United States Student Ass'n Foundation v. Land

VINSON, District Judge,

dissenting.

I respectfully dissent. I believe it is important to emphasize preliminarily that the issue raised in this case — involving the same Michigan practice, the same Michigan statute, and the same provision of the National Voter Registration Act (“NVRA”) — was litigated and decided against the plaintiffs almost thirteen years ago. Specifically, the plaintiffs argued in Association of Community Organizations for Reform Now (“ACORN”) v. Miller, 912 F.Supp. 976 (W.D.Mich.1995), as plaintiffs do here, that Michigan’s voter identification card statute [Mich. Comp. Laws § 168.500c] violated the NVRA because it authorized removal of registered voters from the official voter rolls in a manner other than those specified in 42 U.S.C. § 1973gg-6(d). In a well-reasoned opinion, the district court in Miller rejected the view that an applicant is automatically registered to vote for purposes of the NVRA merely upon filling out the registration application and being placed on the official roll. Id. at 986-87. Rather, the court explained that section 168.500c “clearly provides that an applicant is not registered until he or she receives a voter identification card.” Id. at 986. Because an applicant is not registered to vote under state law unless and until he or she receives the card, there was no conflict between the two statutes because “under the NVRA the states are still left the task of determining that an applicant is eligible, and that the registration form as submitted complies with state law.” Id. at 987. The decision in Miller was later affirmed *390by this Court, albeit without discussion of that particular holding. See ACORN v. Miller, 129 F.3d 833 (6th Cir.1997).1 Therefore, I cannot agree with the majority that the plaintiffs have a substantial likelihood of success on the merits.

The district judge in this case acknowledged the existence of Miller, but he disagreed with the earlier decision because, ultimately, he found that: “What the state may not do and still act consistently with the NVRA is to place a potential voter’s name on the [Qualified Voter File] in a status that permits the registrant to vote, only to later mark the registration as ‘rejected’ at a later date.” See District Court Order at 19-20. In other words, the district court concluded that a person is to be regarded as a “registrant,” and is thus protected under the NVRA, “at the moment his or her name appears on ‘the official list of eligible voters,’ ” id. at 18, and may only be removed pursuant to the specific provisions in the NVRA. Id. at 19. The majority shares this view. I believe this conclusion is not only inconsistent with the law as it has been applied in Michigan ever since the district court opinion in Miller, but, more importantly, it is inconsistent with Sixth Circuit precedent.

That precedent arose in Bell v. Marinko, 235 F.Supp.2d 772 (N.D.Ohio 2002), which involved several individual plaintiffs who were included in Ohio’s “official list” of registered voters. Following an eviden-tiary hearing, the plaintiffs were found to be seasonal residents of the precincts in which they were registered to vote, and they had their registrations terminated based on, and pursuant to, an Ohio state law that defined a “qualified elector” as a person who resided in the relevant precinct on a permanent basis.2 They filed suit, alleging that the only way to be taken off an “official” voter list is in accordance with the specific conditions set forth in the NVRA: (i) at their own request, (ii) by reason of conviction of a crime or mental disability, or (iii) change of residence. Id. at 775. The district court disagreed. It began by noting that the NVRA was adopted “ ‘to establish procedures that will increase the number of eligible citizens who register to vote in elections for federal office,’ while also assuring that ‘accurate and current voter registration rolls are maintained.’ ” Id. (quoting 42 U.S.C. *391§ 1973gg(b)(l), (4) (emphasis added)). Although the NVRA sought to accomplish these dual objectives by, inter alia, ensuring that “once registered, voters could not be removed from registration rolls because of a failure to vote or changed addresses,” the district court noted that it was state law that determined as a threshold matter whether and when an individual is a qualified voter in the first instance. See id. at 776-76 (emphasis added). The Ohio statute in Bell required, among other things, that all voters “ ‘continue[ ] to reside in the precinct until the next election.’ ” Id. at 776 (quoting In re Protest Filed by Citizens for Merit Selection of Judges, Inc., 49 Ohio St.3d 102, 103-04, 551 N.E.2d 150 (1990)). The plaintiffs argued that the “absolute language” in the NVRA required a finding that the defendants violated federal law because the conditions described in section 1973gg-6(a)(3), noted supra, were not present, but the district court held:

[Tjhat reading overlooks the precondition to being entitled to vote: “con-tinu[ing] to reside in the precinct until the next election.” If the residency precondition is not met, a person is not entitled to vote: he is not a “qualified elector.” See [In re Protest, supra, 49 Ohio St.3d at 104, 551 N.E.2d 150] (a person “is not an ‘elector’ or ‘qualified elector’ unless his actual current residence is registered with the board of elections.”).
Residency within the precinct is a crucial qualification. * * * One simply cannot be a “qualified elector” entitled to vote unless one resides in the precinct where he or she seeks to cast his ballot. And, “if one never lived within a precinct, one cannot continue to reside in the precinct.” He or she is not, and cannot be an “eligible voter,” even if listed on the Board’s rolls as such.
The VRA does not affect Ohio’s ability to condition eligibility to vote on residence. Nor did it undertake to regulate challenges, such as that presented here, to a registered voter’s residency ab ini-tio. If the action of the Board were to be found to violate § 197Sgg-6(a)(3), the effect would be to grant, and then protect, the franchise of persons not entitled to vote.
* * *
I conclude that the VRA cannot be read in this manner. To do so would set the stage for chaos whenever a challenge to one of the most fundamental preconditions to voting- — residency within the precinct — arose. The VRA and its manifest purposes, to make enrollment easy and protect the rolls from expungement on the basis of bias or other improper motive, while allowing disqualification when justified, would be frustrated.

Id. at 776 (emphasis added). The district court determined that Ohio’s voter residency challenge and disqualification process must be read in pari materia with the NVRA, id., and it summed up its holding on this point as follows: “Plaintiffs registered to vote. They exercised that franchise, presumably, until challenged. The ability of the challengers to assert that plaintiffs were not eligible, and had not ever been eligible, and of the Board to consider and resolve that challenge, does not contravene § 1973gg-6(a)(3).” Id. at 776-77 (emphasis added).

On appeal, the plaintiffs in Bell argued, just as the plaintiffs do here, that the NVRA “sets forth the exclusive reasons for which a state may remove a voter from a voting precinct’s list of registered voters,” and, because the defendants below had removed the plaintiffs from the official list even though they did not meet that criteria, the removal “violated the Act.” Bell v. Marinko, 367 F.3d 588, 591 (2004). *392The Sixth Circuit ruled against the plaintiffs and held as follows:

Section 1973gg-6(a)(3) of the Act provides that the name of a registrant “may not be removed from the official list of eligible voters except” when the registrant requests such removal, when the registrant has been convicted of a crime, or when he or she is mentally incapacitated. Also, section 1973gg-6(a)(4) allows for removal pursuant to a state program or activity “that makes a reasonable effort” to remove ineligible voters by reason of death or change of residence. Appellants argue that because none of these has occurred, their names may not be removed. We disagree.
In creating a list of justifications for removal, Congress did not intend to bar the removal of names from the official list of persons who were ineligible and improperly registered to vote in the first place. The National Voter Registration Act protects only “eligible” voters from unauthorized removal. See 42 U.S.C. § 1973gg-6(a)(l) (seeking to “ensure that any eligible applicant is registered to vote in an election”); Id. at § 1973gg-6(a)(3) (providing that “the name of a registrant may not be removed from the official list of eligible voters except” under specific circumstances) (emphases added). Eligible voters, at a minimum, are those who qualify as bona fide residents of the precinct in which they are registered or wish to register to vote. See, e.g., [collecting cases]. Residence, as defined in section 3503.02(a) of the Ohio Revised Code, is that place “in which the person’s habitation is fixed and to which, whenever the person is absent, the person has the intention of returning.”

Id. at 591-92 (emphasis added). The Court went on to explain that the purpose of the NVRA was to ensure that “ ‘accurate and current voter registration rolls are maintained,’ ” see id. at 592 (quoting 42 U.S.C. § 1973gg-6(a)(4) (emphasis added)), therefore, the statute could not be read to preclude removal of the name from an official roll when the would-be voter was ineligible and improperly registered to vote in the first instance. Id. at 591-92.

As stated previously, under the Michigan law at issue, an individual is not registered until he or she receives a voter identification card. See Mich. Comp. Laws § 168.500c. Consequently, anyone placed on the official roll prior to receiving his or her card is ineligible and not registered to vote. The Sixth Circuit has expressly rejected the position that the district court apparently adopted here: that a voter placed on an official voter list — even if he or she was “ineligible and improperly registered to vote in the first place, see Bell, supra, 367 F.3d at 591-92 — may be removed from an official voter list only in the specific ways set out in the NVRA. To hold for the plaintiffs in this case would produce an upside down result, for, as this Court recognized in Bell, it would “effectively grant, and then protect, the franchise of persons not eligible to vote.” Id. at 592.

In his decision, the district judge here believed it significant (indeed, the case “hinge[d]” on the fact) that a voter in the QVF could vote immediately, even if his or her identification card “were to be returned as undeliverable only after an election has intervened.” District Court Order at 18-19 (emphasis in original). In other words, because a voter in the QVF may be permitted to vote pending attempted delivery of the identification card, the district court determined that the voter is automatically protected as a “registrant” under the NVRA. The majority also believes this fact to be significant. Indeed, the majority states that “what matters is, *393functionally speaking, when an individual becomes able to cast a ballot.” Majority Op. at 384; accord id. at 17-19 (concluding that “once Michigan gives an individual ‘active’ status in the QVF, the status that would permit the individual to cast a regular ballot on Election Day, the individual becomes a ‘registrant’ protected under the NVRA.”). Using a “simple example” involving voter Mr. Doe, the majority states that if Mr. Doe is listed as “active” in the QVF, then he would be permitted to cast a regular ballot even though his identification card may later be returned as undeliverable. Id. at 17-18. The majority thus concludes that “[o]nce the state takes the step of identifying individuals as eligible voters, those individuals clearly become ‘registrants’ protected by the NVRA.” Id. at 18. In my view, this conclusion flatly contradicts the holding in Bell, supra, where, as noted, the plaintiffs registered to vote and actually “exercised that franchise ... until challenged.” Because the voters in Bell were not only presumptively “eligible” to cast a ballot, but they actually did, they were unquestionably “registrants” under the NVRA as the majority construes that term. Yet, the district court and Sixth Circuit held that it was of no moment that the voters had been placed on the rolls and previously allowed to vote because the voters had never been eligible to vote under state law at the outset. Thus, insofar as the voters in the present case are also ineligible to vote and improperly registered under state law, it is not significant for NVRA purposes that they were placed in the QVF.

The majority suggests that I miscom-prehend the definition and meaning of the term “registrant.” Regardless of whether a voter is on the QVF, a different type of computer database, in a paper file, or on a rolodex, the question of who is a “registrant” ultimately turns on who is a qualified voter legitimately on the voting rolls of the state. The majority appears to take the position that everyone in the QVF is per se qualified, but there is no justification in the record for that conclusion. In fact, the opposite seems more probable. There is a presumption that if your mail is not delivered then you do not reside at the listed address. That presumption is used in the law and in business every single day.

Furthermore, I do not agree with the majority that the defendants have failed to show irreparable harm. The Michigan law and practice has been long established and has, apparently, not presented any real problems. Now, only days before this very important election, a federal court has decided that the Michigan state voter registration process must be immediately enjoined. While the defendants have conceded that “it is possible” to comply with the injunction, to do so will require significant reallocation of state and local resources in preparation for the upcoming election, as well as inject a serious risk of unintended error that would only be discovered after the election. As the defendants have persuasively argued, they have been enforcing the relevant statutes and implementing the accompanying procedures for more than a decade based on existing law, and it is a significant burden for them to implement a new procedure with less than one week until the election. The district court’s opinion seriously alters the status quo on the eve of an election, and it is completely unnecessary given that, as set forth above and based on existing precedent, the practice being challenged does not appear to even conflict with or violate the NVRA.

Nor do I believe that there is any evidence that the plaintiffs will be substantially harmed by issuing the stay and denying the injunction. As the defendants demonstrated in the district court [see De*394fendants’ Exhibit C to Motion for Stay], and as they contend in this appeal, the provisional ballot process ensures that even those individuals who have their original voter identification card returned will not be automatically disqualified from voting November 4th. Rather, the voter with proper identification will be permitted to essentially “re-register” on election day.

And lastly, I believe the defendants have adequately shown that the stay is in the public interest. Despite what the majority contends, voter fraud is real and should not be condoned. There is obviously a strong public interest in the integrity of the voting process and maintaining confidence among the electorate that the system is fair. We do not serve the process well with our decision today.

For these reasons, I respectfully dissent.

. The holding was not discussed by this Court because, apparently, the issue was not raised on appeal. This is not at all surprising since it was State of Michigan defendants who appealed and, obviously, they had no reason to challenge a ruling in their favor. However, the plaintiffs did not challenge it by cross appeal. The holding has, therefore, remained the law of that case and the law with respect to that aspect of Michigan’s voter registration procedure for almost thirteen years, and the defendants "have been enforcing and implementing the process under the auspices of that opinion ever since.” To be clear, despite the majority's suggestion to the contrary, I am not proposing that the district court opinion in Miller is "somehow binding” on this Court. However, the opinion is relevant to the extent it demonstrates that a reasonable jurist can, and has, reached a different conclusion from the majority. More importantly, it speaks to the wisdom of entering an injunction on an emergency basis on the eve of an important election when the procedures being enjoined have been used for more than a decade specifically on the basis of that opinion.

. I recognize that the present case involves a statute in Michigan (not Ohio), and, also, that the alleged violation in Bell arose under a different subsection of section 1973gg-6 of the NVRA. Nevertheless, as will be discussed, I believe the case is closely analogous and highly instructive. Indeed, the underlying holding of Bell — that state law determines whether a person is an eligible voter and the state may challenge eligibility without violating the NVRA "even if [the voter is] listed on the Board's rolls as such” — would appear to control this case.