CRAWFORD v. MARION COUNTY ELECTION BOARD

Legal Principle at Issue

Whether an Indiana law requiring voters to present a government-issued photo ID at the polls violated the Voting Rights Act or the Constitution's guarantee of the right to vote.

Action

Affirmed (includes modified). Petitioning party did not receive a favorable disposition.

Facts/Syllabus

After Indiana enacted an election law requiring citizens voting in person to present government-issued photo identification, the Indiana Democratic Party and the Marion County Democratic Central Committee filed suit in the federal District Court for the Southern District of Indiana against the state officials responsible for its enforcement, seeking a judgment declaring the voter ID law invalid and enjoining its enforcement. Following discovery, the District Court granted respondents summary judgment, finding the evidence in the record insufficient to support a facial attack on the statute’s validity. In affirming, the U.S. Court of Appeals for the Seventh Circuit declined to judge the law by the strict standard set for poll taxes in Harper v. Virginia Board of Elections (1966), finding the burden on voters offset by the benefit of reducing the risk of fraud.

A second suit seeking the same relief was brought on behalf of two elected officials and several nonprofit organizations representing groups of elderly, disabled, poor, and minority voters. The cases were consolidated, and the state of Indiana intervened to defend the validity of the statute. The complaints in the consolidated cases allege that the new law substantially burdens the right to vote in violation of the Fourteenth Amendment; that it is neither a necessary nor appropriate method of avoiding election fraud; and that it will arbitrarily disfranchise qualified voters who do not possess the required identification and will place an unjustified burden on those who cannot readily obtain such identification.