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National Federation of the Blind v. Lamone

813 F.3d 494 (2016)

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National Federation of the Blind v. Lamone

United States Court of Appeals for the Fourth Circuit
813 F.3d 494 (2016)

  • Written by Alexander Hager-DeMyer, JD

Facts

Maryland allowed any voter to vote via absentee ballot. Voters obtained blank ballots through mail or online printing that had to be marked by hand, signed, and submitted by mail or hand-delivery. Maryland had been developing an online ballot-marking tool that would allow absentee voters to electronically mark their ballots before printing, signing, and returning them. The tool’s accessibility was improved with the help of several organizations, including the National Federation of the Blind (federation) (plaintiff), and was deemed secure by an independent auditor. Another independent company seconded the audit, but the Maryland Board of Elections (board) (defendant) refused to take a certification vote on the tool as required by law. The federation and individual disabled voters sued Linda Lamone (defendant), the Maryland administrator of elections, and the board in federal court, arguing that the absentee-voting process violated Title II of the Americans with Disabilities Act (ADA). Evidence presented at trial showed that disabled voters could not vote privately and independently in the current process, and the district court found that the proposed modification of the online-voting tool was reasonable and did not fundamentally alter the voting program. The board appealed to the Fourth Circuit.

Rule of Law

Issue

Holding and Reasoning (Floyd, J.)

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