, a party may file a Motion to Stay the Initial Attorney's Conference. CIAC Report due by 3/21/2018. (brl)

Feb. 28, 2018

Feb. 28, 2018

PACER

Notice to Conduct Initial Attorneys Conference

Feb. 28, 2018

Feb. 28, 2018

PACER
7

CERTIFICATION of initial attorney conference and discovery plan (Henkle, S. Mark) (Entered: 03/21/2018)

March 21, 2018

March 21, 2018

PACER
8

Pretrial Order and Case Management Plan : Estimated Trial Time: one (1) - two (2) days. Discovery due by 8/17/2018. Motions due by 9/17/2018. Bench Trial set for 1/22/2019 10:00 AM in Courtroom 2-2, 401 W Trade St, Charlotte, NC 28202 before Senior Judge Graham Mullen. Signed by Senior Judge Graham Mullen on 3/23/2018. (jaw) (Entered: 03/26/2018)

March 26, 2018

March 26, 2018

PACER
9

MOTION to Dismiss for Lack of Jurisdiction by Kim Westbrook Strach. Responses due by 7/3/2018 plus an additional 3 days if served by mail (Bernier, James) (Entered: 06/19/2018)

June 19, 2018

June 19, 2018

Clearinghouse
10

MEMORANDUM in Support re 9 MOTION to Dismiss for Lack of Jurisdiction by Kim Westbrook Strach. (Attachments: # 1 Appendix, # 2 Exhibit 1, # 3 Exhibit 2)(Bernier, James) (Entered: 06/19/2018)

June 19, 2018

June 19, 2018

PACER
11

MOTION to Stay by Kim Westbrook Strach. Responses due by 7/3/2018 plus an additional 3 days if served by mail (Bernier, James) (Entered: 06/19/2018)

June 19, 2018

June 19, 2018

Clearinghouse
12

ORDER Granting 11 Motion to Stay. This matter is stayed, excepting the deadlines for filing responses to Defendants Motion to Dismiss, until the Motion to Dismiss has been resolved. Signed by Senior Judge Graham Mullen on 6/22/2018. (jaw) (Entered: 06/22/2018)

June 22, 2018

June 22, 2018

Clearinghouse
13

RESPONSE in Opposition re 9 MOTION to Dismiss for Lack of Jurisdiction by Constitution Party of North Carolina. Replies due by 7/10/2018 plus an additional 3 days if served by mail (Attachments: # 1 Appendix, # 2 Exhibit Exhibit 1, # 3 Exhibit Exhibit 2)(Henkle, S. Mark) (Entered: 07/03/2018)

July 3, 2018

July 3, 2018

PACER
14

REPLY to Response to Motion re 9 MOTION to Dismiss for Lack of Jurisdiction by Kim Westbrook Strach. (Bernier, James) (Entered: 07/10/2018)

July 10, 2018

July 10, 2018

PACER
15

ORDER Granting 9 Defendant's Motion to Dismiss for Lack of Jurisdiction. Signed by Senior Judge Graham Mullen on 8/28/2018. (jaw)

Aug. 28, 2018

Aug. 28, 2018

RECAP
16

CLERK'S JUDGMENT is hereby entered in accordance with the Court's Order dated 8/28/2018. Signed by Clerk, Frank G. Johns. (jaw)

Aug. 28, 2018

Aug. 28, 2018

RECAP

Case Details

State / Territory: North Carolina

Case Type(s):

Election/Voting Rights

Special Collection(s):

Law Firm Antiracism Alliance (LFAA) project

Key Dates

Filing Date: Jan. 3, 2018

Closing Date: Aug. 28, 2018

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Constitution Party of North Carolina

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

North Carolina State Board of Elections and Ethics Enforcement, State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Freedom of speech/association

Available Documents:

Trial Court Docket

Complaint (any)

Non-settlement Outcome

Outcome

Prevailing Party: Defendant

Nature of Relief:

Attorneys fees

Source of Relief:

Litigation

Issues

Voting:

Voting: General & Misc.