Raysor v. DeSantis
The Court left in place an appeals court order that blocked a federal judge's ruling against Florida's requirement that people with felony convictions pay all outstanding fines and fees before voting, effectively preventing thousands of poor Floridians from participating in the August 2020 primary.
Three justices dissented, arguing the Court was allowing mass disenfranchisement based on poverty while giving the appeals court a free pass for issuing an unexplained stay that upended a year-old legal status quo days before the registration deadline.
How it got here: A federal district court issued a permanent injunction against Florida's pay-to-vote scheme after an eight-day trial; the Eleventh Circuit stayed that injunction without explanation; affected voters applied to the Supreme Court to vacate the stay.
The Case in Depth
What happened
In 2018, Florida voters passed a constitutional amendment restoring voting rights to people with felony convictions once they completed their sentences. Florida's legislature then conditioned that restored right on full payment of all court-ordered fines, fees, and restitution. A group of indigent people with felony convictions sued, arguing that the requirement unconstitutionally bars people from voting simply because they are too poor to pay — affecting nearly a million otherwise-eligible Floridians.
The question before the Court
Should the Supreme Court have unblocked a lower-court ruling that let poor Floridians with felony convictions vote without first paying off their court fines and fees — just days before a voter-registration deadline?
The Court's answer
No — the Court declined to vacate the Eleventh Circuit's stay, leaving that stay in effect through a single unexplained line. The order gives no reasons for the Court's decision.
Three dissenting justices argued the Court should have stepped in: the Eleventh Circuit issued a bare stay order with no reasoning, failed to defer to a federal district court's detailed findings from an eight-day trial, contradicted its own earlier ruling that the pay-to-vote scheme likely violated equal protection, and created dangerous confusion for voters just nineteen days before the registration deadline — exactly the kind of last-minute electoral disruption the Court's own precedents warn against.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Nearly a million Floridians with felony convictions who still owed fines, fees, or restitution could not register or vote in the August 2020 primary. Tens of thousands who had already registered in reliance on the year-old preliminary injunction were left uncertain about their eligibility and exposed to potential criminal prosecution for voting.
What changes now
The Eleventh Circuit's stay of the district court's permanent injunction remained in effect for Florida's August 2020 primary. The Eleventh Circuit was scheduled to hear oral argument on August 18, 2020 — the day of the primary — meaning the underlying constitutional questions about wealth discrimination in voting were not yet resolved. The Supreme Court's order is temporary and does not decide the merits of Florida's pay-to-vote scheme.
What this does not decide
The order does not decide whether Florida's requirement that felons pay all fines and fees before voting is constitutional. It only declines to undo the appeals court's temporary pause of the district court's ruling. The Equal Protection, Due Process, and Twenty-Fourth Amendment claims remain live in the lower courts.
Concurrences and dissents
Dissent — Justice Sotomayor
Justice Sotomayor argued the Court should have vacated the Eleventh Circuit's stay because it issued an unexplained bare order that contradicted the circuit's own earlier ruling, failed to defer to extensive district court fact-finding, and created severe voter confusion days before a registration deadline — disenfranchising thousands of poor Floridians simply because they cannot pay. She also criticized the Court for invoking its Purcell precedent to block pandemic-era voting accommodations while ignoring Purcell's lessons here.
How the Court got there
The legal reasoning, step by step
- The legal framework for vacating an appellate court's stay comes from a three-part test: the case must be likely to come before the Supreme Court for full review; the stay must cause serious and irreparable harm to the people seeking relief; and the appeals court must have been clearly wrong in applying standard legal principles when it issued the stay.
- The Court's order is a single line with no explanation. Because there is no majority reasoning, the available reasoning comes entirely from the three dissenting justices, who argued that all three factors strongly favored vacating the Eleventh Circuit's stay.
- On irreparable harm, the dissent pointed out that denial of the right to vote is by definition irreparable — it cannot be undone after election day — and that the confusion caused by the stay could deter eligible voters from the polls altogether. The State, by contrast, had proposed the very remedies the district court ordered, making any claim of State harm weaker.
- On the Eleventh Circuit's legal error, the dissent argued the appeals court issued a bare stay order with no written reasoning, ignoring extensive factual findings from an eight-day district court trial — including the finding that the overwhelming majority of affected people genuinely cannot pay their outstanding financial obligations — to which it was legally required to defer.
- The dissent also argued the Eleventh Circuit triggered the precise voter confusion that the Court's 2006 decision in Purcell v. Gonzalez was designed to prevent: the stay reversed a legal status quo that had been in place for nearly a year, arrived nineteen days before the registration deadline, and left tens of thousands of people who had already registered under the earlier ruling uncertain whether they faced criminal prosecution for voting.