McDonald v. Board of Election Comm'rs of Chicago
Headline: Pretrial county jail inmates lose bid for absentee ballots as Court upholds Illinois absentee-voting rules, leaving in-county detainees without that convenient option while states may limit absentee access.
Holding: The Court upheld Illinois’ absentee-voting rules and rejected challengers’ equal-protection claim, finding the statutory categories rationally related to legitimate state interests and not unconstitutional.
- Allows states to restrict which groups may receive absentee ballots.
- Leaves unsentenced in-county jail inmates without automatic absentee ballots.
- Encourages legislatures to expand absentee voting gradually rather than require universal access.
Summary
Background
A group of unsentenced inmates awaiting trial in the Cook County jail — all qualified Illinois voters who could not readily appear at the polls because they were charged with nonbailable offenses or could not post bail — asked for absentee ballots. Their timely applications for the April primary, supported by a warden’s affidavit that they could not appear in person, were denied under Illinois law because they were not “physically incapacitated” as that term is defined in the State’s absentee statutes. The inmates sued, arguing that the law treated similarly situated people differently and violated equal protection, and a three-judge court ultimately decided the question.
Reasoning
The Court asked whether the absentee rules unlawfully discriminated against these jailed voters. It held they did not. The Justices said the absentee provisions aim to make voting more available to some groups and that the classifications in the law are rationally related to legitimate state goals. The Court found no record evidence that Illinois otherwise prevented the inmates from voting and noted the State’s statutes only disenfranchise people who have been convicted and sentenced. Because the classifications were not based on race or wealth and did not bar the right to vote itself, the Court applied ordinary rational-basis review and found the law constitutional.
Real world impact
The ruling lets Illinois keep its limited list of absentee voters and leaves unsentenced in-county detainees without automatic absentee ballots unless the legislature acts. The opinion also affirms that States may expand absentee voting step-by-step and that different treatment of in-county and out-of-county prisoners can be justified on practical grounds like prison discipline and local influence concerns.
Dissents or concurrances
Two Justices (Harlan and Stewart) agreed with the judgment but simply concurred in the result; no separate dissent altering the outcome appears in the record.
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