Missouri State Conference of the NAACP v. State of Missouri
Case Summary
LWV Missouri, the Missouri NAACP, and several individual plaintiffs filed a lawsuit in state court against new restrictions on acceptable voter ID for in-person voting. The League and its co-plaintiffs asserted the new provisions violated the Missouri Constitution’s guarantees of the fundamental right to vote and equal protection of the laws.
On June 29, 2022, Governor Mike Parsons signed HB 1878, a bill which made significant changes to the state’s elections. Among the provisions were increased restrictions on the types of ID acceptable for in-person voting.
Prior to HB 1878’s passage, Missouri voters voting in person had three options for acceptable voter ID. Voters could either present a photo ID, such as an unexpired Missouri driver’s license, alternative forms of ID (Missouri student ID, voter registration cards, utility or bank statements), or a provisional ballot. HB 1878 removed the option for alternative ID, meaning voters without current photo ID had no alternative but to cast a provisional ballot and return with acceptable ID on the same day, or allow election officials to rely on signature verification to count their ballot. Furthermore, under HB 1878, a voter voting with an in-person absentee ballot without a compliant ID could not cast a provisional ballot.
In response, on August 23, 2022, the League of Women Voters of Missouri (LWV Missouri), the Missouri State Conference of the National Association for the Advancement of Colored People (NAACP), and several individual Missouri voters with disabilities and/or difficulties obtaining compliant photo ID filed a lawsuit in the Circuit Court of Cole County, Missouri, asserting the new restrictions violated the Missouri constitution’s equal protection clause and its guarantee of the fundamental right to vote.
The League is represented by ACLU Missouri and the Missouri Voter Protection Coalition.
LWV Timeline
Governor Mike Parsons signs HB 1878 into law
Republican Governor Mike Parsons signs HB 1878, a package of changes to elections, into law. Among other provisions, the bill reduces the options for acceptable voter ID when voting in person.
LWV Missouri files lawsuit
LWV Missouri and the Missouri NAACP file a lawsuit in the Cole County Circuit Court, asserting the new voter ID requirements violate the fundamental right to vote and equal protection of the laws guaranteed by the state constitution.
Court dismisses lawsuit
The court dismisses the lawsuit, stating the individual plaintiffs did not have standing, and that their asserted injuries are speculative. Furthermore, the court also rules LWV Missouri, and the Missouri NAACP had no standing to sue on behalf of its members in this case and were not injured by HB 1878.
LWV Missouri files amended complaint
The plaintiffs file an amended complaint, including additional information on the barriers faced by individual plaintiffs and LWV Missouri and Missouri NAACP members in obtaining compliant photo ID.
State court holds trial
The state trial court hears oral arguments on HB 1878's validity under state law.