Thursday, November 7, 2013

Crawford v. Marion County Election Board case brief

Crawford v. Marion County Election Board case brief summary
128 S. Ct. 1610 (2008)


CASE SYNOPSIS
After Indiana enacted Senate Enrolled Act No. 483 (SEA 483) requiring citizens voting in person to present government-issued photo identification, petitioner voters and state political party filed separate suits challenging the law's constitutionality. The cases were consolidated. Respondent state officials were granted summary judgment which was affirmed by the United States Court of Appeals for the Seventh Circuit. Certiorari was granted.

CASE FACTS
The State of Indiana identified several state interests that arguably justified the burdens that SEA 483 imposed on voters and potential voters. The first interest was election modernization.

DISCUSSION
The Court noted both the National Voter Registration Act of 1993, 42 U.S.C.S. § 1973gg et seq., and the Help America Vote Act of 2002 contained provisions consistent with a state's choice to use government-issued photo identification as a relevant source of information concerning a citizen's eligibility to vote. The second interest was the risk of voter fraud. The Court held that there was no question about the legitimacy or importance of the State's interest in counting only the votes of eligible voters. It also held that inflated voter rolls provided a neutral and nondiscriminatory reason supporting the State's decision to require photo identification. While closely related to the State's interest in preventing voter fraud, public confidence in the integrity of the electoral process had independent significance, because it encouraged citizen participation in the democratic process. These interests were sufficient to outweigh the limited burden on voters' rights.

CONCLUSION
The judgment of the Seventh Circuit was affirmed. 6-3 decision; 1 concurrence; 1 dissent.

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