Hall v. Beals

Background

The appellants were a couple who moved from California to Colorado in June 1968 and tried to register to vote in the November presidential election. Colorado then required six months’ residency to vote for President; election officials refused to register them. They sued county election officials seeking orders to register them conditionally and to stop enforcement of the residency rule. A three-judge District Court upheld the six-month rule and dismissed the case.

Reasoning

While the appeal was pending, Colorado reduced its residency requirement for presidential elections from six months to two months, and the appellants later satisfied the original six-month period. The Court reviewed the case in light of the amended law and concluded there was no longer a live controversy for these plaintiffs to decide. The majority vacated the district judgment and directed dismissal as moot, explaining the plaintiffs no longer faced an adverse effect and thus could not represent a class of people they were not part of.

Real world impact

Because the Court dismissed the case as moot, it did not rule on whether short state residency requirements violate the Constitution. The decision shows that changes in state law can prevent the Supreme Court from resolving constitutional challenges. It also emphasizes that plaintiffs must personally belong to the group they seek to represent when asking for class-wide relief.

Dissents or concurrances

Justices Brennan and Marshall dissented, arguing the case was “capable of repetition, yet evading review,” and would reach the merits. Marshall contended the durational residency rule likely violated equal protection and said he would reverse.