Frank v. Walker

819 F.3d 384 (2016)

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Frank v. Walker

United States Court of Appeals for the Seventh Circuit
819 F.3d 384 (2016)

  • Written by Liz Nakamura, JD

Facts

In 2011, Wisconsin passed a law requiring all voters to present photo identification in order to vote (the photo-ID law). Voters who had difficulty obtaining acceptable photo ID, led by Ruthelle Frank (collectively, the voters) (plaintiffs) sued Scott Walker (Wisconsin) (defendant), the governor of Wisconsin, to enjoin the application of the photo-ID law. The district court held that the photo-ID law was unconstitutional and issued a permanent injunction, holding that because some voters would face difficulties obtaining a photo ID, Wisconsin could not require any voter to present a photo ID in order to vote. On appeal, the Seventh Circuit reversed and remanded. On remand, the voters conceded that the photo-ID law was constitutional as applied to most voters but sought relief for those voters for whom obtaining an acceptable photo ID would be difficult or impossible due to name mismatches on official records, lost vital records, or other serious difficulties. The district court dismissed the voters’ claims, holding that their arguments had already been addressed and resolved in the prior Seventh Circuit order. The voters appealed to the Seventh Circuit, arguing that the Seventh Circuit’s prior order did not prevent the district court from ruling on their claims for relief.

Rule of Law

Issue

Holding and Reasoning (Easterbrook, J.)

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