红杏视频

Eakin is a companion case to Pennsylvania State Conference of the NAACP v. Schmidt, litigation brought by 红杏视频 Voting Rights Project, the 红杏视频 of Pennsylvania, and Hogan Lovells on behalf of voters and a coalition of non-profit civic engagement organizations including the Pennsylvania State Conference of the NAACP, League of Women Voters of Pennsylvania, Common Cause PA, Make The Road PA, POWER Interfaith, and the Black Political Empowerment Project to protect thousands of Pennsylvania voters from being disenfranchised based on a meaningless paperwork error.

In November 2022, the Supreme Court of Pennsylvania interpreted Pennsylvania state law to require county boards of elections not to count mail ballots that had a missing or incorrect handwritten date on the ballot's return envelope, even if those ballots were timely received by the boards of elections. As a result, in the November 2022 election, Pennsylvania counties set aside over 10,000 ballots because voters forgot to write a date on a form on the back of the mail ballot return envelope, even though the date serves no purpose relating to a voter鈥檚 qualifications or the timeliness of their ballot.

In November 2023, the district court granted summary judgment in our favor in the Pennsylvania State Conference case. The district court's decision declared that the Civil Rights Act bars state actors from disenfranchising voters based on immaterial paperwork errors. But in March 2024, the Third Circuit Court of Appeals overturned the district court's ruling on statutory interpretation grounds, acknowledging that the envelope date 鈥渟erves little apparent purpose鈥� but interpreting the Civil Rights Act as not applying to mail ballot paperwork. The Supreme Court later denied review.

The case went back to the district court, where, in 2025, the district court granted summary judgment to the plaintiffs in Eakin, ruling that disenfranchising voters for meaningless paperwork errors violated voters鈥� constitutional rights and holding that voters鈥� ballots may not be excluded on this basis. The RNC appealed.

On appeal, we filed an amicus brief on behalf of the organizational plaintiffs from the Pennsylvania State Conference case highlighting the egregiousness of the disenfranchisement of thousands of Pennsylvania voters based on the factual record from the district court.

Update: In August 2025, a unanimous panel of the Third Circuit affirmed the grant of summary judgment, holding that disenfranchising mail ballot voters for failure to handwrite an irrelevant date on the mail ballot return envelope violates the U.S. Constitution.