On August 7, The Minnesota Supreme Court affirmed the district court’s ruling in Minnesota Voters Alliance, et al., Appellants, vs. Tom Hunt, et al.
The tax payers along with the association to which they all belong, the Minnesota Voters Alliance, attempted to block the Re-Enfranchisement Act which was signed into law in 2023. The Court held that the plaintiffs did not have standing.
What is the Re-Enfranchisement Act?
The Re-Enfranchisement Act of Minnesota went into effect June 1, 2023, and allowed convicted felons who were no longer incarcerated to regain their voting rights. This law affects more than 55,000 Minnesotans.
Previously, Minnesota Statutes section 201.014, which outlines the eligibility to vote required convicted felons to complete their parole before they were eligible to regain their voting rights.
Upon signing the act into law, Minnesota Gov. Tim Walz said, “The idea of not allowing these voices to have a say in the very governing of the community they live in is unacceptable.”
The Case Background
The taxpayers and the Minnesota Voters Alliance filed their declaratory judgment on June 29, 2023, alleging that the Minnesota Constitution only allows felons the right to vote if all their civil rights (plural) were restored. The Re-Enfranchisement Act only restores the single right to vote rather than all civil rights.
Additionally, they argued that since the voting provision is against the Minnesota Constitution, it illegally uses public funds (as the Act also provided for a public education campaign to inform people of the expanded voting rights).
The district court ruled that they didn’t have standing.
“The court determined that the Taxpayers failed to satisfy this requirement because they ‘d[id] not challenge a specific disbursement of public funds,’ but instead, used the Legislature’s appropriations as ‘a mere jumping-off point’ ‘to challenge something that has nothing to do with money: namely, the eligibility of some citizens to vote.'”
Additionally, the district court “rejected the Taxpayers’ argument that ‘any incidental expenditure of public funds related to the implementation of a law confers standing on any taxpayer who wishes to bring a lawsuit challenging any aspect of that law.'”
The district court explained that to grant standing in this case “would render the very concept of taxpayer standing meaningless [as] practically every law entails at least some public expenditure.”
The Minnesota Supreme Court Ruling
The Minnesota Supreme Court accelerated the review of this case.
The Court determined that the requirements for taxpayer standing (“Taxpayers without a direct or personal injury may still have standing to bring an action to restrain the unlawful use of public funds.” McKee v. Likins) were not met in this case.
In the opinion, penned by Chief Justice Natalie Hudson, the Court dove into previous cases surrounding taxpayer standing including Oehler v. City of St. Paul (1928), Regan v. Babcock (1933), McKee v. Likins (1977), and In re Sandy Pappas Senate Committee (1992).
The Court stated, “Today, we clarify that taxpayer standing does not exist when a taxpayer simply seeks to generally restrain ‘illegal action[s] on the part of public officials.’ Instead, we recognize taxpayer standing only when the central dispute involves alleged unlawful disbursements of public funds.”
The Court shared the same concerns as the district court. “We instead hold that when standing would not otherwise exist to challenge a substantive law, a taxpayer cannot manufacture standing by pointing to expenditures that are incidental to implementing the law.”
Source: Minnesota Supreme Court
