Robinson v. Dean et al

In the 2022 Pennsylvania midterm elections, Jeffrey A. Robinson and other voters had their mail-in ballots rejected by the Centre County Board of Elections solely because the outer envelopes lacked a handwritten date, as required by state law. Represented by the ACLU, the plaintiffs sued county election officials Michael Dean and Joshua Maxwell, along with then-Acting Secretary of State Al Schmidt, in federal court. They argued that rejecting ballots for a missing or incorrect date that plays no role in verifying voter eligibility violates the materiality provision of the Civil Rights Act of 1964, which forbids denying the right to vote because of an immaterial paperwork error. On July 10, 2023, the court issued a ruling in favor of the plaintiffs.

U.S. District Judge Matthew W. Brann granted summary judgment for the plaintiffs. The court held that the date requirement is immaterial to voter eligibility, and thus rejecting ballots for non-compliance with it violates the Civil Rights Act. The defendants were permanently enjoined from refusing to count mail ballots solely due to a missing or erroneous handwritten date on the return envelope.

Whether Pennsylvania's requirement that mail-in ballot outer envelopes bear a handwritten date, and the subsequent rejection of undated or incorrectly dated ballots, violates the materiality provision of the Civil Rights Act of 1964 (52 U.S.C. § 10101(a)(2)(B)) by disenfranchising voters over an omission or error that is not material to determining their qualifications to vote.

The ruling secured voting rights for thousands of Pennsylvania electors whose ballots might otherwise be discarded due to a trivial clerical omission. It reinforced the federal materiality provision as a safeguard against overly technical state election laws that can lead to disenfranchisement. The decision served as a key precedent for similar litigation across the United States, influencing ballot access rules ahead of the 2024 presidential election.