A three-judge panel from the US Court of Appeals for the Eleventh Circuit has dismissed a lawsuit by the Alabama NAACP that alleged that the state’s 2011 Photo Voter Identification Law was unconstitutional. The law requires voters to present a form of photo identification at the polls.
The state chapter of the NAACP filed the suit in 2015 against Alabama Secretary of State, John H. Merrill, arguing that the law was racially discriminatory, violated the Voting Rights Act, and was unconstitutional. US District Judge L. Scott Coogler dismissed the NAACP’s lawsuit in 2018, concluding that the law was not racially discriminatory and was enacted to combat voter fraud.
US Circuit Judge Elizabeth Branch wrote Tuesday’s 76-page opinion. In the decision, she stated that the Plaintiffs’ lacked “a showing of evidence necessary to demonstrate the ‘sort of causal connection between racial bias and disparate effect necessary to make a vote-denial claim.'” Accordingly, both Judge Branch and Senior US Circuit Judge Ed Carnes decided to affirm the district court’s decision to dismiss the case.
US District Judge Darrin Gayles dissented, arguing that the in-person voter fraud the law purports to combat is “virtually non-existent.” Judge Gayles also questioned the majority and district court’s discounting of the law’s purpose by challenging the importance of definitive evidence in this case. He suggested that “In modern-day America, it is unusual to have such clear evidence that legislative leaders and sponsors of legislation are motivated by racial discrimination.”
Secretary Merrill released a statement following the court’s ruling celebrating the decision as a victory for Alabama voters:
Photo ID is required when purchasing alcohol or tobacco products, operating a motor vehicle, checking into a flight, purchasing a gun, or booking a hotel. Voting is equally or more important than all of these other examples where a photo ID is required.