Filed Date: June 2, 2016
Closed Date: July 18, 2016
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This case concerns the constitutionality of the Democratic National Committee’s (DNC) use of unpledged delegates, or “superdelegates,” during the Democratic Party’s presidential nomination process.
On June 2, 2016, an individual plaintiff filed a lawsuit against the DNC and the New York State Democratic Committee in the U.S. District Court for the Southern District of New York. The plaintiff argued that the superdelegate system violated his First and Fourteenth Amendment rights by diluting the impact of his vote and constituted a breach of contract under New York law. He sought a preliminary injunction to prevent superdelegates from voting at the Democratic National Convention. However, on July 18, 2016, the court denied this motion, determining the plaintiff failed to show a likelihood of success on the merits of his claims.
Following this decision, the plaintiff amended his complaint twice, ultimately removing the New York State Democratic Committee as a defendant and focusing solely on the DNC. The Second Amended Complaint, filed on December 16, 2016, included various state-law claims and introduced a new federal common law “Democracy Tort.”
The DNC filed a motion to dismiss, which was granted on June 2, 2017. The court dismissed the case due to lack of subject matter jurisdiction, ruling there was no federal question or diversity jurisdiction. The court found the plaintiff’s request for $10,000,000 in punitive damages insufficient to meet the amount in controversy requirement and did not recognize the “Democracy Tort” under federal common law.
In its reasoning, the court noted that while the plaintiff had standing, he failed to demonstrate a likelihood of success on the merits of his First Amendment, Fourteenth Amendment, and breach of contract claims. The court emphasized the limitations of federal courts in adjudicating internal party procedures absent a clear federal issue. The case was ultimately dismissed for lack of subject matter jurisdiction.
Summary Authors
(8/5/2024)
Last updated Aug. 20, 2025, 5:39 p.m.
Docket sheet not available via the Clearinghouse.State / Territory: New York
Case Type(s):
Special Collection(s):
Law Firm Antiracism Alliance (LFAA) project
Key Dates
Filing Date: June 2, 2016
Closing Date: July 18, 2016
Case Ongoing: No reason to think so
Plaintiffs
Plaintiff Description:
A New York resident and a member of the Democratic Party.
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
DEMOCRATIC NATIONAL COMMITTEE, Federal
New York State Democratic Committee, State
Defendant Type(s):
Case Details
Causes of Action:
Voting Rights Act, unspecified, 52 U.S.C. § 10301 et seq (previously 42 U.S.C § 1973 et seq.)
Constitutional Clause(s):
Available Documents:
Outcome
Prevailing Party: Defendant
Nature of Relief:
Source of Relief:
Amount Defendant Pays: 0
Issues
Voting: