Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Election Law
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On December 21, 2012, Petitioner, the Independence Party candidate in the November 6, 2012 election for the U.S. House of Representatives, filed this petition pursuant to Minn. Stat. 204B.44 seeking declaratory and injunctive relief and asserting three claims: (1) Minn. Stat. 202A. 16(2), which identifies those who can participate in and vote at a precinct caucus, violates his First Amendment rights; (2) the Secretary of State improperly withheld from him the e-mail addresses of registered voters in his district in violation of the Minnesota Government Data Practices Act; and (3) the district court's refusal to accept his election contest for filing infringed on his constitutional right of access to the courts. The Supreme Court denied the petition, holding (1) laches bars Petitioner's first two claims, as Petitioner unreasonably delayed bringing these claims and granting relief on the claims would do substantial prejudice to the orderly administration of elections; and (2) Petitioner's third claim falls outside the scope of section 204B.44. View "Carlson v. Ritchie" on Justia Law

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Petitioners sought an order requiring that Respondents, the St. Louis County Auditor and the Minnesota Secretary of State, place Erik Simonson's name on the ballot for the 2012 general election as the candidate for the Democratic-Farmer-Labor (DFL) Party for the office of State Representative for House District 7B. Petitioners contended that the County Auditor erred by refusing to accept the affidavit of withdrawal submitted by DFL-nominated candidate Kerry Gauthier and affidavit of candidacy submitted by newly nominated DFL candidate Simonson for the general election in District 7B. The Supreme Court concluded that Minnesota law required Simonson's name to be placed on the November 2012 ballot by order filed in September 2012, with this opinion to follow, holding (1) a major political party has statutory authority to fill a vacancy in nomination for a partisan office that was caused by the withdrawal of its originally nominated candidate after the primary, as long as the originally nominated candidate complied with the procedures for filing an affidavit of withdrawal; and (2) the County Auditor erred when he rejected the affidavit of withdrawal that Gauthier attempted to file and the certificate of nomination listing Simonson as the DFL-nominated candidate that the DFL attempted to file. View "Martin v. Dicklich" on Justia Law

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In Martin v. Dicklich, the Supreme Court ordered the Saint Louis County Auditor to replace the name of Kerry Gauthier with the name of Erik Simonson as the Democratic-Farmer-Labor (FL) endorsed candidate for state representative, House District 7B, on the November 2012 general election ballot. Jay Fosle, who had previously declared his write-in candidacy for state representative, District 7B, was not served with a copy of the Martin petition. Fosle subsequently filed a petition with the Supreme Court, asking the Court to order that his name also be placed on the November 2012 ballot either as the "Independent candidate" or without party affiliation. The Supreme Court denied Fosle's petition by order filed in October 2012, with this opinion to follow, holding that there was no statutory or other basis on which to grant the relief Fosle sought here. View "Fosle v. Ritchie" on Justia Law

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In these two cases, Petitioners, members of the Minnesota Legislature and others, filed petitions pursuant to Minn. Stat. 204B.44 seeking an order requiring Mark Ritchie, the Minnesota Secretary of State, to use the titles designated by the Minnesota Legislature for two proposed constitutional amendment ballot questions that were scheduled to appear on the November 2012 general election ballot. Petitioners contended that by failing to use the title designated by the Legislature for each ballot question, Respondents failed to comply with the statutory requirement to "provide an appropriate title" for the ballot question. The Supreme Court granted the petitions, holding that when the Legislature has included a title for a ballot question in the bill proposing a constitutional amendment, the "appropriate title" the Secretary of State must provide for that ballot question is the title designated by the Legislature. View "Limmer v. Ritchie" on Justia Law

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This action was brought under Minn. Stat. 204B.44 seeking to correct an alleged error in the preparation of the ballot for the general election. Specifically, Petitioners sought to prevent the people of Minnesota from voting on the question of whether photographic identification should be required to vote in Minnesota. Without expressing an opinion as to the merits of changing Minnesota law to require photographic identification to vote, the Supreme Court concluded that Petitioners were not entitled to relief, holding that Petitioners did not meet their burden of demonstrating that there was an error that required the judiciary to intercede. View "League of Women Voters Minn. v. Ritchie" on Justia Law

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At issue in this case was whether a school district is subject to the campaign-finance reporting requirements found in Minn. Stat. 211A and whether the complaint in this matter stated a claim under Minn. Stat. 211B.06, which prohibits the dissemination of false campaign material. The Supreme Court held (1) a school district is a "corporation" under section 211A.01 and therefore can qualify as a "committee" subject to chapter 211A's campaign-finance reporting requirements if it acts "to promote or defeat a ballot question"; (2) because Appellants' complaint, filed with the Office of Administrative Hearings, stated a prima facie claim that the school district here was a "committee" under section 211A.01 that promoted a ballot question, the ALJ assigned to the matter erred in dismissing the complaint without an evidentiary hearing; and (3) the complaint failed to state a prima facie violation of section 211B.06 with respect to two allegedly false statements. Remanded. View "Abrahamson v. St. Louis County Sch. Dist." on Justia Law

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Petitioner filed with the Secretary of State's (Secretary) office an affidavit of candidacy as the Republican candidate for Minnesota State Senate, District 61. Petitioner's affidavit did not include a telephone number as required by statute, and therefore, Petitioner's affidavit was rejected. Petitioner subsequently filed a petition with the Supreme Court seeking an order requiring the Secretary to place his name on the 2012 general election ballot as a candidate for state senate. The Supreme Court denied the petition, holding that the Secretary properly rejected Petitioner's affidavit of candidacy because Petitioner failed to comply with the statutory requirements for filing to run for elective office. View "In re Petition of Pfliger" on Justia Law

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In June 2012, Petitioner filed an affidavit of candidacy and nominating petition with the Secretary of State's (Secretary) office, seeking to run as an independent candidate for Minnesota state representative. The Secretary rejected Petitioner's nominating petition because it did not bear her residence as required by statute and because Petitioner's statement of political party or political principle exceeded the three-word limit required by statute. Petitioner petitioned the Supreme Court to require the Secretary to list her on the 2012 general election ballot as a candidate for state representative. The Supreme Court denied the petition, holding that the Secretary properly denied Petitioner's nominating petition, as (1) candidates for public office must strictly comply with the statutory requirements for filing for office, and (2) the statement of political party or political principle on the pages of Petitioner's nominating petition exceeded the three-word limit required by statute. View "Anderson v. Ritchie" on Justia Law

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At issue in this appeal was how sealed absentee ballots that were rejected and never counted during the 2008 general election were classified under the Minnesota Government Data Practices Act (MGDPA). Several television stations brought an action under the MGDPA seeking access to the ballots, alleging that they were public government data under the MGDPA. The district court granted summary judgment to the stations. The court of appeals reversed, concluding that Minn. Stat. 13.37(2) unambiguously provided that sealed absentee ballots were nonpublic or private data under the MGDPA. The Supreme Court affirmed, holding (1) the plain language of section 13.37(2), when read in conformity when the MGDPA and statutes governing absentee voting, unambiguously classified unopened absentee ballots not counted in the 2008 general election as not public government data; and (2) because the absentee ballots were not public data, the stations were not entitled under the MGDPA to inspect and copy the disputed ballots. View "KSTP-TV v. Ramsey County" on Justia Law