Thiess v. State Administrative Board of Election Laws

387 F. Supp. 1038, 1974 U.S. Dist. LEXIS 11410
CourtDistrict Court, D. Maryland
DecidedDecember 26, 1974
DocketCiv. 72-1091-K
StatusPublished
Cited by13 cases

This text of 387 F. Supp. 1038 (Thiess v. State Administrative Board of Election Laws) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thiess v. State Administrative Board of Election Laws, 387 F. Supp. 1038, 1974 U.S. Dist. LEXIS 11410 (D. Md. 1974).

Opinion

FRANK A. KAUFMAN, District Judge.

Plaintiffs, residents of the State of Maryland, all of whom have been eonvicted of and never pardoned for one or more crimes, 1 seek injunctive and declaratory relief against the Administrative Board of Election Laws of the State of Maryland and the Baltimore City Board of Supervisors of Elections, pursuant to 42 U.S.C. § 1983 and its jurisdictional counterpart, 28 U.S.C. § 1343. Plaintiffs assert that the provisions of 3 Md. Ann.Code art. 33, §§ 3-4(c), 24-14, as amended, ch. 299, §§ 1-2 [1974] Laws of Maryland 1353-54, 2 violate the Equal Protection Clause of the Fourteenth *1040 Amendment because they single out certain convicted felons for the deprivation of the “fundamental” right to vote. Plaintiffs also allege that those Maryland statutory provisions are unconstitutional because they constitute cruel and unusual punishment inflicted upon those convicted of felonies, an<F further contend that those provisions are void for vagueness. Additionally, plaintiffs contend that those statutes have been arbitrarily and thus unconstitutionally administered. Defendants have filed a motion to dismiss which, because the record contains affidavits and discovery documents in addition to pleadings, has been converted to a motion for summary judgment under Federal Civil Rules 12(b) and 56. That motion was held sub curia by this three-judge Court, empanelled pursuant'to 28 U.S.C. §§ 2281, 2284, pending the filing by the Supreme Court of the United States of its opinion in Richardson v. Ramirez, 418 U.S. 24, 94 S.Ct. 2655, 41 L.Ed.2d 551 (1974).

I.

Before dealing with the substantive constitutional issues posed herein, this Court notes at the outset that serious justiciability problems exist as to all but one of the plaintiffs. Plaintiffs Charlotte Lane, Banks and Little have apparently been convicted for offenses which constitute “infamous” crimes 3 disqualifying them from voter eligibility at the time this suit was instituted. However, none of those plaintiffs claim to have ever attempted to register to vote, and for that reason may not be persons who have yet been deprived of their right to vote. Moreover, under the *1041 1974 amendments to Maryland’s voter registration law, plaintiffs Charlotte Lane and Banks would appear now entitled to register. Plaintiff Richard Lane has not only never attempted to register to vote, but has not alleged that the offenses for which he has been convicted disqualified him from voter eligibility even under the more restrictive provisions of state law existing at the time this case was instituted. Plaintiff Long does assert that he has previously attempted to register as a Maryland voter. However, it is not clear that either under the previous law or under the law as recently amended Long is disqualified from registering to vote. Plaintiff Thiess asserts that he was on at least one occasion denied the opportunity to register as a voter. Thiess has been convicted of two “infamous” crimes, forgery and burglary. Since Thiess has never been pardoned by the Governor of Maryland, he is seemingly presently ineligible to vote in the State of Maryland. Accordingly, as to Thiess, a justiciable controversy exists, at the least in the context of defendants’ pending motion for summary judgment in which all factual inferences must be assumed in favor of plaintiffs.

II.

The contention that the Maryland statutes depriving convicted felons of their right to vote contravene the mandates of the Equal Protection Clause of the Fourteenth Amendment has been fully answered by the Supreme Court’s decision in Richardson v. Ramirez, supra. In that case, the Supreme Court (418 U.S. at 34, 94 S.Ct. at 2658, 41 L.Ed.2d at 556) upheld the provisions of the California Constitution and of California’s implementing statutes disenfranchising persons convicted of infamous crimes. In his opinion in that case, Mr. Justice Rehnquist wrote (418 U.S. at 54, 94 S.Ct. at 2671, 41 L.Ed.2d at 571) that “the exclusion of felons from the vote has an affirmative sanction in § 2 of the Fourteenth Amendment,” and held (418 U.S. 56, 94 S.Ct. at 2671, 41 L.Ed.2d at 572)

•x- ■>,• * that the Supreme Court of California erred in concluding that California may no longer, consistent with the Equal Protection Clause of the Fourteenth Amendment, exclude from the franchise convicted felons who have completed their sentences and paroles. 4

Plaintiffs’ counsel has candidly con- . ceded that Richardson v. Ramirez represents the final word upon the Equal Protection claim now before this Court. That concession is compelled.

III.

Plaintiffs also claim, as indicated above, that the felon disqualification procedures of Maryland law constitute “cruel and unusual punishment.” In his concurring opinion in Furman v. Georgia, 408 U.S. 238, 282, 92 S.Ct. 2726, 33 L.Ed.2d 346 (1972), in which the Supreme Court held the death penalty as then administered proscribed by the Eighth Amendment, Mr. Justice Brennan observed:

Since the Bill of Rights was adopted, this Court has adjudged only three punishments to be within the prohibition of the Clause. See Weems v. United States, 217 U.S. 349, [30 S.Ct. *1042 544, 54 L.Ed. 793] (1910) (12 years in chains at hard and painful labor); Trop v. Dulles, 356 U.S. 86 [78 S.Ct. 590, 2 L.Ed.2d 630] (1958) (expatriation); Robinson v. California, 370 U. S. 660, [82 S.Ct. 1417, 8 L.Ed.2d 758] (1962) (imprisonment for narcotics addiction). * * *

Among the cases cited by Mr. Justice Brennan, only Trop v. Dulles would appear arguably to buttress plaintiffs’ contention that political disenfranchisement is unconstitutional as “cruel and unusual punishment.” In Trop, Mr. Chief Justice Warren concluded (356 U.S. at 103, 78 S.Ct. at 599) “that the Eighth Amendment forbids Congress to punish by taking away citizenship” and indicated (at 101, 78 S.Ct. at 598) that the Eighth “Amendment must draw its meaning from the evolving standards of decency that mark the progress of a maturing society.”

Unlike the penalty of expatriation, the penalty of disenfranchisement is one specifically recognized by the Fourteenth Amendment, an amendment enacted subsequent to the Eighth. See Richardson v. Ramirez, supra 418 U.S. at 54, 94 S.Ct. at 2671, 41 L.Ed.2d at 571. In addition, Mr. Chief Justice Warren’s words in Trop

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387 F. Supp. 1038, 1974 U.S. Dist. LEXIS 11410, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thiess-v-state-administrative-board-of-election-laws-mdd-1974.