Case: Libertarian Party of Mississipi v. Wetzel

1:24-cv-00037 | U.S. District Court for the Southern District of Mississippi

Filed Date: Feb. 5, 2024

Case Ongoing

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Case Summary

This case challenged the legality of Mississippi’s absentee-balloting procedures, specifically the state’s “Ballot Receipt Deadline” statute that extended the deadline for receipt of absentee ballots by five business days past election day, so that ballots postmarked on or before the date of election and received by the registrar no more than five business days after the election would be counted.  On February 5, 2024, the Libertarian Party of Mississippi (LPMS) filed a complaint in the United …

This case challenged the legality of Mississippi’s absentee-balloting procedures, specifically the state’s “Ballot Receipt Deadline” statute that extended the deadline for receipt of absentee ballots by five business days past election day, so that ballots postmarked on or before the date of election and received by the registrar no more than five business days after the election would be counted. 

On February 5, 2024, the Libertarian Party of Mississippi (LPMS) filed a complaint in the United States District Court for the Southern District of Mississippi against the Harrison County Clerk and Registrar, five members of the Harrison County Election Commission, and the Mississippi Secretary of State. LPMS alleged that Mississippi’s absentee ballot receipt deadline, codified in Mississippi Code § 23-15-637(1)(a), violated federal law because it extended the deadline for receipt of absentee ballots by five business days after Election Day. The plaintiff asserted that the five-day extension conflicted with the uniform federal Election Day established by Congress under 2 U.S.C. §§ 1, 7, and 3 U.S.C. § 1. The complaint further contended that the Electoral Count Reform Act (ECRA), which revised the process of casting and counting electoral votes for presidential elections, permitted such extensions only in cases of "force majeure events that are extraordinary and catastrophic," none of which occurred for the November 5, 2024, federal election, and therefore that use of the five-day extension in that election violated federal law. The plaintiff argued that Mississippi’s extended deadline unlawfully diluted the votes of timely voters, disproportionately harmed minor political parties like the LPMS, and imposed unnecessary financial burdens on candidates monitoring post-election canvassing, ultimately undermining the integrity of federal elections. LPMS claimed violations of the First and Fourteenth Amendments, the Elections Clause (Art. I, § 4, cl. 1), and the Electors Clause (Art. II, § 1, cl. 4), and sought declaratory and injunctive relief, including a permanent injunction barring enforcement of the extension statute, temporary relief pending litigation, and an award of costs and attorneys’ fees.  The case was originally assigned to District Judge Taylor B. McNeel, but on February 8, 2024, Judge McNeel recused himself from the case, which was reassigned to District Judge Louis Guiola, Jr. 

On March 1, 2024, the court consolidated this action with a similar lawsuit filed by the Republican National Committee (RNC), the Mississippi Republican Party, James "Pete" Perry, and Matthew Lamb (Republican National Committee v. Wetzel, Case No. 1:24-cv-00025), designating the RNC lawsuit as the lead case. Consequently, on July 29, 2024, the court ordered that this consolidated case be dismissed with prejudice. Developments in the consolidated action are summarized here.

Summary Authors

Madeline Dollard (6/19/2026)

Related Cases

Republican National Committee v. Wetzel, Southern District of Mississippi (2024)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/68223690/parties/libertarian-party-of-mississippi-v-wetzel/


Judge(s)

Guirola, Louis (Mississippi)

Attorney for Plaintiff

Nobile, T. Russell (Mississippi)

Attorney for Defendant

Gov, Rex M. (Mississippi)

Holleman, Tim C. (Mississippi)

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Documents in the Clearinghouse

Document
1

1:24-cv-00037

Complaint

Feb. 5, 2024

Feb. 5, 2024

19

1:24-cv-00037

Judgment

July 29, 2024

July 29, 2024

Docket

See docket on RECAP: https://www.courtlistener.com/docket/68223690/libertarian-party-of-mississippi-v-wetzel/

Last updated June 26, 2026, 3:52 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against Christene Brice, Toni Jo Diaz, Carolyn Handler, Barbara Kimball, Becky Payne, Michael Watson, Justin Wetzel ( Filing fee $ 405 receipt number 5328122), filed by Libertarian Party of Mississippi. (Attachments: # 1 Civil Cover Sheet)(wld) (Entered: 02/05/2024)

1 Civil Cover Sheet

View on RECAP

Feb. 5, 2024

Feb. 5, 2024

Clearinghouse
2

Summons Issued as to Christene Brice, Toni Jo Diaz, Carolyn Handler, Barbara Kimball, Becky Payne, Michael Watson, Justin Wetzel. (wld) (Entered: 02/05/2024)

Feb. 5, 2024

Feb. 5, 2024

3

ORDER OF RECUSAL. District Judge Taylor B. McNeel recused. Case reassigned to District Judge Louis Guirola, Jr. for all further proceedings Signed by District Judge Taylor B. McNeel on 2/8/2024 (wld) (Entered: 02/08/2024)

Feb. 8, 2024

Feb. 8, 2024

RECAP
4

**ERROR**Disregard this entry. SUMMONS Returned Executed by Libertarian Party of Mississippi. All Defendants. (Nobile, T. Russell) Modified on 2/8/2024 (RLW). (Entered: 02/08/2024)

Feb. 8, 2024

Feb. 8, 2024

Remark

Feb. 8, 2024

Feb. 8, 2024

Counsel should use the newly assigned Judge's initials on future filings. 1:24cv37LG-RPM. (wld)

Feb. 8, 2024

Feb. 8, 2024

Docket Annotation

Feb. 8, 2024

Feb. 8, 2024

DOCKET ANNOTATION as to #4: Advising attorney that the summonses returned executed were filed incorrect. All the summonses should not have been scanned in together as one pdf document, and All Defendants should not have been selected. Also, some defendants were served on different days. Each summons should have been scanned and docketed separately in order for the answer due date to be set. This entry will be disregarded. Attorney is advised to re-file each summons separately, enter service date, and set the answer due date if prompted. (RLW)

Feb. 8, 2024

Feb. 8, 2024

5

Unopposed MOTION to Exempt Defendant from Filing Answer to Plaintiff's Complaint to Accommodate Parties' Anticipated Filing of Early Cross-Motions for Summary Judgment by Michael Watson (Shannon, III-State Gov, Rex) (Entered: 02/16/2024)

Feb. 16, 2024

Feb. 16, 2024

RECAP
6

SUMMONS Returned Executed by Libertarian Party of Mississippi. (Nobile, T. Russell) (Entered: 02/16/2024)

Feb. 16, 2024

Feb. 16, 2024

RECAP
7

SUMMONS Returned Executed by Libertarian Party of Mississippi. (Nobile, T. Russell) (Entered: 02/16/2024)

Feb. 16, 2024

Feb. 16, 2024

RECAP
8

SUMMONS Returned Executed by Libertarian Party of Mississippi. (Nobile, T. Russell) (Entered: 02/16/2024)

Feb. 16, 2024

Feb. 16, 2024

9

SUMMONS Returned Executed by Libertarian Party of Mississippi. (Nobile, T. Russell) (Entered: 02/16/2024)

Feb. 16, 2024

Feb. 16, 2024

10

SUMMONS Returned Executed by Libertarian Party of Mississippi. (Nobile, T. Russell) (Entered: 02/16/2024)

Feb. 16, 2024

Feb. 16, 2024

11

SUMMONS Returned Executed by Libertarian Party of Mississippi. (Nobile, T. Russell) (Entered: 02/16/2024)

Feb. 16, 2024

Feb. 16, 2024

12

SUMMONS Returned Executed by Libertarian Party of Mississippi. Michael Watson served on 2/9/2024, answer due 3/1/2024. (Nobile, T. Russell) (Entered: 02/16/2024)

Feb. 16, 2024

Feb. 16, 2024

13

NOTICE of Appearance by Tim C. Holleman on behalf of Christene Brice, Toni Jo Diaz, Carolyn Handler, Barbara Kimball, Becky Payne, Justin Wetzel (Holleman, Tim) (Entered: 02/22/2024)

Feb. 22, 2024

Feb. 22, 2024

14

Joinder in Document by Christene Brice, Toni Jo Diaz, Carolyn Handler, Barbara Kimball, Becky Payne, Justin Wetzel to 5 Unopposed MOTION to Exempt Defendant from Filing Answer to Plaintiff's Complaint to Accommodate Parties' Anticipated Filing of Early Cross-Motions for Summary Judgment filed by Michael Watson (Holleman, Tim) (Entered: 02/22/2024)

Feb. 22, 2024

Feb. 22, 2024

15

ORDER granting 5 Motion to Exempt Defendant from Filing Answer to Plaintiff's Complaint to Accommodate Parties' Anticipated Filing of Early Cross-Motions for Summary Judgment. Signed by District Judge Louis Guirola, Jr., on 2/23/2024. (BR) (Entered: 02/23/2024)

Feb. 23, 2024

Feb. 23, 2024

RECAP

Docket Annotation

Feb. 23, 2024

Feb. 23, 2024

DOCKET ANNOTATION as to #13 and #14: Attorney is advised to include the correct district judge assignment of LG on future filed pleadings. This case was reassigned to Judge Guirola on 2/8/24. (RLW)

Feb. 23, 2024

Feb. 23, 2024

16

Unopposed MOTION for Extension of Time to File Answer re 1 Complaint, by Christene Brice, Toni Jo Diaz, Carolyn Handler, Barbara Kimball, Becky Payne, Justin Wetzel (Holleman, Tim) (Entered: 02/26/2024)

Feb. 26, 2024

Feb. 26, 2024

Order on Motion for Extension of Time to Answer

Feb. 26, 2024

Feb. 26, 2024

TEXT ONLY ORDER granting 16 Motion to Exempt Defendants from Filing Answer to 1 Complaint . JUSTIN WETZEL, in his official capacity as the clerk and registrar of the Circuit Court of Harrison County, and TONI JO DIAZ, BECKY PAYNE, BARBARA KIMBALL, CHRISTENE BRICE, and CAROLYN HANDLER, in their official capacities as members of the Harrison County Election Commission are exempted from filing an answer or other response to Plaintiffs 1 Complaint by February 26, 2024, or otherwise, subject to further order of this Court regarding the prospective entry of a briefing schedule on the parties anticipated cross-motions for summary judgment. NO FURTHER WRITTEN ORDER WILL ISSUE FROM THE COURT. Signed by District Judge Louis Guirola, Jr., on 2/26/2024. (BR)

Feb. 26, 2024

Feb. 26, 2024

Docket Annotation

Feb. 27, 2024

Feb. 27, 2024

DOCKET ANNOTATION as to #16: Incorrect event chosen. The event code, Miscellaneous Relief should have been selected. Attorney is not required to re-file. Motion has been ruled on. (RLW)

Feb. 27, 2024

Feb. 27, 2024

17

ORDER CONSOLIDATING CASES: Republican National Committee, et al. v. Justin Wetzel, et al., 1:24cv25-LG-RPM, and Libertarian Party of Mississippi v. Justin Wetzel, et al., 1:24cv37-LG-RPM, are consolidated for all purposes, with Republican National Committee v. Justin Wetzel, et al., 1:24cv25-LG-RPM, serving as the lead case. All subsequent motions, notices, and pleadings shall be filed in the lead case only. See Order for more details. Signed by District Judge Louis Guirola, Jr. on 3/1/24 (RLW). (Entered: 03/01/2024)

March 1, 2024

March 1, 2024

18

**ERROR**Disregard this entry. ANSWER to [] Complaint, by Christene Brice, Toni Jo Diaz, Carolyn Handler, Barbara Kimball, Becky Payne, Justin Wetzel. (Holleman, Tim) Modified on 3/15/2024 to remove relationship to document #1 (RLW). (Entered: 03/14/2024)

March 14, 2024

March 14, 2024

Docket Annotation

March 15, 2024

March 15, 2024

DOCKET ANNOTATION as to #18: Pursuant to consolidation order 17, all filings should now be made in the Lead Case No. 1:24cv25 LG-RPM. This docket entry will be disregarded. (RLW)

March 15, 2024

March 15, 2024

19

FINAL JUDGMENT: Ordered that these consolidated cases are dismissed with prejudice. Signed by District Judge Louis Guirola, Jr on 7/28/24. (JCH) (Entered: 07/29/2024)

July 29, 2024

July 29, 2024

Clearinghouse

Case Stayed

April 18, 2025

April 18, 2025

Case Details

State / Territory:

Mississippi

Case Type(s):

Election/Voting Rights

Special Collection(s):

Trump Administration 2.0: Litigation and Investigations By the Government

Key Dates

Filing Date: Feb. 5, 2024

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

The Libertarian Party of Mississippi (LPMS)

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

County

Harrison County Clerk and Registrar Mississippi

Members of Harrison County Election Commission

State

Mississippi Secretary of State

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Equal Protection

Freedom of speech/association

Other Dockets:

Southern District of Mississippi 1:24-cv-00037

Available Documents:

Any published opinion

Complaint (any)

Trial Court Docket

Outcome

Prevailing Party: None Yet / None

Relief Sought:

Injunction

Relief Granted:

None yet

Source of Relief:

None yet

Issues

Voting:

Election administration

Recommended Citation