Filed Date: Oct. 31, 2016
Closed Date: Feb. 3, 2017
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This case involved allegations from the Plaintiff, the Public Interest Legal Foundation Inc. (“PILF”) that the Defendant, the General Registrar for the City of Manassas (“GR”), failed to maintain accurate voter rolls and failed to provide access to public records, resulting in the inclusion of ineligible voters and violation of transparency requirements under the National Voter Registration Act of 1993 (“NVRA”).
Plaintiff filed a lawsuit in the U.S. District Court Eastern District of Virginia on October 31, 2016. Plaintiff cited the National Voter Registration Act of 1993 (“NVRA”), 52 U.S.C. § 20507 and cited related cases Lake v. Neal, 585 F.3d 1059 (7th Cir. 2009), Davis v. Freedom of Information Commission, 259 Conn. 45 (2002). Defendant cited the Driver Privacy Protection Act of 1994 (“DPPA”). The case was assigned initially to Judge Gerald Bruce Lee and later Judge Claude M. Hilton.
Plaintiff had two key allegations. First, that defendant had failed to maintain accurate voter rolls, resulting in the inclusion of ineligible voters. The categories of ineligible voters included deceased individuals; non-residents; and duplicate registrations. Second, defendant had failed to provide access to public records, resulting in the violation of the NVRA’s transparency requirements, that were put in place to verify the accuracy and integrity of voter rolls. Plaintiff sought declaratory and injunctive relief to force the defendant’s compliance with Section 8 NVRA (administrative requirements of the State).
Defendant filed a motion to dismiss on November 25, 2026, on the grounds that the privacy provision of the DPPA, 18 U.S.C. §§ 2721-2725, overrides the public disclosure provision of the NVRA under the circumstance of this case. Defendant argued actions were in compliance with law and noncitizen cancellation reports derived from the DPPA, which prohibits disclosure of such reports as they do not fall under the category of list maintenance documents. Additionally, defendant argued cases cited by plaintiff were not binding upon the Court and were distinguishable. Defendant argued that in Lake v. Neal, the case concerned a voter registration form and not a noncitizen cancellation form, that have different disclosure requirements under the Virginia Code. Similarly in Davis v. Freedom of Information Commission, defendant argued the case does not relate to disclosure of citizenship data.
Plaintiff submitted their opposition to GR’s motion to dismiss on December 6, 2016 and the Court denied defendant's motion to dismiss on January 27, 2017, finding that the DPPA does not apply to the disclosure of the voter information requested by Plaintiff. Case was dismissed on February 3, 2017 pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure, as all claims in the action had been resolved by private settlement and the parties requested the case be dismissed, with each party bearing its own costs and attorneys’ fees.
Summary Authors
(6/6/2024)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/13369855/parties/the-public-interest-legal-foundation-v-reed/
Hilton, Claude M. (Virginia)
Hilton, Claude M. (Virginia)
Lee, Gerald Bruce (Virginia)
Adams, John Christian (Virginia)
Hilton, Claude M.
See docket on RECAP: https://www.courtlistener.com/docket/13369855/the-public-interest-legal-foundation-v-reed/
Last updated Oct. 28, 2025, 6:14 p.m.
State / Territory:
Case Type(s):
Special Collection(s):
Law Firm Antiracism Alliance (LFAA) project
Key Dates
Filing Date: Oct. 31, 2016
Closing Date: Feb. 3, 2017
Case Ongoing: No
Plaintiffs
Plaintiff Description:
The Public Interest Legal Foundation Inc. - a U.S. non-profit legal organization that focuses on election integrity and the enforcement of election laws.
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Susan Reed, General Registrar for the City of Manassas (City of Manassa, Alexandria), City
Facility Type(s):
Case Details
Causes of Action:
Other Dockets:
Eastern District of Virginia 1:16-cv-01375
Available Documents:
Outcome
Prevailing Party: Mixed
Nature of Relief:
Source of Relief:
Form of Settlement:
Content of Injunction:
Amount Defendant Pays: Each party to pay own fees
Issues
Voting: