Purcell v. Gonzalez

2006-10-20

Headline: Court vacates an appeals-court injunction and allows Arizona’s Proposition 200 voter ID rules to take effect for the upcoming election, letting voters cast ballots under the new ID procedures while the case proceeds.

Holding: The Court granted the State’s petitions, vacated the Ninth Circuit’s injunction against enforcing Arizona’s Proposition 200 identification rules, and allowed the upcoming election to proceed without suspending those rules.

Real World Impact:

Allows Arizona’s new voter ID rules to be used in the upcoming election.
Leaves the ID law subject to later court review and fuller factual findings.
Pushes lower courts to build a clearer record on disenfranchisement and fraud.

Topics: voter ID rules, election procedures, voting rights, court injunctions

Summary

Background

Arizona voters approved Proposition 200 in 2004, requiring proof of citizenship to register and identification to vote on election day. The State set procedures allowing conditional provisional ballots that must be verified within five business days and permitting early voting without ID. The Attorney General precleared the changes under the Voting Rights Act in May 2005. Plaintiffs — Arizona residents, Indian tribes, and community groups — sued in 2006. The District Court denied a preliminary injunction on September 11 but did not issue findings until October 12. Meanwhile the Ninth Circuit’s two-judge motions panel, without giving reasons, enjoined enforcement on October 5 pending appeal.

Reasoning

The Supreme Court emphasized both the State’s interest in preventing voter fraud and voters’ interest in access to the ballot. It said the Court of Appeals should have shown deference to the District Court’s role and provided reasoning before enjoining the law so close to an election. Because the appeals court issued a bare order without findings, this Court could not evaluate the ruling against the District Court’s later findings. The Supreme Court therefore granted the State’s filing, vacated the Ninth Circuit’s order, and sent the cases back for further proceedings while allowing the election to go forward.

Real world impact

The immediate effect is that Arizona’s identification rules remain in place for the upcoming election and voters will cast ballots under those procedures. The decision is not a final ruling on the law’s constitutionality; the legal challenge will continue and lower courts must develop a fuller factual record.

Dissents or concurrances

Justice Stevens concurred, stressing that letting the election proceed will produce better factual evidence about how many voters might be disenfranchised and how common voter fraud actually is.