People First of Alabama v. Merrill

The State of Alabama (Alabama) (defendant) had laws in place regarding nontraditional voting. The laws included (1) a requirement that a notary or two witnesses sign all absentee-ballot affidavits (witness requirement), (2) a requirement that absentee voters provide a copy of photo identification with absentee-ballot applications (ID requirement), and (3) a de facto ban on curbside voting (curbside ban). During 2020, the COVID-19 pandemic raised worries about public-health risks during in-person voting. Alabama Secretary of State John Merrill (defendant) chose to enforce the absentee and curbside provisions during pandemic elections. People First of Alabama, other organizations, and several Black, disabled, and elderly citizens (collectively, the impacted parties) (plaintiffs) sued Alabama, Merrill, and other Alabama officials, claiming that Alabama’s absentee and curbside requirements disenfranchised voters by forcing them to risk COVID-19 exposure in order to vote. The impacted parties sought an injunction preventing enforcement of voting provisions for the November 2020 election. The court issued many findings of fact detailing the negative effects and health risks posed by COVID-19, Alabama’s measures to stop the virus’s spread, Alabama’s history of disenfranchising Black, elderly, and disabled voters through unfair voting requirements, and the increased health risks COVID-19 posed to elderly and disabled individuals. The court further discussed societal and systemic issues that led to Black voters facing higher health risks and being impacted more significantly by the voting provisions. The issues included a history of segregation, a lack of economic resources, insufficient infrastructure in Black communities, and predatory lending. The court then addressed whether enforcing the voting requirements violated citizens’ fundamental right to vote under the First and Fourteenth Amendments as well as other federal statutes.