Purcell v. Gonzalez was mentioned in the decision below as a case stating that voting is a fundamental political right (though that is not clearly stated anywhere in the Constitution).
The Purcell case cites Dunn v. Blumstein as the source of the precedence.
Here background on both cases, both from Oyez.
- Click here for Purcell v. Gonzalez.
Facts of the case: In 2002, Arizona passed Proposition 200, which required a photo ID for voter registration. The Election Assistance Commission (EAC) notified Arizona’s Secretary of State that Proposition 200 conflicted with the National Voter Registration Act (NVRA) regarding the need for photo ID as proof of citizenship for mailed voter registration forms. Shortly thereafter, the plaintiffs — Arizona residents, Indian tribes, and community organizations — filed a restraining order to prevent the state of Arizona from enforcing the new rules for voter registration. The petition for a restraining order was denied by the district court. The plaintiffs appealed to the U.S. Court of Appeals for the Ninth Circuit and argued that it should grant an emergency injunction based on the fact that elections were about to begin. The appellate court granted the injunction to stop the enforcement of Proposition 200.
Question: Did the U.S. Court of Appeals for the Ninth Circuit err in granting an emergency injunction regarding Proposition 200 close to election time?
Conclusion: In a per curiam decision, the Court held that the U.S. Court of Appeals for the Ninth Circuit erred in granting an injunction against the enforcement of Proposition 200. Because the lower court’s decision lacked any information regarding how it came to its conclusion, the Supreme Court could not properly assess this decision, so it ordered that the case be remanded.
Justice John Paul Stevens wrote a concurring opinion in which he agreed because there was no discussion of the rationale for requiring identification for voter registration.
- Click here for Dunn v. Blumstein.
Facts of the case: A Tennessee law required a one-year residence in the state and a three-month residence in the county as a precondition for voting. James Blumstein, a university professor who had recently moved to Tennessee, challenged the law by filing suit against Governor Winfield Dunn and other local officials in federal district court.
Question: Did Tennessee's durational residency requirements violate the Equal Protection Clause of the Fourteenth Amendment?
Conclusion: In a 6-to-1 decision, the Court held that the law was an unconstitutional infringement upon the right to vote and the right to travel. Applying a strict equal protection test, the Court found that the law did not necessarily promote a compelling state interest. Justice Marshall argued in the majority opinion that the durational residency requirements were neither the least restrictive means available to prevent electoral fraud nor an appropriate method of guaranteeing the existence of "knowledgeable voters" within the state.
