Scheer v. City of Miami
15 F. Supp. 2d 1338 (1998)
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Rule of Law:
A federal court should not intervene in a state election dispute, even one involving massive fraud that results in the disenfranchisement of lawful voters, so long as the state's remedy is based on established, pre-existing state law and does not involve a post-election change in rules that would create fundamental unfairness.
Facts:
- On November 4, 1997, the City of Miami held a mayoral election between primary contenders Joe Carollo and Xavier Suarez.
- Neither candidate received a majority, forcing a run-off election on November 13, 1997.
- In the run-off, Suarez defeated Carollo, with the outcome largely determined by absentee ballots.
- Following the election, evidence emerged of a massive and widespread fraudulent scheme involving the absentee ballots.
- A class of absentee voters who lawfully cast their ballots had their votes invalidated as a result of the state court's remedy to the fraud.
Procedural Posture:
- Three Miami voters filed a state lawsuit in the Circuit Court of the Eleventh Judicial Circuit of Florida, challenging the results of the mayoral election.
- Candidates Joe Carollo and Xavier Suarez intervened in the state court action.
- The state trial court found massive absentee voter fraud and ordered a new election as the remedy.
- The decision was appealed to the Third District Court of Appeal of Florida.
- The state appellate court affirmed the finding of fraud but reversed the remedy, ordering that only the absentee ballots be invalidated, which resulted in Carollo being declared the winner.
- A class of absentee voters whose lawful votes were invalidated filed a new lawsuit in the U.S. District Court for the Southern District of Florida, seeking declaratory and injunctive relief in the form of a new election.
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Issue:
Does a state court's decision to invalidate all absentee ballots in an election due to widespread fraud, thereby nullifying lawfully cast votes, constitute a federal constitutional violation that warrants federal court intervention?
Opinions:
Majority - Chief Judge Edward B. Davis
No. A state court's decision to invalidate all absentee ballots due to massive fraud, based on long-standing state precedent, is not a federal constitutional violation requiring federal court intervention. Federal courts should only intervene in state election disputes in extreme circumstances of fundamental unfairness, not for 'garden variety' election irregularities or 'episodic events' like voter fraud. The court distinguished this case from those where a state changed its election rules after votes were cast, which would be fundamentally unfair. Here, Florida's judiciary applied a consistent, sixty-year-old legal precedent for dealing with absentee ballot fraud. Therefore, this is a matter of state law and process, and principles of federalism and equity require the federal court to abstain from meddling with the state's chosen remedy.
Analysis:
This decision strongly reinforces the principle of federalism and judicial restraint regarding state election administration. It establishes a high bar for federal court intervention, distinguishing between 'episodic' problems like fraud and systemic, state-sanctioned 'fundamental unfairness' like a post-election change of rules. The case clarifies that even when a state's remedy for fraud results in the disenfranchisement of innocent voters, it does not automatically create a federal constitutional issue if the remedy is consistent with established state law. This precedent significantly limits the ability of litigants to use federal courts to challenge the outcomes of state elections marred by irregularities, pushing such disputes firmly into the purview of state courts.
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