Purcell v. Gonzalez, 549 U.S. 1 (2006)
Primary Holding
The Supreme Court vacated the order of the Court of Appeals, emphasizing that the election procedures implemented under Proposition 200, which required proof of citizenship and identification for voting, were precleared under the Voting Rights Act and did not necessarily disenfranchise qualified voters.
In the case of Purcell v. Gonzalez, the Supreme Court decided that Arizona's voting rules, which required proof of citizenship and identification, were allowed under federal law. This is important because it means that states can implement measures to prevent voter fraud, as long as they don't unfairly stop qualified voters from casting their ballots. If you're a voter in Arizona or a similar state, this case is relevant because it clarifies that you may need to show ID when you vote, but there are ways to ensure you can still vote even if you forget your identification.
AI-generated plain-language summary to help you understand this case
In 2004, Arizona voters approved Proposition 200, which aimed to reduce voter fraud by mandating that voters provide proof of citizenship when registering and identification when voting on election day. The implementation of this law allowed voters without proper identification to cast a conditional provisional ballot, which could be counted if the voter presented valid identification within five business days. Additionally, voters could participate in early voting without needing to show identification, as their signatures would be verified against registration rolls. The dispute arose when a group of Arizona residents, including members of Indian tribes and various community organizations, filed a lawsuit in May 2006 challenging the identification requirements established by Proposition 200. The District Court denied their request for a preliminary injunction on September 11, 2006, but did not provide findings of fact or conclusions of law, which were necessary for the Court of Appeals to evaluate the case. Following this denial, the plaintiffs appealed and sought an injunction pending the appeal from the Court of Appeals, which was assigned to a two-judge motions panel. On October 5, 2006, the Court of Appeals issued an order enjoining the enforcement of Proposition 200's provisions without providing any explanation or justification. This order prompted the State of Arizona and county officials to seek relief from the injunction, leading to the Supreme Court's involvement. The Court ultimately granted the petitions from the State and county officials and vacated the order of the Court of Appeals, addressing the procedural issues surrounding the injunction.
Whether the Court of Appeals for the Ninth Circuit erred in issuing an interlocutory injunction that enjoined Arizona from enforcing Proposition 200's identification requirements pending appeal.
The order of the Court of Appeals is vacated, and the cases are remanded for further proceedings consistent with this opinion.
- Court
- Supreme Court
- Decision Date
- October 20, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
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