PILF v. North Carolina State Board of Elections

Lawsuit filed under Section 8 of the National Voter Registration Act to compel the release of records reflecting noncitizen registration and voting held by the North Carolina State Board of Elections.

United States District Court for the Eastern District of North Carolina (Case Number 5:19-cv-00248)

Court Documents

• Complaint (June 17, 2019)
• Exhibits: A, B, C, D, E, F, G, H, I, J, K (June 17, 2019)

Press Releases

Lawsuit: North Carolina Illegally Withholding Data on Noncitizen Voters (June 18, 2019)

LULAC et. al. v. Texas

Intervention to defend Texas’ efforts to assist in the identification and removal of noncitizens registered to vote in the state.

United States District Court for the Western District of Texas (Case Number 5:19-cv-00074 )

Case Documents

• First Amended Complaint (February 1, 2019)
• Preliminary Order (February 27, 2019)
• Motion to Intervene by Proposed Intervenor-Defendant PILF (March 1, 2019)
• Proposed Answer of Intervenor-Defendant PILF (March 1, 2019)

Press Releases

• PILF Seeks to Intervene in Texas Noncitizen Voter Removal Case (March 1, 2019)

Rucho v. Common Cause

Amicus brief filed in opposition to plaintiffs’ claim that North Carolina‘s 2016 congressional map is an unconstitutional partisan gerrymander.

U.S. Supreme Court

Case Filings

Brief of the Public Interest Legal Foundation as Amicus Curiae in Support of Appellants (February 12, 2019)

Decision (June 27, 2019)

Press Releases

PILF Praises SCOTUS Decision on Partisan Gerrymandering Claims (June 27, 2019)

ACRU, et al. v. Snipes

PILF filed a lawsuit in federal court against Brenda Snipes, the Supervisor of Elections in Broward County, Florida, for failure to maintain accurate and current voter rolls and for failure to provide records related to voter roll maintenance and possible noncitizen voters, as required by federal law.

United States District Court for the Southern District of Florida (No. 16-cv-61474)

United States Court of Appeals for the Eleventh Circuit (No. 18-11808-GG)

Trial Court Documents

• Complaint (June 27, 2016)
• Order on Motions for Partial Summary Judgment and Motion to Exclude Opinions and Testimony (July 12, 2017)
• Bench Trial Opening Statement (July 25, 2017)
• Plaintiff’s Proposed Findings of Fact and Conclusions of Law (October 20, 2017)
• Trial Court Order (March 30, 2018)
• Plaintiff’s Notice of Appeal (April 29, 2018)

11th Circuit Court of Appeals Documents

• Brief for the Appellant American Civil Rights Union (August 13, 2018)
• Reply Brief for Appellant American Civil Rights Union (October 9, 2018)

Press Releases

• Broward County Sued for Corrupt Voter Rolls (June 27, 2016)
• PILF Scores Early Court Victories in Florida Voter Roll Cleanup Suit (July 13, 2017)
• Dates for Broward County Voter Roll Trial Released (July 18, 2017)
• Broward County Voter Roll Trial Continues (July 30, 2017)

Relevant Press Clips

• Sun-Sentinel: Broward’s voting rolls challenged by group (July 25, 2017)
• LifeZette: Florida County Has ‘Thousands’ of Voters Over Age 100 (July 26, 2017)
• Sun-Sentinel: Broward elections supervisor Brenda Snipes to testify in voter list trial (July 27, 2017)
• Miami Herald: Broward elections supervisor to testify in federal voter roll lawsuit in Miami (July 28, 2017)
• Sun-Sentinel: Broward election supervisor makes changes after being sued (July 31, 2017)
• Local 10 News Miami: Brenda Snipes Defends Office in Federal Court amid Lawsuit (July 31, 2017)
• LifeZette: Broward Co. Elections Chief Admits She Has Seen Fraud (August 1, 2017)
• Sun-Sentinel: Trial over Broward County’s disputed voting lists ends (August 2, 2017)
• Sun-Sentinel: Broward voter rolls case has national implications (August 6, 2017)
• The Washington Times: Election Integrity Needs to Be a Top Priority (August 7, 2017)
• Sun-Sentinel: Broward needs to trim its voting lists, group tells judge (October 24, 2017)
• The Christian Science Monitor: Securing the vote: could Henny Nelson, age 131, help Russia rig an election? (November 3, 2017)
• The Christian Science Monitor: Securing the vote: How efforts to prevent fraud and voting rights collide (November 6, 2017)
• POLITICO: Experts: Broward’s elections chief broke law in destroying ballots (December 15, 2017)
• Breitbart News; Florida Official Overseeing Vote Count Destroyed Ballots, Accused of Not Removing Dead Voters from Rolls (November 8, 2018)
• The Daily Wire; Broward County Supervisor Of Elections Has A Sketchy History (November 9, 2018)
• The Daily Signal; Trump Calls Out Embattled County Election Official in Florida Vote-Count Mess (November 10, 2018)
• The New York Times; Before the Fights Over Recounts: An Election Day Vote on Voting (November 12, 2018)
• Breitbart News; Soros-Funded Groups Defended Broward’s Brenda Snipes in Lawsuit Alleging Inaccurate Voter Rolls (November 13, 2018)
• PJ Media; Federal Judge Rebuked Broward Supervisor for Hiding ‘Mystery’ Voter Roll Manual (November 13, 2018)

2020 Census Citizenship Question Case

Amicus briefs filed in defense of the U.S. Department of Commerce’s reinstatement of a citizenship question for the 2020 Census.

U.S. Court of Appeals for the Second Circuit

U.S. Supreme Court

Case Filings

• Brief of the Public Interest Legal Foundation as Amicus Curiae in Support of Petitioners (September 14, 2018)
• Brief of the Public Interest Legal Foundation as Amicus Curiae in Support of the Petition (September 14, 2018)
• Brief of Amicus Curiae of PILF in Support of Defendant’s Position at Trial (October 29, 2018)
• Brief in Support of Government’s Position for a Writ of Mandamus Before the U.S. Supreme Court (November 13, 2018)
• Brief as Amicus Curiae in Support of Petitioners Before the U.S. Supreme Court (December 24, 2018)
• Brief as Amicus Curiae in Support of Petitioners Before the U.S. Supreme Court (February 11, 2019)
• Certiorary Granted (February 15, 2019)
• Brief as Amicus Curiae in Support of Petitioners Before the U.S. Supreme Court (March 6, 2019)
• Decision (June 27, 2019)

Related Press Releases

• J. Christian Adams Praises Inclusion of Citizenship Question in 2020 Census (March 27, 2018)
• J. Christian Adams Before Congress: Return Citizenship Question to Census (June 8, 2018)
• PILF Granted Amicus Position Defending 2020 Census Citizenship Question (September 25, 2018)
• PILF Applauds SCOTUS Decision on Wilbur Ross Deposition (October 22, 2018)
• PILF Granted Amicus Position Defending 2020 Census Citizenship Question at Trial (October 30, 2018)
• PILF to SCOTUS: 2020 Census Needs Citizenship Question (November 13, 2018)
• Census Citizenship Question, PILF Briefs Get SCOTUS Hearing (November 19, 2018)
• PILF to SCOTUS: Take the Census Case Now (February 11, 2019)
• Statement on Census Citizenship Question Decision (June 27, 2019)
• SCOTUSblog: The Unanswered Census Question (June 28, 2019)

PILF v. Harris Bennett

Lawsuit filed under Section 8 of the National Voter Registration Act to compel the release of records reflecting noncitizen registration and voting in Harris County, Texas.

United States District Court for the Southern District of Texas (Case Number 4:18-cv-00981)

District Court of Travis County, Texas, 459^th District (Case Number D-1-GN-18-001583)

Federal Trial Court Documents

• Complaint (March 29, 2018)
  • Exhibits: A, B, C, D, E, F, G (March 29, 2018)
• PILF’s Motion for Preliminary Injunction and Memorandum of Points and Authorities (March 29, 2018)
• Doc. 15 — PILF’s Reply Memorandum in Support of Motion for Preliminary Injunction (May 10, 2018)
• Doc. 16 — PILF’s Response in Opposition to Harris County’s Motion to Dismiss (May 10, 2018)
• Doc. 21 — First Amended Complaint (June 13, 2018)
• Doc. 34 — PILF’s First Motion for Summary Judgment (November 21, 2018)
• Doc. 42 — Magistrate’s Memorandum and Recommendation (February 6, 2019)
• Doc. 47 – PILF’s Response in Opposition to Defendant’s Objections to the Memorandum Denying MTD (March 8, 2019)
• Doc. 48 — Order on Motion to Dismiss (March 11, 2019)
• Doc. 53 – Plaintiff’s Reply to Defendant’s Response in Opposition to Plaintiff’s First Motion for Summary Judgment (April 17, 2019)
  • Exhibit 1
• Doc. 54 – PILF’s Response in Opposition to Defendant’s Motion to Stay or Abstain (April 23, 2019)

Texas Court Documents

• Harris Bennett v. Texas Complaint (March 29, 2018)
• PILF Petition to Intervene (April 11, 2018)
• Intervention Exhibit 1-48 (April 11, 2018)
• Defendant Paxton’s Original Answer (April 16, 2018)

Press Releases

• PILF Sues Harris County, Texas for Data on Noncitizen Voters (March 29, 2018)
• PILF: Texas Court Lacks Jurisdiction in Noncitizen Voter Data Case (April 12, 2018)
• Texas AG Urges Disclosure of Noncitizen Voting Records to PILF (April 17, 2018)
• Harris County Seeks to Shield Noncitizen Voter Records (May 11, 2018)
• Noncitizen Voter Prosecution Shows Need for Transparency in Harris County (May 14, 2018)
• Harris County: Revealing Noncitizen Voter Records Harms ‘Public Interest’ (June 5, 2018)
• 7 Reasons for Summary Judgment in Harris County Noncitizen Voter Data Case (November 21, 2018)
• Lawsuit Seeking Harris County Noncitizen Voter Records Can Proceed (March 11, 2019)

Additional Documents

• Case Fact Sheet (March 29, 2018)
• Sample of Responsive Documents: Hidalgo County
• Sample of Responsive Documents: Tarrant County

Relevant News Clips

• The Washington Free Beacon; Texas County Hit with Lawsuit for Concealing Records of Noncitizens Registered to Vote (March 29, 2018)
• Empower Texans; Harris County Sued for Hiding Noncitizen Voting Records (March 29, 2018)
• Breitbart News; Lawsuit: Largest Texas County Withholding Noncitizen Voting Records (March 29, 2018)
• FOX 26 Houston; Harris County Faces Lawsuit for Concealing Voter Registration List Maintenance Records (March 29, 2018)
• Houston Chronicle; Nonprofit Group Sues Harris County over Voter Registration Records (March 30, 2018)
• Laredo Morning Times; Nonprofit Group Sues Harris County over Voter Registration Records (March 30, 2018)
• KPRC-AM Houston; PILF interview (April 3, 2018)
• KTRH-AM Houston; Harris County Sued for Voting Records (April 3, 2018)
• Empower Texans; Harris County Dodging Federal Law to Hide Voting Records from Public (April 3, 2018)
• KPRC-AM Houston; PILF interview (April 19, 2018)
• Empower Texans; Texas AG: Harris County Should Disclose Non-Citizen Voter Records (April 24, 2018)
• Breitbart News; Mexican National Stole Texan’s Identity and Voted Three Times, Says AG (May 14, 2018)
• The Washington Times; Mexican woman stole American’s identity to vote in elections: Texas AG (May 14, 2018)
• KPRC-AM Houston; PILF interview (May 16, 2018)
• The Washington Times; Houston registrar battles to keep noncitizens on voter rolls (June 6, 2018)
• The Washington Times; Noncitizens across the U.S. find it easy to register to vote, cast ballots (July 31, 2018)
• Fox News Channel; Names of non-US citizens increasingly found on voter rolls (August 1, 2018)
• Empower Texans; Citizens Challenge 4,000 Voter Registrations in Harris County (August 3, 2018)

PILF v. Pennsylvania

Lawsuit filed under Section 8 of the National Voter Registration Act to compel the release of records reflecting noncitizen registration and voting across Pennsylvania.

United States District Court for the Middle District of Pennsylvania (Case Numbers  1:18-cv-00463 and 1:19-cv-00622)

Philadelphia County Court of Common Pleas

Federal Case Documents

• Complaint (February 26, 2018)
  • Exhibit 1, Exhibit 2, Exhibit 3, Exhibit 4, Exhibit 5, Exhibit 6, Exhibit 7, Exhibit 8, Exhibit 9, Exhibit 10
• Doc. 14 – Plaintiff’s Response in Opposition to Defendants’ Motion to Dismiss (April 18, 2018)
  • Exhibit 14-1, Exhibit 14-2
• Doc. 18 – Plaintiff’s Consent Motion for Leave to File Sur-Reply (May 8, 2018)
  • 18-1: Sur-Reply in Opposition to Defendants’ Motion to Dismiss
  • Exhibit A, Exhibit B
• Refiled Complaint (April 10, 2019)
  • Exhibit A, Exhibit B, Exhibit C, Exhibit D, Exhibit E, Exhibit F, Exhibit G, Exhibit H, Exhibit I, Exhibit J, Exhibit K, Exhibit L, Exhibit M, Exhibit N, Exhibit O, Exhibit P, Exhibit Q

Philadelphia County Court of Common Pleas Documents

• City of Philadelphia v. PILF Notice of Appeal (May 2, 2018)

Press Releases

• PILF Sues Pennsylvania to Release Data on ‘100K’ Noncitizen Voter Registrants (February 26, 2018)
• PILF: Pennsylvania SOS’ Read of Disclosure Law is ‘Absurd’ (April 18, 2018)
• PA Contradicts Own Claim of ‘No’ Noncitizen Voter Records (May 10, 2018)

Additional Documents

• Case Fact Sheet (February 26, 2018)

Relevant News Clips

• The Washington Times; Lawsuit: 100,000 noncitizens registered to vote in Pennsylvania (February 26, 2018)
• The Washington Free Beacon; Pennsylvania Dept. of State Sued for Hiding Noncitizen Voting Records (February 27, 2018)
• LifeZette; Pennsylvania Officials Accused of Hiding Data on Noncitizen Voting (February 27, 2018)
• Breitbart News; Report: More than 100,000 Non-Citizens are Registered Voters in Pennsylvania (February 27, 2018)
• The Daily Caller; Legal Group Sues for Records of up to 100,000 Noncitizens on Pennsylvania Voter Rolls (February 27, 2018)
• Law360; Anti-Voter Fraud Group Wants Pa. Data on Noncitizens (February 27, 2018)
• The Hill; Mueller’s chase ignores the real foreign influence in our elections (February 28, 2018)
• Fox News Channel; Why aren’t Mueller, the FBI and DOJ interested in illegal actions that might alter our elections? (March 1, 2018)
• Hot Air; 100K Non-citizens Registered to Vote in Pennsylvania? (March 4, 2018)
• Pittsburgh Tribune-Review; Editorial: 100,000-plus noncitizen Pa. voters? Withheld records hold answer (March 5, 2018)
• LifeZette; Noncitizen Voters in Pennsylvania Not a ‘Glitch,’ Philly Official Says (March 13, 2018)
• The Washington Times; PA Gubernatorial Candidate Targets Non-Citizen Voting in Wake of Special Election (March 14, 2018)
• WITF NPR/PBS Harrisburg; What’s behind the claim Pa. is swarming with illegal voters? (April 3, 2018)
• The Philadelphia Inquirer; Are there thousands of ineligible immigrants registered to vote in Pa.? We don’t know yet | Editorial (April 5, 2018)
• WITF-NPR; PA addresses non-citizen voter issue (April 30, 2018)
• CBS Philly Radio; Christine Flowers Show (May 6, 2018)
• The Washington Times; Noncitizens across the U.S. find it easy to register to vote, cast ballots (July 31, 2018)
• Fox News Channel; Names of non-US citizens increasingly found on voter rolls (August 1, 2018)
• PennLIVE; Foundation that targets voting by non-citizens claims Pa. is violating federal voter registration law (April 12, 2019)

Watch @ElectionLawCtr discuss noncitizen voting and more on @PCNCnighttalk https://t.co/NCYmp26Sh2

— PublicInterestLegal (@PILFoundation) August 1, 2018

#Watch: @ElectionLawCtr tells @ShannonBream that foreign voters are the real “foreign influence” in our #Elections https://t.co/7IBqNfYJNM

— PublicInterestLegal (@PILFoundation) March 5, 2018

J.Christian Adams– @ElectionLawCtr–joined me on ‘Justice’ to discuss how he believes that the real foreign influence in our elections has been ignored by the Justice Department for years. Take a look: pic.twitter.com/niDeBQ8rba

— Jeanine Pirro (@JudgeJeanine) March 4, 2018

Common Cause Indiana v. Lawson

Intervention to defend Indiana’s use of the Interstate Voter Registration Crosscheck program under the National Voter Registration Act of 1993. The plaintiff seeks to impose restrictions on Indiana’s ability to conduct fair and robust elections by limiting the State’s programs for ensuring that its list of eligible voters is kept accurate and current. Plaintiff seeks to impose limits clearly beyond what was contemplated by Congress.

United States District Court for the Southern District of Indiana (Case Number 1:17-cv-3936)

Case Documents

• Original Complaint (October 27, 2017)
• Motion to Intervene as Defendant by the Public Interest Legal Foundation (November 9, 2017)
• Proposed Answer by Defendant-Intervenor PILF (November 9, 2017)
• Memorandum Supporting PILF’s Motion to Intervene as Defendant (November 9, 2017)
• PILF Brief as Amicus Curiae (April 26, 2018)

Press Releases

• PILF Intervention Defends Indiana’s Use of Voter Roll Crosscheck (November 9, 2017)

Press Clips

• Indianapolis Star; Safeguard Indiana’s Voter Registration Rolls (May 2, 2018)

Luna et al. v. Cegavske

Intervention to defend Nevada’s recall procedures against unconstitutional applications of the Voting Rights Act. The Plaintiffs’ lawsuit seeks to impose unconstitutional restrictions on the democratic voice of Nevada citizens by extinguishing a means to hold government accountable and by ultimately seeking to prevent the state from holding an election altogether. This would be the ultimate denial and infringement on the right and freedom of citizens to participate in the electoral process.

United States District Court for the District of Nevada (Case Number 2:17-cv-02666)

Case Documents

• Original Complaint (October 16, 2017)
• Motion to Intervene As Defendant by PILF and Proposed Answer (October 30, 2017)
• Order, Findings & Recommendations RE PILF Motion to Intervene (December 20, 2017)
• Notice of Voluntary Dismissal (April 29, 2019)

Press Releases

• PILF Challenges Marc Elias’ Effort to Block Nevada’s Recall Elections (October 30, 2017)
• PILF Successfully Intervenes in Lawsuit Blocking Nevada Recall Efforts (December 21, 2017)

Gill v. Whitford

Are partisan gerrymandering claims justiciable?

Case Documents

• Supreme Court Brief of the American Civil Rights Union and the Public Interest Legal Foundation as Amici Curiae in Support of the Appellants (August 4, 2017)
• Slip Opinion (June 18, 2018)

Press Releases

• PILF Rejects Partisan Gerrymandering Claims Before SCOTUS (August 9, 2017)
• PILF Praises SCOTUS Decision on ‘Partisan Gerrymandering’ (June 18, 2018)