Miller v. Newsom
- Beth Freeman
- 5:20-cv-08021
- U.S. District Court · Northern District of California
- 3
In Miller v. Newsom, Judge Freeman dismissed Miller’s voting-rights lawsuit with prejudice, ruling that prisoner disenfranchisement did not state a constitutional claim.
The ruling affected Isaac A. Miller’s federal lawsuit challenging the loss of his right to vote while serving a sentence in state prison.
What happened
Isaac A. Miller, a state inmate, sued California Governor Gavin Newsom under a federal civil-rights law, claiming that losing his right to vote violated the Fourteenth Amendment. He sought restoration of his voting rights.
The court explained that the Fourteenth Amendment allows states to restrict voting because of a criminal conviction. It also noted that California’s Constitution denies prisoners and parolees the right to vote. Because Miller was serving a sentence in state prison, the court found that his disenfranchisement was lawful.
The court dismissed the complaint with prejudice for failure to state a claim and found that amendment would be futile. Judge Beth Labson Freeman issued the order on March 19, 2021.
The detailed version
- Miller v. Newsom · No. 5:20-cv-08021
- Beth Freeman
- Mar. 19, 2021
Background
Isaac A. Miller, identified in the opinion as a state inmate, filed a lawsuit without a lawyer under 42 U.S.C. § 1983. He sued California Governor Gavin Newsom, alleging that the deprivation of his right to vote violated the Fourteenth Amendment. Miller stated that inmates had historically voted regularly and asked the court to restore his voting right, along with other rights or immunities that might apply.
The court noted that Miller’s motion for permission to proceed without paying the filing fee would be addressed in a separate order.
Screening and analysis
Because Miller was a prisoner suing a government officer, the court was required to conduct an initial screening under 28 U.S.C. § 1915A. That statute requires dismissal of claims that are frivolous, malicious, fail to state a claim, or seek money damages from an immune defendant. The court also stated that filings by people without lawyers must be read liberally.
The court concluded that Miller’s complaint failed to state a claim. Section 2 of the Fourteenth Amendment expressly allows the right to vote to be restricted because of participation in a crime. The court relied on the Supreme Court’s decision in a prior related proceeding, which held that laws disenfranchising people convicted of crimes were not inconsistent with the Fourteenth Amendment’s equal-protection guarantee, including under the California law then at issue. The court further stated that California’s Constitution currently denies prisoners and parolees the right to vote.
Because Miller’s complaint indicated that he was a convicted felon serving a sentence in state prison, the court determined that his disenfranchisement was lawful under both the Fourteenth Amendment and the California Constitution.
Disposition
The court dismissed the complaint with prejudice for failure to state a claim for which relief could be granted. It also concluded that there was no set of facts Miller could allege that would cure the complaint’s deficiencies, making amendment futile. Judge Beth Labson Freeman signed the order of dismissal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.