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![handle is hein.congcourts/usflcne0001 and id is 1 raw text is: CASE STUDIES IN EMERGENCY ELECTION LITIGATION
Unsuccessful Challenge
to Ohio's Changed Primary Election Procedures
During the COVID-19 Pandemic
League of Women Voters of Ohio v. LaRose
(Michael H. Watson, S.D. Ohio 2:20-cv-1638)
A district judge found that Ohio's primary election accommodations
for the 2020 COVID-19 pandemic did not result in unconstitution-
ally cumbersome voting.
Subject: Registration procedures. Topics: COVID-19;
registration procedures; absentee ballots; National Voter
Registration Act; primary election; intervention.
Two voting-rights organizations and four voters filed a federal complaint in
the Southern District of Ohio on March 30, 2020, seeking an expansion of the
voter registration period and easier vote-by-mail procedures during the 2020
COVID-19 infectious pandemic.1 On March 16, Ohio's secretary of state post-
poned the state's March 16 primary election and forbade election officials
from similarly extending the deadline for voter registrations.2 The proscrip-
tion was included in a statute enacted on March 27 that set the election for
April 28 and created what plaintiffs described as unduly cumbersome proce-
dures for voting by mail.3 On March 31, the plaintiffs filed an amended com-
plaint4 and a motion for a temporary restraining order.5
Judge Michael H. Watson held a telephonic conference on March 31 and
learned that the secretary was working to alleviate some of the plaintiffs' con-
cerns.6 Judge Watson ordered a response to the pending motion by 3:00 p.m.
on April 2 and a reply by 3:00 p.m. on April 3.7
Presiding over a time-sensitive case with changing facts is a challenge, and
Judge Watson met the challenge by maintaining engagement with the parties
and keeping up with the most current information.'
1. Complaint, League of Women Voters of Ohio v. LaRose, No. 2:20-cv-1638 (S.D. Ohio
Mar. 30, 2020), D.E. 1; see Rick Rouan & Darrel Rowland, Voting Rights Groups Sue Over
Extended Primary, Cincinnati Enquirer, Apr. 1, 2020, at A7.
2. Opinion at 2-3, League of Women Voters of Ohio, No. 2:20-cv-1638 (S.D. Ohio Apr. 3,
2020), D.E. 57, 2020 WL 6115006.
3. Id. at 3-8; Complaint, supra note 1, at 10-13.
4. Amended Complaint, League of Women Voters of Ohio, No. 2:20-cv-1638 (S.D. Ohio
Mar. 31, 2020), D.E. 5.
5. Temporary Restraining Order Motion, id. (Mar. 31, 2020), D.E. 4.
6. Order, id. (Mar. 31, 2020), D.E. 14 [hereinafter Mar. 31, 2020, Order].
Tim Reagan interviewed Judge Watson for this report by telephone on August 26, 2020.
7. Mar. 31, 2020, Order, supra note 6.
8. Interview with Hon. Michael H. Watson, Aug. 26, 2020.
Federal Judicial Center 8/4/2021
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