Justia Minnesota Supreme Court Opinion Summaries

Matthew Eric Zinda filed a petition under Minn. Stat. § 204B.44, requesting that Steve Simon, Minnesota Secretary of State, and Deborah Erickson, Crow Wing County Auditor, exclude Josh Heintzeman from the 2024 primary and general election ballots for State Representative for Legislative District 6B. Heintzeman had filed an affidavit of candidacy listing his party as “Republican.” Zinda argued that Heintzeman did not seek the nomination of a major political party because he did not specify “Republican Party of Minnesota” and thus should not be on the primary ballot.The Minnesota Supreme Court directed the parties to file responses and memoranda. Zinda was the only other candidate who filed an affidavit of candidacy for the Republican primary for the same office, listing his party as “Republican Party of Minnesota.” The court noted that Heintzeman won the Republican primary and would appear on the general election ballot as the Republican candidate.The Minnesota Supreme Court held that Zinda did not prove that the respondents committed an error by placing Heintzeman on the primary ballot. The court found that the term “Republican” is understood to refer to the Republican Party of Minnesota, as Minnesota law precludes other parties from using the word “Republican” on the ballot. The court also concluded that Minn. Stat. § 204B.06, subd. 1, does not require candidates to list the full name of a major political party on their affidavit of candidacy. Therefore, the court denied Zinda’s petition, allowing Heintzeman to remain on the ballot as a Republican candidate. View "Zinda v. Simon" on Justia Law

The case involves a challenge to the Re-Enfranchisement Act, which allows individuals convicted of felony-level offenses to vote once they are no longer incarcerated. The plaintiffs, individual taxpayers and the Minnesota Voters Alliance, argued that the Act violates the Minnesota Constitution by restoring only the right to vote rather than all civil rights. They also claimed that using public funds to educate and notify people about the new voting provision is unlawful if the Act itself is unconstitutional.The district court denied the petition, concluding that the plaintiffs lacked standing. The court determined that taxpayer standing requires a challenge to an illegal expenditure or waste of tax money, which the plaintiffs failed to demonstrate. The court also found that the Minnesota Voters Alliance lacked associational standing because its members did not have standing.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court clarified that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. The court held that the plaintiffs could not manufacture standing by pointing to incidental expenditures related to implementing the law. Since the plaintiffs' challenge was primarily against the substantive law itself and not the expenditures, they lacked the necessary standing. Consequently, the Minnesota Voters Alliance also lacked associational standing. The court did not address the merits of the case due to the lack of standing. View "Minnesota Voters Alliance vs. Hunt" on Justia Law

The case revolves around the petitioner, Ryan Binkley, who sought to have his name included on the Republican Party of Minnesota's ballot for the 2024 presidential nomination primary. However, the Chair of the Republican Party of Minnesota did not include Binkley as a candidate when notifying the Minnesota Secretary of State, Steve Simon, of the candidates for its ballot. Consequently, Binkley and his campaign committee filed a petition with the court, arguing that the procedures established by Minnesota Statutes section 207A.13, subdivision 2(a), which allow a major political party to determine the candidates that will appear on its ballot for the presidential nomination primary, violate the Electors Clause of the United States Constitution.The case was brought before the Minnesota Supreme Court after the petitioners' claim was denied in the lower court. The petitioners argued that the Electors Clause prohibits state-based favoritism on ballots through the exclusion of qualified candidates. The Secretary of State, however, contended that the presidential nomination primary is not subject to the Electors Clause because Minnesota does not use the presidential nomination primary to appoint presidential electors.The Minnesota Supreme Court agreed with the Secretary of State, ruling that the presidential nomination primary is not part of the process that Minnesota uses to appoint presidential electors. Therefore, the statutes that govern the presidential nomination primary do not fall within the scope of the Electors Clause. The court concluded that the petitioners' claim that section 207A.13, subdivision 2(a) violates the Electors Clause fails as a matter of law. The petition was thus denied. View "J. Binkley for President 2024 vs. Simon" on Justia Law

The Minnesota Supreme Court ruled that the Legal Marijuana Now Party (LMNP) does not meet the requirements to be classified as a major political party under Minnesota law. The case was initiated by Ken Martin, the chair of the Democratic-Farmer-Labor Party, who filed a petition arguing that the LMNP failed to comply with certain requirements for major political parties. Specifically, Martin claimed that the LMNP did not maintain a state central committee subject to the state convention’s control, as required by Minnesota law.The case was referred to a referee, who concluded that the LMNP had indeed failed to meet the requirements to be a major political party. The LMNP objected to these findings and argued that the relevant statutes unconstitutionally infringed upon its First Amendment associational rights.The Minnesota Supreme Court rejected the LMNP's arguments. It found that the LMNP's single committee, The Head Council, was not subject to the control of the LMNP’s state convention, as required by law. The court also rejected the LMNP’s constitutional challenge, finding that the party failed to demonstrate how the statutory requirements specifically burdened its associational rights. As a result, the court held that the LMNP does not meet all the statutory requirements to maintain its status as a major political party for the upcoming state primary and general elections. View "Martin vs. Simon" on Justia Law

In Minnesota, a group of voters sought to prevent former President Donald Trump from appearing on the 2024 presidential primary and general election ballots, arguing that Section 3 of the Fourteenth Amendment of the U.S. Constitution, which disqualifies anyone from holding office who has engaged in insurrection or rebellion against the U.S., rendered him ineligible. The Minnesota Supreme Court held that it would not be an error to place Trump's name on the 2024 Republican Party presidential nomination primary ballot. The court reasoned that the nomination primary is an internal party election, and the state law does not prohibit a major political party from placing an ineligible candidate on the primary ballot. However, the court did not decide on the issue of Trump's name on the general election ballot, stating that the matter was not yet ripe for adjudication as it was not "about to occur" under the relevant state law. The court did not foreclose the possibility of petitioners bringing such a claim at a later date. View "Growe v. Simon" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals concluding that Minnesota Rule 8210.2450, subparts 2 and 3 (the rule) does not conflict with Minn. Stat. 203B.121 (the statute) and that the challenged rule was therefore invalid, holding that subpart 3 of the rule conflicted with subdivision 2(b)(3) of the statute.Appellants brought this declaratory judgment action seeking a prospective declaration that the administrative rule, which governed the acceptance of absentee ballots, was invalid because the rule subparts conflicted with the statute by infringing on discretion the legislature gave to ballot board members. The court of appeals determined that there was no conflict between the rule and the statute. The Supreme Court reversed in part, holding (1) Minn. R. 8210.2450, sub. 3, which authorized any ballot board member to review signatures in the event of an identification number mismatch, was invalid to the extent that the rule conflicted with Minn. Stat. 203B.121, subd.2(b)(3), which required that election judges conduct that review; and (2) the other challenged parts of the rule did not conflict with the statute. View "Minn. Voters Alliance v. Office of Minn. Secretary of State" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that an unconstitutional provision in a proposed charter amendment was not severable, holding that the provision was not severable from the remainder of the proposed charter amendment.On August 8, 2022, the Bloomington City Council voted to reject the entirety of a proposed charter amendment based on its conclusion that the last of the proposed amendment's four sections, section 4.08, was manifestly unconstitutional. Appellants filed a petition seeking declaratory and injunctive relief to sever section 4.08 and submit the remaining valid provisions to voters. The district court denied the petition, concluding that it would be improper to sever section 4.08 from the remainder of the proposed charter amendment. The Supreme Court affirmed, holding that section 4.08 could not properly be severed from the proposed city-charter amendment. View "Kranz v. City of Bloomington" on Justia Law

The Supreme Court granted a petition sought by Petitioner seeking an order authorizing Petitioner to send notices about errors on the for the Murray County ballot for the November 8, 2022 general election to all mail ballot voters and to all voters who had already requested an absentee ballot, holding that Petitioner was entitled to relief.The petition asserted that the ballot at issue incorrectly identified the district number for the Minnesota legislative officers as Senate District 22 and House District 22A. Petitioner did not seek to correct the errors on the ballot but sought to send notices regarding the errors and the authority to post the same notice in all Murray County polling places. The Supreme Court granted the petition, holding that Petitioner proposed an appropriate plan to remedy the ballot errors. View "In re Murray County Ballot" on Justia Law

The Supreme Court ordered that Petitioners shall correct the ballot for the November 8, 2022 general election because the general election ballot used by voters in Roseau County and Kittson County omitted information required by Minnesota law.Roseau and Kittson Counties filed petitions under Minn. Stat. 204B.44(a) to correct errors on the November 8, 2022 general election ballot, stating the the ballots in each county failed to include the political party affiliation for federal and state candidates and failed to include the word "incumbent" next to names of currently-serving judicial candidates. The Supreme Court ordered that the counties shall correct the ballot for the November 8, 2022 general election and that Petitioners shall resume delivery of ballots to voters after they receive corrected ballots from their vendors. View "In re Roseau County Ballot for the November 8, 2022 General Election" on Justia Law

The Supreme Court approved a plan proposed by Petitioner to correct an error on the November 8, 2022 general election ballot in this petition brought by the Ramsey County Elections Manager under Minn. Stat. 204B.44(a) with minor modifications.Due to a clerical error, Ramsey County ballots incorrectly listed Beverly Peterson, and not Scott Hesselgrave, as the Republican Party candidate for Minnesota House District 67A. Petitioner sought an order authorizing correction of the ballot for House District 67A, distribution of the corrected ballot, and procedures for counting these voters' ballots. The Supreme Court held that it was authorized to correct the ballot error and the Petitioner proposed an appropriate plan to remedy the error. View "In re 2022 General Election Ballot" on Justia Law