Purcell v. Gonzalez
The Supreme Court set aside a federal appeals court order that had blocked Arizona from enforcing its new voter-identification rules just weeks before the 2006 election, finding the appeals court gave no reasons and failed to defer to the trial judge who had already declined to block the law.
The ruling let Arizona's identification requirements go into effect for the upcoming election while the underlying lawsuit over the law's constitutionality continued, and it established a lasting caution that courts should be wary of changing election rules on the eve of an election.
“Court orders affecting elections, especially conflicting orders, can themselves result in voter confusion and consequent incentive to remain away from the polls.”
The Court's caution about judicial intervention in election procedures close to an election.
How it got here: A federal trial court denied a preliminary injunction against Arizona's voter ID law; a Ninth Circuit motions panel then enjoined the law without explanation, prompting Arizona's emergency request to the Supreme Court.
The Case in Depth
What happened
Arizona voters approved Proposition 200 in 2004, requiring proof of citizenship to register and identification to vote. Arizona residents, Indian tribes, and community organizations sued, arguing the ID requirements would disenfranchise qualified voters. A federal trial court denied their request to block the law before the November 2006 election, though it took weeks to explain its reasoning.
The question before the Court
Just weeks before an election, could a federal appeals court block Arizona's new voter ID law without explaining its reasoning or deferring to the trial judge?
Why it matters
Arizona voters faced the new identification rules at the polls for the 2006 election, while the broader legal fight over whether the law disenfranchises voters continued in the lower courts. The decision also gave courts nationwide a guiding caution — since dubbed the "Purcell principle" — against issuing last-minute changes to election procedures close to voting.
What changes now
The injunction against Arizona's identification rules was lifted, allowing the rules to be enforced in the imminent election. The case was sent back to the lower courts for full briefing and argument on whether the identification requirements are ultimately constitutional; the Supreme Court expressly took no position on that underlying question, leaving it to be resolved later with a fuller factual record.
What this does not decide
The Court expressly said it was not deciding whether Arizona's voter ID law is constitutional or how the appeal of the preliminary injunction denial should ultimately come out. It only found the appeals court's unexplained, last-minute injunction improper, leaving the merits for further proceedings below.
Concurrences and dissents
Concurrence — Justice Stevens
Justice Stevens agreed that letting the election proceed without an injunction was wise, but for an evidentiary reason: allowing the law to operate first would create a better factual record on two unresolved questions — how many voters the ID rules would disenfranchise and how widespread the fraud problem actually was — so the constitutional issues could later be judged on facts rather than speculation.
How the Court got there
The legal reasoning, step by step
- The Court recognized competing interests: a state's compelling interest in preventing voter fraud and preserving election integrity, against voters' fundamental right to cast a ballot without being wrongly turned away.
- The Court explained that as an election approaches, court orders changing voting procedures — especially conflicting ones — can themselves confuse voters and discourage them from going to the polls, so late judicial intervention carries its own risks.
- Despite those time pressures, the Court held that a court of appeals must still give deference to a trial court's discretion when reviewing a request to block election procedures, since the trial court is closer to the facts.
- The Court found the appeals panel gave no explanation, findings, or reasoning for enjoining the ID rules and made no showing that the trial court's later findings were wrong.
- Because the appeals panel disregarded the deference it owed the trial court and offered no justification of its own, the Court concluded that issuing the injunction without explanation was error.