CINCINNATI, OH – The Sixth Circuit Court of Appeals has upheld the dismissal of a lawsuit filed by the Republican National Committee (RNC) that challenged Michigan’s maintenance of its voter rolls.
The RNC alleged that Michigan Secretary of State Jocelyn Benson and Bureau of Elections Director Jonathan Brater failed to make a reasonable effort to remove ineligible voters, including individuals who no longer lived in the state, in violation of the National Voter Registration Act. The lawsuit pointed to counties where the number of registered voters appeared to exceed the voting-age population.
The district court dismissed the case for lack of standing, and the appeals court agreed. Judges ruled that the RNC had not shown an imminent or “certainly impending” injury that would give it standing to pursue injunctive relief. The court noted that the RNC’s claims relied on the possibility it “may” misallocate resources or “may” incur expenses, which the court said was too speculative to establish a concrete injury.
The ruling also rejected the RNC’s argument that the dismissal was improper without giving it a chance to amend its complaint, noting that the committee had the opportunity to amend earlier but did not. Because the case was dismissed for lack of jurisdiction under Rule 12(b)(1), the court emphasized that the dismissal was without prejudice, leaving the RNC free to refile.
The decision affirms that Michigan’s voter roll maintenance practices will not face federal court intervention based on the RNC’s current allegations.
