Snyder v. King

Dist. Ct. did not err in dismissing plaintiff’s section 1983 action against defendants-state and county election officials alleging that defendants’ notification that plaintiff’s voter registration had been temporarily cancelled due to his incarceration pursuant to Indiana statute violated National Voter Registration Act, as well as Help America Vote Act and Civil Rights Act of 1964. Sovereign Immunity barred plaintiff from suing state defendants, and plaintiff failed to state cause of action against county defendants where: (1) plaintiff failed to allege any causal link between county policy and alleged deprivation; and (2) county’s removal of plaintiff from voter registration roll was act based solely on state statute. As such, county defendants were not “persons” for purposes of plaintiff maintaining lawsuit under section 1983.