Trudy Grant v. Conway Belangia
Split Score
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Case Summary
Disposition
Reversed in Part
The Fourth Circuit held that South Carolina’s statute limiting no-excuse absentee-by-mail voting to citizens aged 65 and older violates the Twenty-Sixth Amendment because it abridges younger voters’ right to vote on account of age. The court reversed the district court on that claim, affirmed dismissal of the Equal Protection claim, and remanded for the district court to craft an appropriate remedy.
Circuit Split Identified
Legal Issue
Whether state laws that grant no-excuse absentee-by-mail voting only to voters aged 65 and older abridge the right to vote on account of age in violation of the Twenty-Sixth Amendment.
Circuit Positions
Age-based no-excuse absentee-by-mail schemes violate the Twenty-Sixth Amendment because they abridge younger voters’ access to a method of voting on account of age.
Age-based no-excuse absentee-by-mail schemes do NOT violate the Twenty-Sixth Amendment where alternative voting methods (e.g., in-person voting) remain; the Amendment prohibits only retrogressive changes or does not reach absentee methods.
Conflict Summary
The Fourth Circuit holds that singling out voters 65 and older for unconditional absentee-by-mail voting unconstitutionally abridges younger voters’ rights under the Twenty-Sixth Amendment, while the Fifth and Seventh Circuits have held that such age-based absentee voting schemes are permissible because the Amendment bars only retrogressive changes or does not cover preferred voting methods so long as in-person voting remains available.