Montana Public Interest Research Group v. Jacobsen

CourtCourt of Appeals for the Ninth Circuit
DecidedSeptember 3, 2024
Docket24-2811
StatusUnpublished

This text of Montana Public Interest Research Group v. Jacobsen (Montana Public Interest Research Group v. Jacobsen) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Montana Public Interest Research Group v. Jacobsen, (9th Cir. 2024).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS SEP 3 2024 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

MONTANA PUBLIC INTEREST No. 24-2811 RESEARCH GROUP; MONTANA D.C. No. FEDERATION OF PUBLIC 6:23-cv-00070-BMM EMPLOYEES, MEMORANDUM* Plaintiffs - Appellees,

v.

CHRISTI JACOBSEN, in her official capacity as Montana Secretary of State; AUSTIN KNUDSEN, in his official capacity as Montana Attorney General; CHRIS GALLUS, in his official capacity as Montana Commissioner of Political Practices,

Defendants - Appellants,

REPUBLICAN NATIONAL COMMITTEE; MONTANA REPUBLICAN PARTY,

Intervenor-Defendants – Appellants.

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. Appeal from the United States District Court for the District of Montana Brian M. Morris, Chief District Judge, Presiding

Argued and Submitted August 14, 2024 San Francisco, California

Before: GRABER, CALLAHAN, and KOH, Circuit Judges.

Plaintiffs Montana Public Interest Research Group and Montana Federation

of Public Employees (collectively, “Plaintiffs”) are organizations in Montana that

conduct voter registration activities focused on college students and union

members. Plaintiffs challenged Montana House Bill 892 (“HB 892”), which

amended Montana Code Annotated section 13-35-210, raising constitutional

overbreadth and vagueness claims and moving for preliminary relief. The district

court granted Plaintiffs’ motion for a preliminary injunction on the ground that HB

892 is unconstitutionally overbroad. Defendants Christi Jacobsen, Austin

Knudsen, and Chris Gallus in their capacities as Montana officials (collectively,

“Defendants”) timely appealed. We have jurisdiction under 28 U.S.C. § 1291. We

review the grant of a preliminary injunction for abuse of discretion, Sierra Forest

Legacy v. Rey, 577 F.3d 1015, 1021 (9th Cir. 2009), and affirm.1

1. A plaintiff seeking a preliminary injunction must demonstrate that (1) she

1 Plaintiffs argue on appeal that we may affirm the district court’s grant of the preliminary injunction on the alternative ground that HB 892 is vague. Because we affirm on the ground that HB 892 is overbroad, we do not reach this issue. is likely to succeed on the merits, (2) she is likely to suffer irreparable harm in the

absence of preliminary relief, (3) the balance of the equities tips in her favor, and

(4) an injunction is in the public interest. Winter v. Nat. Res. Def. Council, 555

U.S. 7, 20 (2008). Defendants argue that the district court misapplied the Winter

factors by adopting a relaxed standard for the merits analysis as articulated in

Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127 (9th Cir. 2011), without

adopting a more stringent standard for its analysis of the equities. See id. at 1134–

35. Defendants are mistaken. The district court stated repeatedly that it was

analyzing likelihood of success on the merits. It also repeatedly explained that it

evaluated the motion for a preliminary injunction under the Winter standard.

2. The district court did not abuse its discretion when it determined that

Plaintiffs were likely to succeed on the merits of their overbreadth claim. Plaintiffs

argued that provisions of HB 892 that imposed criminal penalties of up to eighteen

months in prison and $5,000 in fines for those who “purposefully remain registered

to vote in more than one place in this state or another state any time” or who fail to

“provide . . . previous registration information on the Montana voter registration

application” were unconstitutionally overbroad.

To prevail on an overbreadth challenge in the First Amendment context, a

party must demonstrate that “a substantial number of the law’s applications are

unconstitutional, judged in relation to the statute’s plainly legitimate sweep.”

3 Moody v. NetChoice, LLC, 144 S. Ct. 2383, 2397 (2024) (brackets omitted)

(quoting Ams. for Prosperity Found. v. Bonta, 594 U.S. 595, 615 (2021)). To

judge whether a statute is overbroad, a court must first “construe the challenged

statute; it is impossible to determine whether a statute reaches too far without first

knowing what the statute covers.” United States v. Williams, 553 U.S. 285, 293

(2008). Second, a court assesses whether the statute “criminalizes a substantial

amount of protected expressive activity,” id. at 297, that is “realistic, not fanciful,”

United States v. Hansen, 599 U.S. 762, 770 (2023).

The district court followed those steps here. It first construed the statute,

correctly determining that the law “has two separate but related effects: 1)

prohibits a person from purposefully remaining registered to vote in multiple

jurisdictions . . . ; and 2) requires a person registering to vote using the Montana

voter registration application to provide prior voting registration information.” The

court then determined that HB 892’s legitimate sweep was the prevention of the

crime of double voting. This conclusion was not erroneous: double voting has

long been illegal in Montana, See Mont. Code Ann. § 13-35-210(1) (1995) (“No

person may vote more than once at an election.”), and “[s]peech intended to bring

about a particular unlawful act has no social value; therefore, it is unprotected.”

Hansen, 599 U.S. at 783.

Second, the court determined that HB 892 prohibits a substantial amount of

4 protected speech relative to its plainly legitimate sweep. The record supports this

conclusion. Plaintiffs submitted declarations by their respective organizations’

executives explaining that HB 892 could discourage some of their thousands of

members from registering to vote in Montana, especially if those individuals do not

know where they plan to vote due to uncertainty about where they will reside

during future elections. On the other hand, Defendants submitted evidence that

there were only fourteen instances of suspected double voting in Montana in the

2020 general election. Given these facts, we discern no abuse of discretion in the

district court’s determination that HB 892 criminalizes a substantial amount of

non-fanciful protected speech relative to its limited legitimate sweep.2

3. On appeal, Defendants assert that voter registration is not protected

speech and that there is no First Amendment right to maintain multiple voter

registrations. Therefore, they contend, HB 892 reaches only conduct unprotected

by the First Amendment. We decline to consider this argument. Defendants failed

2 At oral argument, Defendants appeared to argue that Moody v. NetChoice, LLC, 144 S. Ct. 2383 (2024), reformulated the overbreadth analysis such that “the comparator is all Montana voters.” This new argument, raised for the first time at oral argument, was not presented in the briefs.

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Related

Elrod v. Burns
427 U.S. 347 (Supreme Court, 1976)
United States v. Williams
553 U.S. 285 (Supreme Court, 2008)
Sierra Forest Legacy v. Rey
577 F.3d 1015 (Ninth Circuit, 2009)
Cornhusker Casualty Insurance v. Kachman
553 F.3d 1187 (Ninth Circuit, 2009)
Kaass Law v. Wells Fargo Bank, N.A.
799 F.3d 1290 (Ninth Circuit, 2015)
Obama for America v. Jon Husted
697 F.3d 423 (Sixth Circuit, 2012)
Americans for Prosperity Foundation v. Bonta
594 U.S. 595 (Supreme Court, 2021)
Alliance for Wild Rockies v. Cottrell
632 F.3d 1127 (Ninth Circuit, 2011)
United States v. Hansen
599 U.S. 762 (Supreme Court, 2023)

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Montana Public Interest Research Group v. Jacobsen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/montana-public-interest-research-group-v-jacobsen-ca9-2024.