Establishing Legislative Standing: Michigan Supreme Court Affirms Legislature’s Right to Defend Election Laws

Establishing Legislative Standing: Michigan Supreme Court Affirms Legislature’s Right to Defend Election Laws

1. Introduction

The Michigan Supreme Court, in the case League of Women Voters of Michigan v. Secretary of State (506 Mich. ___, 2020), addressed critical questions surrounding legislative standing and the constitutionality of amendments made to the Michigan Election Law (2018 PA 608). This case involved the League of Women Voters of Michigan (LWV) alongside other plaintiffs challenging modifications to petition drive procedures, including signature distribution limits, mandatory checkboxes for petition circulators, and affidavit requirements for paid circulators. Concurrently, the Michigan Legislature sought to defend the legality of these amendments, leading to a complex legal battle over who held the standing to contest or uphold these changes in court.

2. Summary of the Judgment

The Michigan Supreme Court held that while the Legislature has standing to appeal when the Attorney General declines to defend a statute against constitutional challenges, the specific case at hand became moot when one of the lead plaintiffs, Michiganders for Fair and Transparent Elections (MFTE), ceased its petition efforts due to the COVID-19 pandemic. Consequently, no other plaintiff retained standing, leading the Court to vacate lower-court decisions in the LWV case. Additionally, the Court affirmed the Court of Appeals' ruling that the Legislature lacked standing in its own separate action against the Secretary of State, ultimately directing the dismissal of both cases.

3. Analysis

3.1 Precedents Cited

The Court referenced several key precedents in determining legislative standing and mootness:

  • Federated Ins Co v Oakland Co Rd Comm: Established that an intervenor must be an aggrieved party to maintain a justiciable controversy.
  • Lujan v Defenders of Wildlife: Outlined the requirements for standing, emphasizing the need for concrete and particularized injuries.
  • Meyer v Grant: Addressed the mootness doctrine, particularly in election-related cases where issues may recur yet evade judicial review.
  • United States v Windsor and Immigration & Naturalization Service v Chadha: Discussed legislative standing when the executive branch refuses to defend a statute.
  • Paquin v City of St Ignace: Reinforced the principles of mootness in election contexts.

These precedents collectively influenced the Court's approach to assessing both standing and mootness, particularly in the specialized context of election law disputes.

3.2 Legal Reasoning

The Court's legal reasoning can be broken down into several key components:

3.2.1 Legislative Standing

The Court determined that the Legislature possesses standing to appeal when the Attorney General opts not to defend a statute against constitutional challenges. This recognition stems from the Legislature's inherent interest in defending its enacted laws and ensuring their proper application. By intervening, the Legislature can uphold the legislative intent behind the statutes in question.

3.2.2 Mootness

The cessation of MFTE's petition drive rendered the case moot regarding their involvement, as there was no longer an active controversy requiring judicial intervention. Furthermore, since no other plaintiffs retained standing, the overall case lost its justiciable controversy. The Court emphasized that mootness decisions must consider whether a live controversy exists and whether the issue is likely to recur yet evade review.

3.2.3 Impact of Lower Courts' Decisions

The Court acknowledged procedural irregularities in the lower courts, including the lack of standing for the Legislature in one case and the mootness in the other. Given these factors, the Supreme Court found it equitable to vacate the lower-court decisions and remand the cases for dismissal, thereby maintaining the integrity of judicial processes.

3.3 Impact

This judgment has significant implications for future legislative and election law cases in Michigan:

  • Legislative Oversight: Affirms the Legislature's ability to defend its statutes independently when executive branches do not.
  • Election Law Compliance: Clarifies the boundaries of petition drive regulations and the legal mechanisms for contesting them.
  • Judicial Process: Reinforces the doctrines of standing and mootness, ensuring that courts address only live and justiciable controversies.

By establishing that the Legislature can intervene in cases where executive branches abstain from defending statutes, the decision ensures that legislative intent is safeguarded, preventing executive overreach or neglect from undermining enacted laws.

3.4 Legal Reasoning

The Court meticulously applied established legal doctrines to the unique circumstances of the case, concluding that:

  • The Legislature had the right to intervene and possess standing due to its vested interest in upholding the 2018 PA 608 amendments.
  • The case became moot for MFTE following the suspension of its petition drive, removing the active controversy necessary for judicial consideration.
  • The remaining plaintiffs (LWV and individual voters) lacked standing as they could not demonstrate a concrete and particularized injury, adhering to the Lujan framework.

This structured application of law underscores the Court's commitment to separating judicial decisions from political disputes while ensuring that legitimate legislative interests are protected.

4. Complex Concepts Simplified

4.1 Standing

Standing is a legal principle that determines whether a party has the right to bring a lawsuit to court. To have standing, a plaintiff must demonstrate that they have suffered a concrete and particularized injury that can be addressed by the court. In this case, the Michigan Legislature's standing was affirmed when the Attorney General chose not to defend the statute, indicating a direct interest in the outcome.

4.2 Mootness

Mootness occurs when the issues at stake in a lawsuit are no longer "live" or the parties involved no longer have a stake in the outcome. Here, the plaintiff MFTE's suspension of its petition drive meant that the specific controversy no longer existed, rendering part of the case moot.

4.3 Declaratory Judgment

A declaratory judgment is a court ruling that clarifies the rights and obligations of the parties without ordering any specific action or awarding damages. The plaintiffs sought a declaratory judgment to declare parts of the Election Law unconstitutional, aiming to guide future petition drives.

5. Conclusion

The Michigan Supreme Court's decision in League of Women Voters of Michigan v. Secretary of State is a landmark ruling affirming the Legislature's standing to defend its statutes in court when the executive branch chooses not to. By vacating lower-court decisions due to mootness and lack of standing among remaining plaintiffs, the Court underscored the importance of having live, justiciable controversies before judicial intervention. This judgment not only clarifies the interplay between legislative and executive branches in judicial settings but also ensures that legislative intent is preserved, thereby maintaining the balance of powers within the state government. Future cases involving election law amendments and legislative standing will undoubtedly reference this decision, shaping the landscape of Michigan's legal and electoral processes.

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