Pennsylvania federal court rules election official should count undated mail-in ballots News
Lauren Ban // JURIST
Pennsylvania federal court rules election official should count undated mail-in ballots

A US federal court in Pennsylvania ruled that undated mail-in ballots must be counted in a Monday decision that could significantly influence future elections in the state. The decision further builds upon Pennsylvania’s ongoing legal battles over mail-in voting, which have been ongoing since the enactment of Act 77, a voting reform bill in the state.

The ruling comes from NAACP v. Schmidt. A group of plaintiff individual voters and several voting rights groups challenged the disqualification of mail-in ballots that lacked a handwritten date on their return envelopes. The plaintiffs argued that the state’s refusal to count these ballots amounted to a “meaningless technicality.”

In this case, the plaintiffs presented two primary arguments: that the law violated the Materiality Provision of the Civil Rights Act and an Equal Protection claim under the US Constitution’s Fourteenth Amendment.

For the Materiality Provision claim, the plaintiffs contended that the law’s requirement of a handwritten date next to the voter’s signature on mail ballots conflicted with the Materiality Provision. This provision safeguards voters by stipulating that their ballots cannot be rejected for errors or omissions that are not significant to determine whether they are qualified to vote. In this context, the plaintiffs maintained that a missing or incorrect date, which is not crucial for establishing voting eligibility, should not invalidate a ballot. 

The court agreed with the plaintiffs, holding that refusing to count votes due to a missing or incorrect date on the envelope violated the Materiality Provision.

Regarding the Equal Protection claim, the plaintiffs argued that Pennsylvania’s enforcement of the date requirement on mail-in ballot envelopes was inconsistently applied, affecting domestic voters differently than overseas and military voters. They argued, “For [overseas and military voters’] ballots, any mistake or omission in the completion of the ballot does not invalidate the ballots as long as the mistake or omission does not prevent determining whether a covered voter is eligible to vote.”

Nevertheless, the court chose not to proceed with this claim. Following the principle of judicial restraint—a legal principle where courts avoid ruling on broader constitutional issues when a case can be resolved on narrower grounds—the court found that the issue had already been adequately addressed under the Materiality Provision. This means the court decided the case on plaintiffs’ first claim. Therefore, it was deemed unnecessary to delve into the constitutional question of equal protection.

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