Minnesota Voters Alliance v. City of Minneapolis

Background

The plaintiffs were Minnesota Voters Alliance, a nonprofit corporation, and Ronald Moey, Marissa Skaja, Charles Halverson, and Blair Johnson. The individual plaintiffs were members of Minnesota Voters Alliance, Minneapolis residents, and eligible Minnesota voters. The defendant was the City of Minneapolis, which administers elections within the city.

The Center for Tech and Civic Life offered COVID-19 Response Grants to local election offices. Minneapolis applied for and was awarded $2,297,342. The City planned to use the money for election-related expenses, including absentee-ballot processing, early voting and ballot-drop-off options, polling-place materials, secure drop boxes, voter outreach and education, and protective equipment.

The plaintiffs filed a complaint asserting that the City acted without legal authority by accepting and using the grant. They relied on the Elections Clause, the Supremacy Clause, the Help America Vote Act, the National Voter Registration Act, and Minnesota’s criminal bribery statute. They asked the court to temporarily restrain the City from accepting or using the grant and any other private federal election grant.

Standing analysis

Before considering the requested injunction, the court addressed standing, which requires a plaintiff seeking court relief to show a concrete and personal injury that was caused by the defendant and could likely be remedied by a favorable order.

The court concluded that the plaintiffs had not shown an injury to their right to vote. They did not allege that they would be unable to cast a ballot or would have to choose between voting in unsafe conditions and not voting. The court found that the City’s grant-funded actions were intended to improve voting in Minneapolis for all eligible voters, including the individual plaintiffs, and that the plaintiffs had not explained how they would be uniquely affected.

The court characterized the plaintiffs’ allegations as a generalized grievance: an objection that the government had not followed the law, without a distinct personal injury. The court rejected the theory that making voting easier for all Minneapolis voters injured the plaintiffs because Minneapolis voters were statistically more likely to be progressive. It distinguished a case in which plaintiffs alleged that government action made voting inaccessible to some voters while favoring others. Here, the plaintiffs did not allege that Minneapolis targeted one group for encouragement and another for discouragement.

The court also addressed the plaintiffs’ reliance on several legal provisions. It determined that the Supremacy Clause and the Help America Vote Act did not provide the plaintiffs with a private right to sue. The court concluded that the plaintiffs were not within the group allowed to bring a private action under the National Voter Registration Act because they did not allege that their voting rights had been denied or impaired; the court also noted that Minnesota is exempt from that Act. Under Minnesota law, the criminal bribery statute did not create a private civil cause of action. The court stated that the existence of a private right of action, by itself, would not establish standing.

The court further found that Minnesota Voters Alliance lacked standing both in its own right and as a representative of its members. The organization identified no concrete injury separate from the alleged injury to its members, and its members themselves lacked standing.

Disposition

Because no plaintiff could establish standing, the court denied the Plaintiffs’ Motion for Temporary Restraining Order. The court expressly did not reach the merits—that is, it did not decide whether the plaintiffs’ underlying preemption and other legal claims were valid. The order did not enjoin the City from accepting or using the grant.