Common Cause Indiana v. Marion County Election Bd.

In section 1983 action alleging that defendant-election board’s decision to not approve in-person early voting satellite offices for elections taking place from 2010 to 2016 violated voters’ First and 14^th Amendment rights, Ct. of Appeals vacated Dist. Ct.’s Consent Decree that required defendant to establish five in-person early voting satellite offices for future general elections and two in-person early voting satellite offices for primary elections. Defendant changed voting scheme after issuance of Consent Decree, which replaced precinct-based structure at time of issuance of Consent Decree with vote center plan that required County to have two in-person early voting satellite offices for primary elections and six in-person early voting satellite offices for general elections. As such, Ct. found that vacatur of Consent Decree was required because both parties agreed that Decree should no longer be in effect given change in voting scheme.