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People First of Alabama v. Merrill
United States District Court for the Northern District of Alabama
491 F. Supp. 3d 1076 (2020)
The State of Alabama (state) (defendant) had laws in place regarding nontraditional voting. The provisions included (1) a requirement that a notary or two witnesses sign all absentee-ballot affidavits, (2) a photo-identification requirement for all absentee-ballot applications, and (3) an effective ban on curbside voting. During 2020, the COVID-19 pandemic raised substantial public-health concerns, including worries about public-health risks during in-person voting for elections. Alabama Secretary of State John Merrill (defendant) chose to enforce the absentee- and curbside-voting provisions during pandemic elections. People First of Alabama (plaintiff), as well as several individual Black, disabled, and elderly citizens (plaintiffs) filed suit in federal district court, claiming that the state’s absentee and curbside provisions disenfranchised the people of Alabama and infringed on their constitutional right to vote by forcing them to risk COVID-19 exposure in order to vote. The citizens filed for declaratory judgment and an injunction to prevent enforcement of the provisions for the November 2020 election. Through briefs and testimony, the court issued many findings of fact detailing the negative effects and health risks posed by COVID-19, the state’s measures to stop the spread of the virus, the state’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 Alabama voters being at higher health risk and less likely to be able to meet the absentee and curbside provision requirements. These issues included a history of segregation, redlining, lack of economic resources, insufficient infrastructure in Black communities, predatory lending, and refusal by state legislators to expand Medicaid or increase insurance options. The court then addressed whether enforcing the voting requirements violated the citizens’ constitutional rights.
Rule of Law
Holding and Reasoning (Kallon, J.)
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