Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Appellants brought an action against appellee, in his official capacity as Secretary of State of South Dakota, claiming violations of the First and Fourteenth Amendments related to appellants' efforts to place a candidate for governor on the 2010 ballot in South Dakota and challenged the constitutionality of two statutory provisions related to that process. At issue was whether appellants had standing to challenge S.D. Codified Laws 12-5-3(9), which permitted only in-state residents to circulate the petitions at issue ("Count II"), and whether the court erred in failing to strike it down as unconstitutional. The court held that all appellants lacked standing to challenge the constitutionality of the relevant statute and vacated the district court's judgment and remanded with instructions to dismiss Count II without prejudice for lack of jurisdiction.

Plaintiffs, three Minnesota-based grass roots advocacy organizations, challenged a Minnesota law that made it a crime to knowingly, or with reckless disregard for the truth, make a false statement about a proposed ballot initiative under the Minnesota Fair Campaign Practices Act ("FCPA"), Minn. Stat. 211.B06, subd.1. At issue was whether the district court erred when it dismissed plaintiffs' complaint for lack of jurisdiction; when it alternatively held that it would dismiss plaintiffs' complaint for failing to state a claim upon which relief could be granted; and when it denied plaintiffs' motion for summary judgment. The court held that plaintiffs' claims were justiciable and that subject matter jurisdiction was proper in federal court; that plaintiffs did allege First Amendment claims upon which relief could be granted; and that the district court's denial of plaintiffs' motion for summary judgment based on its findings of mootness was vacated. Therefore, the court remanded for additional development of arguments regarding whether section 211.b06 satisfied strict scrutiny.

The United States Secretary of Labor ("Secretary") appealed the district court's grant of summary judgment to Amalgamated Transit Union, Local 1005 ("Local 1005) on the claim that Local 1005's November 2008 election procedures violated the "adequate safeguards" provision of the Labor Management Reporting and Disclosure Act ("LMRDA"), 29 U.S.C. 481(c). At issue was whether the district court applied the wrong legal standard in its analysis and whether the district erred when it determined that Local 1005 did not violate the "adequate safeguards provision" of the LMRDA. The court held that the district court did not apply the wrong legal standard where the district court found no violation of section 481(c). The court also affirmed summary judgment and held that Local 1005's actions regarding the accurate announcement of the sole requirement to stand for elected office, coupled with the fully accurate notices posted both on Local 1005's job site bulletin and boards, as well as on its website, amounted to "adequate safeguards" under the LMRDA.