Case: O'Neal v. Goins

15-373-TTT | Tennessee state trial court

Filed Date: March 25, 2015

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Case Summary

On March 25, 2015, a former inmate filed this class action lawsuit in the Tennessee Chancery Court for Davidson County to regain voting rights for all persons who had their citizenship rights restored pursuant to Tennessee Code section 40-29-201. Like many other states, Tennessee revokes the voting rights of certain felons. Section 40-29-201, however, allows a state circuit court to restore those rights. The plaintiff brought this suit against the Coordinator of Elections for the State of Tenne…

On March 25, 2015, a former inmate filed this class action lawsuit in the Tennessee Chancery Court for Davidson County to regain voting rights for all persons who had their citizenship rights restored pursuant to Tennessee Code section 40-29-201. Like many other states, Tennessee revokes the voting rights of certain felons. Section 40-29-201, however, allows a state circuit court to restore those rights. The plaintiff brought this suit against the Coordinator of Elections for the State of Tennessee and the Tennessee State Election Commission. The plaintiff claimed that despite having his citizenship rights restored in an earlier proceeding, the defendants refused to restore plaintiff's right to vote. Represented by private counsel, the plaintiff sought declaratory, injunctive, and any other relief the court found reasonable and necessary, asserting that the defendants had improperly refused to restore his right to vote.

The defendants soon moved to dismiss the complaint. Chancellor Ellen H. Lyle granted the motion, dismissing the case with prejudice for lack of subject matter jurisdiction and failure to state a claim for relief. The court held that the claims against the defendants in their official capacities were barred by sovereign immunity because the plaintiff did not allege that they were enforcing an unconstitutional statute. The class action certification was denied because the allegations of the complaint failed to satisfy the numerosity, commonality, and typicality requirements required by state law.

The plaintiff appealed to the Court of Appeals of Tennessee. On July 29, 2016, Judge Richard H. Dinkins affirmed dismissal of the complaint and denial of the application to amend, however, he modified the judgment to make the dismissal without prejudice.

This case is now closed.

Summary Authors

Abigail DeHart (2/7/2017)

Hannah Greenhouse (3/23/2019)

People


Judge(s)

Dinkins, Richard Hovey (Tennessee)

Attorney for Plaintiff

McClellan, Elizabeth R. (Tennessee)

Judge(s)

Dinkins, Richard Hovey (Tennessee)

Attorney for Plaintiff

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Documents in the Clearinghouse

Document

15-373-TTT

Complaint

March 25, 2015

March 25, 2015

Complaint

M2015-01337-COA-R3-CV

Opinion

Tennessee state appellate court

April 13, 2016

April 13, 2016

Order/Opinion

2016 WL 2016

Docket

Last updated Aug. 30, 2023, 1:40 p.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Tennessee

Case Type(s):

Election/Voting Rights

Key Dates

Filing Date: March 25, 2015

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Former felons seeking the right to vote.

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Denied

Defendants

Tennessee State Election Commission (Nashville, Davidson), State

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

State law

Available Documents:

Complaint (any)

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None yet

Issues

Voting:

Voting: General & Misc.

Voter qualifications

Voter registration rules