Introduction

The case of Bonnie Raysor, et al. v. Ron DeSantis, Governor of Florida, et al. (140 S. Ct. 2600) presents a significant judicial examination of voter disenfranchisement through financial barriers. This commentary analyzes Justice Sonia Sotomayor's dissenting opinion in the Supreme Court of the United States, dated July 16, 2020. The central issue revolves around Florida's "pay-to-vote" scheme, which mandates individuals with felony convictions to pay all fines, fees, and restitution before regaining their voting rights. The dissent highlights concerns about wealth discrimination and the broader implications for voting rights in the United States.

Summary of the Judgment

In this case, Justice Sotomayor dissenting from the majority's decision to deny the application to vacate a stay placed by the Eleventh Circuit. The stay effectively suspended a District Court's permanent injunction against Florida's pay-to-vote system. Sotomayor argued that this decision unjustly prevents thousands of eligible voters from participating in Florida's primary elections due to financial constraints. She emphasized that the stay undermines established legal protections and disrupts the voting process shortly before the primary election.

Analysis

Precedents Cited

Justice Sotomayor references several key precedents to bolster her argument:

• Purcell v. Gonzalez, 549 U.S. 1 (2006): Established the fundamental political right to vote, emphasizing that any legislation affecting voting rights must be scrutinized meticulously.
• Jones v. Governor of Florida, 950 F.3d 795 (CA11 2020): Involved the initial challenge to Florida's voter restoration amendment, which Sotomayor uses to illustrate the ongoing legal battles surrounding voting rights for individuals with felony convictions.
• Coleman v. Paccar Inc., 424 U.S. 1301 (1976): Outlined the criteria under which the Supreme Court may vacate an appellate court stay, which Sotomayor argues the Eleventh Circuit failed to meet.
• Frank v. Walker, 574 U.S. 929 (2014): Demonstrates instances where the Supreme Court has exercised its discretion to vacate appellate stays in voting rights cases, supporting Sotomayor's stance.

Legal Reasoning

Sotomayor's legal reasoning centers on the Equal Protection Clause, the Due Process Clause, and the Twenty-fourth Amendment. She contends that Florida's requirement for paying all legal financial obligations (LFOs) before voting imposes an unconstitutional wealth barrier. The court had previously found that many individuals genuinely cannot afford these payments, thereby discriminating against the economically disadvantaged. Additionally, the procedural complexities and unreliable state records exacerbate the disenfranchisement, violating due process by impeding individuals' ability to understand their obligations and consequences fully.

Furthermore, Sotomayor highlights the failure of the Eleventh Circuit to provide a reasoned basis for the stay, arguing it contradicts established precedents and undermines the District Court's factual findings. She emphasizes that the Eleventh Circuit's decision disregards the disproportionate impact on impoverished voters and fails to adhere to the standard of deference owed to lower court rulings.

Impact

The dissenting opinion underscores the potential for significant voter disenfranchisement. By allowing the stay, the majority decision could prevent nearly a million eligible voters from exercising their fundamental right to vote. This outcome not only affects individual voters but also has broader implications for the integrity of the electoral process in Florida and potentially other states instituting similar measures.

Additionally, the judgment signals a reluctance of the Supreme Court to intervene in cases of alleged voting rights violations, which could embolden states to implement restrictive voting laws without fear of immediate judicial overturning. This could lead to increased instances of wealth-based voting barriers nationwide, exacerbating existing inequalities in the electoral system.

Complex Concepts Simplified

Equal Protection Clause

Part of the Fourteenth Amendment, it requires states to provide equal protection under the law to all people within their jurisdictions. In this case, it challenges laws that unjustly discriminate based on economic status.

Due Process Clause

Also part of the Fourteenth Amendment, it ensures that legal proceedings are fair and that individuals are given notice and an opportunity to be heard before being deprived of life, liberty, or property.

Twenty-fourth Amendment

Prohibits the requirement of a poll tax for voting in federal elections. The court in this case interprets Florida's payment requirements as a form of tax, thereby violating this amendment.

Legal Financial Obligations (LFOs)

These are fines, fees, and restitution that individuals must pay as part of their criminal sentencing. Florida's law requires that all LFOs be paid in full before an individual can regain voting rights, which poses significant financial barriers.

Conclusion

Justice Sotomayor's dissent in Bonnie Raysor, et al. v. Ron DeSantis serves as a crucial critique of measures that tie voting rights to financial obligations. By highlighting the unconstitutional aspects of Florida's pay-to-vote scheme, the dissent underscores the fundamental principle that the right to vote should not be contingent upon an individual's economic status. This judgment calls for a reevaluation of policies that inadvertently disenfranchise the economically disadvantaged, ensuring that voting remains an inclusive and equitable right for all eligible citizens.