Purcell v. Gonzalez

Supreme Court of United States
549 U.S. 1, 127 S. Ct. 5 (2006)

ELI5:

Rule of Law:

Federal courts should not issue injunctions that alter state election rules in the period immediately preceding an election, as such judicial orders can create voter confusion and uncertainty, which itself is a significant harm.

Facts:

In 2004, Arizona voters approved Proposition 200, a measure requiring voters to present proof of citizenship to register to vote and identification to vote on election day.
The new procedure allowed a voter without ID on election day to cast a conditional provisional ballot.
To count the provisional ballot, the voter had five business days to return to a designated site and present proper identification.
The law also permitted early voting without identification, as election officials had adequate time to verify signatures against registration rolls.
In May 2005, the U.S. Attorney General precleared Proposition 200's procedures under the Voting Rights Act.
Various Arizona residents, Indian tribes, and community organizations challenged the constitutionality of the identification requirements.

Procedural Posture:

In May 2006, plaintiffs sued Arizona officials in the U.S. District Court for the District of Arizona, challenging Proposition 200.
The plaintiffs moved for a preliminary injunction to block enforcement of the law's identification requirements.
On September 11, 2006, the District Court (the trial court) denied the plaintiffs' request for a preliminary injunction.
The plaintiffs appealed the denial to the U.S. Court of Appeals for the Ninth Circuit (the intermediate appellate court).
While the appeal was pending, plaintiffs asked the Court of Appeals for an injunction pending appeal.
On October 5, 2006, a two-judge motions panel of the Ninth Circuit issued a four-sentence order granting the injunction, blocking Proposition 200 without providing any reasoning.
On October 12, the District Court issued its formal findings, concluding plaintiffs had shown only a 'possibility' of success on the merits and that the balance of harms weighed against an injunction.
The State of Arizona and county officials (the applicants) filed an emergency application with the U.S. Supreme Court, which the Court construed as a petition for a writ of certiorari.

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Issue:

Does a federal appellate court err when it issues an unreasoned injunction against a state's election procedures shortly before an election, thereby failing to give deference to the lower court's denial of the same injunction?

Opinions:

Majority - Per Curiam

Yes. A federal appellate court errs when it issues an unreasoned injunction altering election rules close to an election without deferring to the District Court. A state has a compelling interest in preserving the integrity of its election process, and court orders affecting elections close to election day can result in voter confusion and an incentive for citizens to stay away from the polls. The Court of Appeals provided no factual findings or legal reasoning for its order, failing to give the required deference to the discretion of the District Court. This failure to explain its reasoning, especially in light of the impending election and the need for clear guidance, constituted an error requiring this Court to vacate the injunction.

Concurring - Justice Stevens

Yes. Allowing the election to proceed under the challenged law is the correct course of action because it will create a better factual record on which to judge the law's constitutionality later. Key factual issues, such as the scope of potential disenfranchisement and the prevalence of voter fraud, are currently unresolved and based on speculation. Permitting the election to go forward will provide historical facts, rather than speculation, which will enhance the likelihood that the important constitutional questions are resolved correctly in the future.

Analysis:

This case established what is now known as the "Purcell principle," a strong presumption against federal courts altering state election rules in the period just before an election. The decision prioritizes the avoidance of voter confusion and administrative chaos over the last-minute adjudication of the merits of an election law challenge. The Purcell principle has become a significant doctrinal hurdle for plaintiffs seeking emergency relief in election litigation, forcing them to bring challenges well in advance of an election. It underscores the judiciary's reluctance to manage elections from the bench, particularly as election day nears.

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