Filed Date: Oct. 12, 2016
Closed Date: Oct. 18, 2016
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This case involved requiring the State of Georgia to extend the voter registration deadline in Chatham County ahead of the November 8, 2016 general election due to the state of emergency caused by Hurricane Matthew.
On October 12, 2016, the Georgia Coalition for the Peoples’ Agenda, Inc., the George State Conference of the NAACP and Third Sector Development Inc. filed this lawsuit in the United States District Court for the Southern District of Georgia. The plaintiffs sued the Governor of Georgia and the Secretary of State of Georgia under Section 8 of the National Voter Registration Act of 1993, 52 U.S.C. § 20507 and the 1st and 14th Amendments of the United States Constitution. The plaintiffs were represented by private counsel at Bryan Cave LLP and public interest lawyers at the Lawyers’ Committee for Civil Rights Under Law. The judge was District Judge William T. Moore, Jr.
The voter registration deadline for Georgia for the general election on November 8, 2016 was October 11, 2016. Hurricane Matthew hit Chatham County on Friday October 7, 2016 and caused massive damage, substantial flooding, and loss of power to more than a hundred thousand county residents. The Governor of the State of George declared a state of emergency and issued a mandatory evacuation order. The Chatham County Board of Elections office was closed from October 6 to October 12, 2016. Moreover, post office closures and the suspension of mail service during this period potentially prevented individuals from submitting their registration applications. Finally, many individuals were potentially unable to register, either in person or electronically, due to evacuation or recovery efforts. Many prospective voters thus lost the ability to register to vote during the last six days of the voter registration period.
The Lawyer’s Committee for Civil Rights under Law sent a letter to Georgia Attorney General and General Counsel for the Georgia Secretary of State on October 11, 2016 requesting that the voter registration deadline be extended to allow county residents an opportunity to participate in the electoral process. The request was declined, citing that extending the deadline would not be appropriate because opportunities to register remained available and also that the county needed to prepare for early voting beginning on Monday October 17.
The plaintiffs sought a declaratory judgment that the defendant’s refusal to extend the voter registration deadline (a) violates the fundamental right to vote under the First and Fourteenth Amendments; and (b) violates Section 8 of the National Voter Registration Act of 1993, 52 U.S.C. § 20507 (which requires states to process any voter registration form received or postmarked at least 30 days prior to an election). The plaintiffs also filed a motion for a preliminary injunction requiring the defendants to extend the voter registration deadline in Chatham County to October 18, 2016.
The Court heard oral arguments from the parties on October 14, 2016. The defendants contended that extending the deadline to October 18, 2016 would present significant administrative burdens on the Chatham County Board of Elections because early voting will have already begun on October 17 and if voter registrations were extended until October 18 then the Board will have insufficient time to prepare and begin early voting. Defendants also argued that the impacts of Hurricane Matthew did not preclude individuals from registering electronically.
The court concluded that the plaintiffs had established a sufficient likelihood of success on the merits to warrant injunctive relief. The court reasoned that an individual’s ability to participate in elections was arguably the most cherished right in the United States Constitution and that the administrative hurdles cited by the defendant were not enough to warrant denying an extension of the registration deadline. In an Order dated October 14, 2016, the court granted the plaintiff’s motion for preliminary injunction and defendants were directed to extend the voter registration deadline for Chatham County from October 11, 2016 to October 18, 2016.
Defendants directed the Chatham County Board of Registrars to comply with the Order the day it was issued. Between October 12 and 18, 2016, the Chatham County Board of Registrars received 1,418 voter registration applications. Of the 1,418 voter registration applicants, 1,293 (91.2%) were placed into “active” status and were eligible to vote in Chatham County in the election held on November 8, 2016.
As of March 15, 2017, the case was dismissed with prejudice, after the parties had jointly stipulated that the case be dismissed with prejudice.
Summary Authors
(9/12/2024)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4505778/parties/georgia-coalition-for-the-peoples-agenda-inc-v-deal/
Custer, William V. (Georgia)
Houk, Julie M. (Georgia)
Anderson, Julia B. (Georgia)
Correia, Cristina Maria (Georgia)
Heidt, Josiah Benjamin (Georgia)
See docket on RECAP: https://www.courtlistener.com/docket/4505778/georgia-coalition-for-the-peoples-agenda-inc-v-deal/
Last updated Aug. 20, 2025, 9:04 p.m.
State / Territory: Georgia
Case Type(s):
Special Collection(s):
Law Firm Antiracism Alliance (LFAA) project
Key Dates
Filing Date: Oct. 12, 2016
Closing Date: Oct. 18, 2016
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Georgia Coalition for the Peoples' Agenda, Inc., as an organization; Georgia State Conference of the NAACP, as an organization; and Third Sector Development, Inc., as an organization
Plaintiff Type(s):
Non-profit NON-religious organization
Attorney Organizations:
Lawyers Comm. for Civil Rights Under Law
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
State of Georgia (Chatham), State
Defendant Type(s):
Case Details
Causes of Action:
Declaratory Judgment Act, 28 U.S.C. § 2201
Constitutional Clause(s):
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Preliminary injunction / Temp. restraining order
Source of Relief:
Form of Settlement:
Court Approved Settlement or Consent Decree
Content of Injunction:
Order Duration: 2016 - 2016
Issues
Voting: