Filed Date: Dec. 7, 2016
Closed Date: May 26, 2017
Clearinghouse coding complete
This case is about the certification requirements for California’s presidential electors. The plaintiff was an independent candidate for President of the United States in the 2016 general election. On October 25, 2016, the California Secretary of State’s office notified him that they would not certify his slate of presidential electors because the listed addresses for seven of the electors could not be matched to the addresses recorded on their voter registration applications. As a result, California did not tabulate write-in votes cast for the plaintiff.
On December 17, 2016, the plaintiff filed this lawsuit in the U.S. District Court for the Eastern District of California. He sued the California Secretary of State under 42 U.S.C. § 1983. He alleged the Secretary of State selectively refused to certify his slate of electors while ignoring defects with the slates of electors filed by other political parties, in violation of the Equal Protection Clause of the Fourteenth Amendment to the U.S. Constitution. the plaintiff sought an order enjoining the Secretary of State from certifying California’s 2016 general election results without tabulating the write-in votes for his presidential candidacy, a declaration that the Secretary of State violated the Fourteenth Amendment, and attorneys’ fees. The case was assigned to District Judge John A. Mendez.
On February 2, 2017, the plaintiff filed an amended complaint alleging the defendant’s actions also violated the U.S. Constitution’s “Elector Qualification Clause,” U.S. Const. art. II, § 8, cl. 2. The plaintiff argued that the Constitution provides the exclusive list of requirements for presidential electors and that the Secretary of State cannot impose any additional requirements.
On March 27, 2017, the Secretary of State moved to dismiss the Equal Protection claim because it had already been raised and decided in another case filed by the plaintiff in California state court. On April 18, 2017, the plaintiff filed a reply arguing the previous state court case was not a final adjudication on the merits and that the current claim sought a remedy based on new facts.
On May 2, 2017, the court denied the Secretary of State’s motion to dismiss but asked for additional briefing from the parties on whether the plaintiff had standing to pursue his claims. During the briefing on that issue, the plaintiff did not oppose the dismissal of his Equal Protection claim on standing grounds, nor did he address his standing for the “Elector Qualification Clause” claim. Accordingly, on May 16, 2017, the court dismissed the complaint without prejudice.
Summary Authors
John McGinnis (7/17/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/13410626/parties/de-la-fuente-v-padilla/
Mendez, John A. (California)
PHV, Paul Anthony (California)
Scudi, Morgan J.C. (California)
Eisenberg, Jonathan Michael (California)
Medley, Amie Leann (California)
See docket on RECAP: https://www.courtlistener.com/docket/13410626/de-la-fuente-v-padilla/
Last updated March 26, 2026, 4:46 a.m.
State / Territory:
Case Type(s):
Special Collection(s):
Law Firm Antiracism Alliance (LFAA) project
Key Dates
Filing Date: Dec. 7, 2016
Closing Date: May 26, 2017
Case Ongoing: No
Plaintiffs
Plaintiff Description:
An independent candidate for President of the United States in the 2016 general election
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
State
California Secretary of State
Defendant Type(s):
Case Details
Causes of Action:
Constitutional Clause(s):
Other Dockets:
Eastern District of California 2:16-cv-02877
Available Documents:
Outcome
Prevailing Party: Defendant
Relief Granted:
Source of Relief:
Issues
Voting:
Case Summary of De La Fuente v. Padilla, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/44926/ (last updated 7/17/2025).