Wednesday, May 09, 2018

https://my.indy.gov/activity/voter-photo-id-law

A voter who is indigent or has a religious objection to being photographed may cast a provisional ballot that will be counted only if she executes an appropriate affidavit before the circuit court clerk within 10 days following the election. §§3–11.7–5–1, 3–11.7–5–2.5(c) (West 2006).[Footnote 2] A voter who has photo identification but is unable to present that identification on election day may file a provisional ballot that will be counted if she brings her photo identification to the circuit county clerk’s office within 10 days.

 Finally, in a provision entitled “Fail-safe voting,” HAVA authorizes the casting of provisional ballots by challenged voters. §15483(b)(2)(B).

A photo identification requirement imposes some burdens on voters that other methods of identification do not share. For example, a voter may lose his photo identification, may have his wallet stolen on the way to the polls, or may not resemble the photo in the identification because he recently grew a beard. Burdens of that sort arising from life’s vagaries, however, are neither so serious nor so frequent as to raise any question about the constitutionality of SEA 483; the availability of the right to cast a provisional ballot provides an adequate remedy for problems of that character.A photo identification requirement imposes some burdens on voters that other methods of identification do not share. For example, a voter may lose his photo identification, may have his wallet stolen on the way to the polls, or may not resemble the photo in the identification because he recently grew a beard. Burdens of that sort arising from life’s vagaries, however, are neither so serious nor so frequent as to raise any question about the constitutionality of SEA 483; the availability of the right to cast a provisional ballot provides an adequate remedy for problems of that character.

Both evidence in the record and facts of which we may take judicial notice, however, indicate that a somewhat heavier burden may be placed on a limited number of persons. They include elderly persons born out-of-state, who may have difficulty obtaining a birth certificate;[Footnote 18] persons who because of economic or other personal limitations may find it difficult either to secure a copy of their birth certificate or to assemble the other required documentation to obtain a state-issued identification; homeless persons; and persons with a religious objection to being photographed. If we assume, as the evidence suggests, that some members of these classes were registered voters when SEA 483 was enacted, the new identification requirement may have imposed a special burden on their right to vote.
   The severity of that burden is, of course, mitigated by the fact that, if eligible, voters without photo identification may cast provisional ballots that will ultimately be counted. To do so, however, they must travel to the circuit court clerk’s office within 10 days to execute the required affidavit. It is unlikely that such a requirement would pose a constitutional problem unless it is wholly unjustified. And even assuming that the burden may not be justified as to a few voters,[Footnote 19] that conclusion is by no means sufficient to establish petitioners’ right to the relief they seek in this litigation.


 (c) If:
        (1) the voter is unable or declines to present the proof of identification; or
        (2) a member of the precinct election board determines that the proof of identification provided by the voter does not qualify as proof of identification under IC 3-5-2-40.5;
a member of the precinct election board shall challenge the voter as prescribed by this chapter.
    (d) If the voter executes a challenged voter's affidavit under section 22 of this chapter, the voter may:
        (1) sign the poll list; and
        (2) receive a provisional ballot.


(j) In case of doubt concerning a voter's identity, the precinct election board shall compare the voter's signature with the signature on the affidavit of registration or any certified copy of the signature provided under IC 3-7-29. If the board determines that the voter's signature is authentic, the voter may then vote. If either poll clerk doubts the voter's identity following comparison of the signatures, the poll clerk shall challenge the voter in the manner prescribed by section 21 of this chapter.

That the State accommodates some voters by permitting (not requiring) the casting of absentee or provisional ballots, is an indulgence—not a constitutional imperative that falls short of what is required. - scalia






Monday, May 07, 2018

https://www.brennancenter.org/sites/default/files/legal-work/fa3a4f2682405f5e42_jbm6bhn9i.pdf

Judge declines to interfere with voter ID law

October 22, 2008


A federal judge in Indianapolis won't interfere with the state law requiring voters to show photo identification at the election polls.
On Tuesday, U.S. District Judge Larry McKinney denied a temporary injunction request from a Cumberland attorney and resident who is challenging Indiana's 3-year-old voter ID law that's been upheld by the Supreme Court of the United States.
Plaintiff Robbin G. Stewart filed the suit in April in Marion County, though it was later removed to the U.S. District Court, Southern District of Indiana, to resolve the multiple federal and state constitutional claims. In September, Stewart asked the judge for one of three potential relief options: that he be allowed to vote without showing the required photo ID; that the state and county be required to count all provisional ballots cast by those not showing photo ID; or that the state not be allowed to enforce the voter ID law during the Nov. 4 general election.
Judge McKinney heard arguments Oct. 14 in Robbin Stewart v. Marion County, et al., No. 1:08-cv-586-LJM-TAB, and took the matter under advisement.
In his 10-page ruling, Judge McKinney rejected each of Stewart's arguments and found that he didn't represent a class of any similarly situated Hoosier voters and that he didn't adequately show any hardship in obtaining a photo ID. The court referenced how Stewart himself had obtained a valid license, and that meant he can vote and wouldn't suffer any irreparable injury by this injunction denial.
Turning to the landmark ruling issued earlier this year in Crawford v. Marion County Election Board, 128 S.Ct. 1610 (2008), Judge McKinney noted the reasoning in that facial challenge case applies to Stewart, even though he'd asserted this as an as-applied challenge that survives the Crawford scrutiny.
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"Plaintiff has not designated any evidence to demonstrate a burden that, on balance, outweighs the State's interest in protecting against voter fraud," the judge wrote.
Judge McKinney also rejected Stewart's federal constitutional claims that the state law violates the First and 21st Amendments, finding that the 7th Circuit Court of Appeals in Chicago had explicitly held in Crawford that the law isn't a poll tax and that all courts had decided it didn't violate the First Amendment.
On a claim that the law violates the Fourth Amendment on search and seizures, the judge pointed out that Stewart did not cite a single case holding that poll workers must have probable cause before requiring voters to produce a valid photographic ID, and as a result he didn't show he could win on that claim.
The judge also rejected Stewart's state constitutional claims, finding that he didn't cite adequate legal authority and has not demonstrated any likelihood of success on the merits.
"I'm disappointed but not shocked," Stewart said about the judge's ruling. "The case is still alive; it's not like he dismissed it or anything. The next step is to take this to the 7th Circuit for some preliminary relief."
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Plaintiff loses federal challenges to voter ID law

April 19, 2010


A federal judge ruled against a Cumberland man in his federal challenge to Indiana's voter identification law, but did remand his pending state claims to a Marion Superior Court for consideration.
U.S. District Judge Larry J. McKinney in the Southern District of Indiana granted summary judgment April 16 for Marion County, Marion County Clerk Beth White, and the State of Indiana in Robbin Stewart's lawsuit challenging Indiana's statutory requirement that a person voting at the polls has to present a government-issued photo ID. Stewart has an acceptable form of identification but believes having to present it violates his rights.
Stewart argued in Robbin Stewart v. Marion County, et al., No. 1:08-CV-586, that the voter ID law violates the First, Fourth, 14th and 24th amendments of the U.S. Constitution. His challenges based on the First and 14th amendments are foreclosed by Indiana Democratic Party v. Rokita, 458 F. Supp.2d 775 (S.D. Ind. 2006), and Crawford v. Marion County Election Board, 553 U.S. 181 (2008). His challenge that the voter ID law is a poll tax also failed because the 7th Circuit already noted that it's not a poll tax in Crawford.
"Stewart already has a driver's license, which is a valid form of photo identification. Therefore, he has not been required to incur any extra costs to obtain a valid photo identification to present when voting and does not have standing to challenge any alleged fees which might be incurred by a person not similarly equipped with photo identification," wrote Judge McKinney.
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Stewart's Fourth Amendment challenge failed because those rights aren't affected. Stewart had a choice when voting in person - present his driver's license and vote, or refuse to present it and choose to cast or not cast a provisional ballot. The encounter was consensual and had no impact on his rights, wrote the judge.
"Even if requiring identification at the polls does constitute a search, it still does not violate the Fourth Amendment," wrote Judge McKinney. "... the State of Indiana has an important interest in preventing voter fraud. Asking every voter who appears at the polls for identification in a consistent manner is a lawful means of serving this interest."
The federal judge decided not to exercise supplemental jurisdiction over Stewart's pending claims under Indiana state law and remanded the case to Marion Superior Court for consideration. Last year, the Indiana Court of Appeals held that the voter ID law violates Article 1, Section 23 of the Indiana Constitution in League of Women Voters of Indiana, et al. v. Rokita, 915 N.E.2d 151 (Ind. Ct. App. 2009). The case is currently pending before the Indiana Supreme Court, which heard arguments in the case March 4.
Stewart, an attorney, was suspended in May 2009 for not fulfilling CLE requirements.