Common Cause Indiana v. Lawson

Dist. Ct. erred in granting plaintiff’s request for preliminary injunction seeking to enjoin defendants’ enforcement of Indiana statute that limited circumstances for extending election polls’ closing hours, even though plaintiff argued that said statute burdened right to vote by creating multiple step process that left voter unable to petition court to extend poll hours. Defendants were entitled to stay of injunction pending appeal, since there was likelihood that defendants would succeed on appeal, since: (1) instant statute did not place burden on any Indiana resident’s constitutional right to cast ballot; and (2) nothing in instant statute restricted voters’ right to file section 1983 action to seek redress for any constitutional right to vote. Ct. also observed that Dist. Ct. should not have entered any election-related injunction only five weeks prior to November election day, especially where instant statute had been enacted more than one year prior to filing instant lawsuit.