Richard Stanley, Jr. and Tim Clark v. Brown County Election Board

CourtDistrict Court, S.D. Indiana
DecidedJanuary 27, 2026
Docket1:25-cv-01482
StatusUnknown

This text of Richard Stanley, Jr. and Tim Clark v. Brown County Election Board (Richard Stanley, Jr. and Tim Clark v. Brown County Election Board) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard Stanley, Jr. and Tim Clark v. Brown County Election Board, (S.D. Ind. 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

RICHARD STANLEY, JR., ) TIM CLARK, ) ) Plaintiffs, ) ) v. ) Case No. 1:25-cv-01482-TWP-MKK ) BROWN COUNTY ELECTION BOARD, ) ) Defendant. )

ORDER ON DEFENDANT'S MOTION TO DISMISS AND PLAINTIFFS' MOTIONS FOR SUMMARY JUDGMENT AND PRELIMINARY INJUNCTION

This matter is before the Court on a Motion to Dismiss the Amended Complaint (Filing No. 27) filed by Defendant Brown County Election Board (the "Election Board"), as well as a Motion for Summary Judgment (Filing No. 25) and a Motion for Preliminary Injunction (Filing No. 29) filed by Plaintiffs Richard Stanley, Jr. ("Stanley") and Tim Clark ("Clark") (together, "Plaintiffs"). Plaintiffs initiated this lawsuit alleging that the Election Board's enforcement of the Indiana Republican Party's decision—that Plaintiffs are not Republicans in good standing for a period of five years and thus may not appear on the Republican primary ballot—violates Plaintiffs' constitutional rights (Filing No. 1). For the reasons discussed below, the Election Board's Motion to Dismiss is granted, Plaintiffs' Motion for Preliminary Injunction is denied, and their Motion for Summary Judgment is denied as moot. I. BACKGROUND On December 20, 2024, Stanley, as counsel for Clark, filed a complaint with the Indiana Republican Party asserting that the chairman of the local Republican Party violated "GOP Rule 1- 25" (Filing No. 22-1 at 1). In the complaint, Clark requested that the Indiana Republican Party remove the local Republican Chairman from his office and ban him from running for elected office for five years as a Republican. Id. On January 23, 2024, the District 9 Officers of the Indiana Republican Party held a hearing on Clark's complaint. Id. At the end of the hearing, the District 9 Officers issued a written decision dismissing Clark's complaint against the local Republican

chairman and determining that both Stanley and Clark are not Republicans in good standing for a period of five years. Id. Specifically, the written decision stated that Clark is not a Republican in good standing "because of his long and well-documented history of opposition to Republican candidates, financial support for candidates opposing Republican nominees, and frequent public self-declarations of being an independent." (Filing No. 1-7 at 2). The decision found that Stanley is not a Republican in good standing "because of his contribution to independent candidate Greg Taggart." Id. On February 5, 2025, Stanley and Clark filed an appeal with the Indiana Republican Party (Filing No. 22-1 at 2). On May 14, 2025, the Indiana Republican Party issued a written decision upholding the District 9 Officers' decision in its entirety. Id. On July 2, 2025, Stanley sent a copy

of a draft civil complaint to the Election Board and requested it issue a written statement refusing to enforce the decision of the Indiana Republican Party. That same day, the chairman of the Election Board responded but declined to state whether the Election Board intends to enforce the Indiana Republican Party's decision against Stanley and Clark. Id. On July 16, 2025, Stanley sent a follow-up letter to the Election Board concerning a potential lawsuit. Id. at 3. The Election Board did not respond. Id. Because he is "concerned about dysfunction in his local government and corruption in the local Republican party," Stanley recently confirmed that he intends to run for elected office in Brown County as a Republican and announced in a public forum his plans to run for the elected office of County Commissioner in Brown County Indiana in the 2026 election cycle (Filing No. 22-1 at 2). The deadline to file a declaration of candidacy for major political party primary nomination is February 6, 2026. Plaintiffs initiated this lawsuit on July 25, 2025 (Filing No. 1) and filed their Amended

Complaint on November 12, 2025 (Filing No. 22-1). That same day, Plaintiffs filed the instant Motion for Summary Judgment (Filing No. 25). On December 12, 2025, the Election Board moved to dismiss the Amended Complaint (Filing No. 27). Shortly thereafter, Plaintiffs filed their Motion for a Preliminary Injunction (Filing No. 29). On January 15, 2026, Plaintiffs filed a motion to submit additional legal authority (Filing No. 35), which the Court granted (Filing No. 37). This case is now ripe for ruling on the various motions. II. LEGAL STANDARDS A. Rule 12(b)(6) Standard Federal Rule of Civil Procedure 12(b)(6) allows a defendant to move to dismiss a complaint that has failed to "state a claim upon which relief can be granted." Fed. R. Civ. P. 12(b)(6). When

deciding a motion to dismiss under Rule 12(b)(6), the Court accepts as true all factual allegations in the complaint and draws all inferences in favor of the plaintiff. Bielanski v. Cnty. of Kane, 550 F.3d 632, 633 (7th Cir. 2008). However, courts "are not obliged to accept as true legal conclusions or unsupported conclusions of fact." Hickey v. O'Bannon, 287 F.3d 656, 658 (7th Cir. 2002). The complaint must contain a "short and plain statement of the claim showing that the pleader is entitled to relief." Fed. R. Civ. P. 8(a)(2). In Bell Atlantic Corp. v. Twombly, the United States Supreme Court explained that the complaint must allege facts that are "enough to raise a right to relief above the speculative level." 550 U.S. 544, 555 (2007). The allegations must "give the defendant fair notice of what the . . . claim is and the grounds upon which it rests." Twombly, 550 U.S. at 555. Stated differently, the complaint must include "enough facts to state a claim to relief that is plausible on its face." Hecker v. Deere & Co., 556 F.3d 575, 580 (7th Cir. 2009) (citation and quotation marks omitted). The question is whether relief is possible under any set of facts that could be established

consistent with the allegations. Northern Trust, 69 F.3d at 129. To be facially plausible, the complaint must allow "the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 U.S. at 556). B. Preliminary Injunction Standard "A preliminary injunction is an extraordinary remedy never awarded as of right. In each case, courts must balance the competing claims of injury and must consider the effect on each party of the granting or withholding of the requested relief." Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7, 20 (2008). To obtain a preliminary injunction, the party seeking relief must show: (1) it has some likelihood of success on the merits of its claim; (2) it has no adequate remedy at law; (3) without relief it will suffer irreparable harm. If the plaintiff fails to meet any of these threshold requirements, the court must deny the injunction. However, if the plaintiff passes that threshold, the court must weigh the harm that the plaintiff will suffer absent an injunction against the harm to the defendant from an injunction, and consider whether an injunction is in the public interest.

GEFT Outdoors, LLC v. City of Westfield, 922 F.3d 357, 364 (7th Cir. 2019) (citations and quotation marks omitted).

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Richard Stanley, Jr. and Tim Clark v. Brown County Election Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-stanley-jr-and-tim-clark-v-brown-county-election-board-insd-2026.