IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

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1 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 1 of 22 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION GEORGIA MUSLIM VOTER PROJECT and ASIAN-AMERICANS ADVANCING JUSTICE-ATLANTA, vs. Plaintiffs, BRIAN KEMP, in his official capacity as the Secretary of State of Georgia; and GWINNETT COUNTY BOARD OF VOTER REGISTRATION AND ELECTIONS, on behalf of itself and similarly situated boards of registrars in all 159 counties in Georgia, Defendants. Civil Action No.: 1:18-cv LMM PLAINTIFFS OPPOSITION TO DEFENDANT BRIAN KEMP S MOTION FOR STAY

2 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 2 of 22 Defendant Brian Kemp ( Secretary has filed a motion to stay this Court s temporary restraining order ( TRO, which if granted will result in the permanent disenfranchisement of lawful absentee voters who cannot vote in-person, or who receive notice that their ballots have been rejected too late. The Secretary s motion largely parrots arguments he has already made, and which this Court has already considered and rejected in granting the TRO. Thus, the Secretary s motion should be denied largely for the same reasons this Court has already provided. I. THE TEMPORARY RESTRAINING ORDER IS NOT BARRED BY LACHES The Secretary s argument concerning laches, Dkt. No. 33 ( Sec y Stay Br. at 3-7, repeats nearly verbatim the same arguments made in the Secretary s initial opposition brief, Dkt. No. 24 ( Sec y Opp n Br. at For the reasons given in this Court s order granting Plaintiffs TRO motion, Dkt. No. 28 ( Order at 16-19, the Secretary s argument is without merit. II. THE SECRETARY HAS NOT DEMONSTRATED A STRONG LIKELIHOOD OF SUCCESS ON THE MERITS The Secretary next argues that he not the Plaintiffs is likely to succeed on the merits of their due process claims because the three factors set forth in Mathews v. Eldridge, 424 U.S. 319 (1976, tip in his favor. The Secretary is wrong. 1

3 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 3 of 22 A. The Private Interest Is Substantial In the Secretary s initial opposition brief, he did not dispute that the first Mathews factor, the private interest involved, weighed heavily in Plaintiffs favor as it pertains to having a validly-cast absentee ballot counted. Sec y Opp n Br. at 32. Now, the Secretary argues for the first time in a stay motion that that the interest is light, because absentee voting is a mere privilege and a convenience. Sec y Stay Br. at This argument, which has been waived, 2 is also wrong. As an initial matter, this case is not about the free-floating interest in casting an absentee ballot. 3 This case concerns the right of an absentee voter who has done 1 The Secretary did previously argue that absentee voting is a mere privilege and a convenience, but only in support of his assertion that the first element of a due process challenge was not satisfied, not in support of the first Mathews factor as he does for the first time here. Sec y Opp n Br. at See Jet Networks FC Holding Corp. v. Goldberg, No. 09-cv-21082, 2009 WL , at *4 (S.D. Fla. Sept. 16, 2019 (declining to consider argument raised for the first time in [a] Motion for a Stay Pending Appeal as it was never raised in pleading that ultimately led to order; cf. In re Egidi, 571 F.3d 1156, 1163 (11th Cir ( Arguments not properly presented in a party s initial brief or raised for the first time in the reply are deemed waived. 3 While not directly at issue here, Plaintiffs strongly dispute the premise of the State s argument. The State is constitutionally required to provide absentee voting, at least for voters who cannot vote in-person, because states cannot impose a burden on the fundamental right to vote without a sufficiently compelling reason. 2

4 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 4 of 22 everything right and has complied with all the instructions required to apply for or cast an absentee ballot. Those voters have a substantially weighty interest in having their ballot counted or application processed. Order at Most importantly here, the Secretary s assertion that absentee voting is a privilege and convenience is irrelevant in the due process analysis since state law has created an entitlement to an absentee ballot so long as voters fulfill the prerequisites. As this Court correctly ruled, state-created statutory entitlements can trigger due process. Order at 22 (citing Goldberg v. Kelly, 397 U.S. 254, 262 (1970, and Paul v. Davis, 424 U.S. 693, (1976. Indeed, the Supreme Court has expressly rejected the same argument the Secretary now raises. In Goldberg, which involved the termination of welfare benefits, the Court recognized that welfare benefits are a matter of statutory entitlement for persons qualified to receive them, and thus, [t]he constitutional challenge cannot be answered by an argument that public assistance benefits are a privilege and not a right. 397 U.S. at 262. Similarly, the Supreme Court in Paul expressly See Anderson v. Celebrezze, 460 U.S. 780 (1983; Burdick v. Takushi, 504 U.S. 428 (1992. Making it impossible for voters who cannot vote in-person to cast a ballot is unjustifiable. At a minimum, the private interest of voters who cannot vote in-person to vote absentee is extremely weighty because they have no other option. 3

5 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 5 of 22 recognized that a variety of interests which are difficult of definition... are nevertheless comprehended within the meaning of either liberty or property... by virtue of the fact that they have been initially recognized and protected by state law. 424 U.S. at 711 (emphasis added. The Supreme Court has repeatedly ruled that the procedural guarantees of the Fourteenth Amendment apply whenever the State seeks to remove or significantly alter that protected status. Id. A pair of Eleventh Circuit cases are illustrative. In Grayden v. Rhodes, 345 F.3d 1225 (11th Cir. 2003, the Eleventh Circuit held that it violated due process to evict tenants living at Lafayette Square without providing adequate notice and an opportunity to be heard. When weighing the private interest, the Eleventh Circuit found that the tenants primary interest is one of undeniably great magnitude: they seek to protect their interest in enjoying uninterrupted occupancy in their residence of choice, and that they also had an important interest in maintaining their residence, in the long term, at Lafayette Square. Id. at These interests were weighty even though no one had a federal constitutional right to live in Lafayette Square, even though nothing in the Constitution required the city to build Lafayette Square, even though nothing prohibited the city from regulating the terms of who was allowed to live there, and even though it was undeniably a privilege and a 4

6 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 6 of 22 convenience for people to choose to do so. But once the tenants have made that choice, their private interest in maintaining that residence became weighty. Similarly here, once absentee voters have made their lawful choice to vote by absentee ballot and have complied with all of the requirements for doing so, their interest in having their absentee ballot counted became particularly weighty. In Catron v. City of St. Petersburg, 658 F.3d 1260 (11th Cir. 2011, the Eleventh Circuit held that it violated due process to issue trespass ordinances to people in publicly-accessible spaces without an opportunity to be heard. When weighing the private interest, the Eleventh Circuit found that the plaintiffs possess a private liberty interest in lawfully visiting city property that is open to the public. Id. at This interest was significant even though the city had every right to make certain properties no longer open to the public, even though no one has a federal constitutional right to set foot wherever they want, even though nothing in the Constitution requires cities to open all spaces to the public, and even though it was undeniably a privilege and a convenience for the city to have opened certain places to the public. But once persons chose to access those spaces open to the public, the city could not suddenly kick them out of those spaces without providing due process. 5

7 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 7 of 22 As for the interest of absentee ballot applicants to receive an absentee ballot, their interest is just as important. An absentee voter cannot cast an absentee ballot without first applying for the ballot. The private interest in having a validlysubmitted absentee ballot application accepted is thus just as weighty as the private interest in having a validly-cast absentee ballot counted. The Fifth Circuit in United States v. Atkins, 323 F.2d 733 (5th Cir. 1963, 4 makes this connection clear. The right at issue in Atkins was the right to register to vote, not the right to vote. Nevertheless, the Fifth Circuit the right to register important enough to deserve due process protections because it was the mandatory gateway to voting, and [t]he right to vote is one of the most important and powerful privileges which our democratic form of government has to offer. Id. at 743 (emphasis added. Critically for the case at hand, the Fifth Circuit arrived at that conclusion even though the registrant could theoretically attempt to re-register to vote and try to prove their good moral character a countless number of times after their registration form was initially declined. It is no answer to say that the private 4 In Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir (en banc, the Eleventh Circuit adopted as binding precedent all decisions of the former Fifth Circuit handed down prior to October 1,

8 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 8 of 22 interest is light simply because a rejected absentee ballot applicant can just apply again. B. The Risk of Error is High, and Additional Procedures Have Great Probative Value The Secretary s argument concerning the second Mathews factor, Sec y Stay Br. at 10-11, repeats essentially the same arguments made in the Secretary s initial opposition brief, Sec y Opp n Br. at For the reasons given in this Court s order, Order at 24-25, the Secretary s argument is without merit. Curiously, the Secretary also argues that [r]equiring the state to conduct hearings or other additional process regarding a voter s identity is completely unnecessary since that simple verification of identity can be accomplished by the voter simply showing up at the county election office. Sec y Stay Br. at 11. But that is all that the TRO requires that the voter (or their attorney or attorney in fact show up at the county election office with identification. Indeed, that is what the Secretary asked for in his objections to the proposed order: a more informal and manageable process, of allowing voters to simply provide proof of identification to the county election official, which could cause less disruption to county election officials. Dkt. No. 31 at 2. The Secretary cannot now argue that the identity confirmation procedure he himself requested (and for which he is currently advocating as a means of simple verification of identity is not useful. 7

9 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 9 of 22 C. Additional Procedures Are Not So Burdensome As to Outweigh the Right to Vote As for the third Mathews factor, the Secretary argues that allowing an attorney to represent the voter when confirming the voter s identity introduces a risk of fraud particularly absent any kind of oath or affidavit requirement for the attorney presenting the voter s identification. Sec y Stay Br. at This concern is specious, since the Secretary s earlier objections to the Court s proposed order expressed no concern with individual voters faxing or ing a copy of one s photo identification to election officials. Dkt. No. 31 at 2. In-person presentation under the TRO, even by an attorney or attorney in fact, is more stringent than the process the Secretary was comfortable with just two days ago. In any event, Plaintiffs have no objection to requiring attorneys or attorneys in fact to sign an oath, under penalty of perjury, before presenting a copy of photo identification confirming the voter s identity. The Secretary also argues that these changes will require other significant administrative burdens, including significant changes to how at least some counties track absentee ballot rejections; changes to the systems for tracking absentee ballot voters; and more. Sec y Stay Br. at 12 (citing Dkt. No (Harvey Supp. Decl But he Secretary concedes this procedure is not impossible, Dkt. No (Harvey Supp. Decl. 5, even in the window of time before the election, and 8

10 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 10 of 22 makes no claim that these changes would impose intractable costs or burdens to implement outside the context of this election, see Dkt. No (Harvey Decl. 15. As previously noted, it was to account for the Secretary s concerns for a more informal and manageable process, which could cause less disruption to county election officials, Dkt. No. 31 at 2, that the Court ordered the simple verification process to confirm identity that the Secretary himself proposed. While the question of whether these changes are too burdensome to do before this year s elections may go to other equitable factors in a stay analysis (discussed below, they do not go to liability. The third Mathews factor does not change over time, depending on whether there is an upcoming election. This factor thus tilts in favor of Plaintiffs. See Zinermon v. Burch, 494 U.S. 113, 137 (1990 ( we cannot say that postdeprivation process was impossible. The remainder of the Secretary s arguments concerning facial due process claims and attempting to distinguish other signature-mismatch cases, Sec y Stay Br. at 14-18, were already previously raised, Sec y Opp n Br. at 18-21, 25-29, and rejected by this Court. They should be rejected again for the same reasons. 9

11 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 11 of 22 III. THERE IS NO IRREPARABLE HARM TO THE SECRETARY THAT JUSTIFIES A STAY A. The TRO Does Not Prevent the Secretary From Enforcing Any Statute The Secretary argues, for the first time, that the TRO would cause him irreparable harm because [a]ny time a State is enjoined by a court from effectuating statutes enacted by representatives of its people, it suffers a form of irreparable injury. Maryland v. King, 567 U.S. 1301, 1301 (2012 (Roberts, C.J., in chambers. Sec y Stay Br. at The Secretary did not raise this argument in the primary briefing when arguing about the equities, so it is waived. In any event, the TRO does not prevent the Secretary from doing something a statute requires, or even authorizes, him to do. Indeed, as the Secretary himself has repeatedly confirmed, the challenged statute does not require the Secretary to do anything at all. Sec y Opp n Br. at The TRO also does not enjoin the effectuation of any statute as a practical matter. As Defendants conceded at oral argument, counties already permit voters to verify their signatures through extrinsic evidence on an ad hoc basis, Order at 25, which means that elections officials do not construe the statute as prohibiting what the TRO requires. See N.M. Dep t of Game and Fish v. U.S. Dep t of the Interior, 854 F.3d 1236, (10th Cir King is also distinguishable because the injunction there 10

12 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 12 of 22 completely prevented the State from implementing a law that required it to collect DNA for public safety purposes. Here, the TRO does not enjoin elections officials from comparing signatures for identity confirmation purposes, and it still satisfies the State s interest in preventing voter fraud by requiring absentee voters to verify their identity by presenting identification the very procedure the Secretary himself has recommended. See Ga. State Conf. of the NAACP v. Fayette Cty. Bd. of Comm rs, 118 F. Supp. 3d 1338, 1348 (N.D. Ga Lastly, the Secretary cannot credibly claim irreparable harm from the mere fact that an injunction prevents implementation of a state election law (which the TRO does not even do in this case, or that this form of irreparable harm suffered always trumps the equitable reasons necessitating the issuance of the injunction in the first instance. The Supreme Court has consistently reaffirmed the role of federal courts in reviewing legislation that threatens the right to vote, cf. Tashjian v. Republican Party of Conn., 479 U.S. 208, 217 (1986 ( The power to regulate the time, place, and manner of elections does not justify, without more, the abridgement of fundamental rights, such as the right to vote, while recognizing the irreparable injury that necessarily inures from unlawful restrictions on constitutional rights, see Elrod v. Burns, 427 U.S. 347, 373 (1976; see also League of Women Voters of N.C. v. North Carolina, 769 F.3d 224, 247 (4th Cir. 11

13 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 13 of ( Courts routinely deem restrictions on fundamental voting rights irreparable injury.... [O]nce the election occurs, there can be no do-over and no redress. The injury to these voters is real and completely irreparable if nothing is done to enjoin this law., cert. denied, 135 S. Ct (2015. B. The Concerns Raised in Hand v. Scott Do Not Justify a Stay The Secretary relies heavily on the Eleventh Circuit s stay of an injunction in Hand v. Scott, 888 F.3d 1206, 1214 (11th Cir. 2018, but the case is distinguishable in multiple respects. First, the injunction in Hand infringed voting rights by preventing state officials from immediately reenfranchising voters under its vast discretion. Hand, 888 F.3d at Here, by contrast, staying the TRO would result in the permanent disenfranchisement of absentee voters in this election. Second, the injunction in Hand prevented state officials from doing what the statute required it to do exercise its discretion to reenfranchise voters with a criminal record. Here, as noted above, the TRO does not prohibit the Secretary from doing anything that a statute requires him to do. In fact, it requires actions Defendants have always believed they had the power to do. Third, the injunction in Hand required state officials to create brand new procedures out of whole cloth applied to potentially upwards of a million people 12

14 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 14 of 22 with criminal records. 5 Here, the TRO simply applies existing due process protections on the back end, O.C.G.A (g, to the mere hundreds (as discussed below of absentee voters facing disenfranchisement due to a signature mismatch. Fourth, the injunction in Hand changed the front-end rules that people with criminal records had to follow in order to be reenfranchised. Here, the TRO does not change any of the rules for casting an absentee ballot, any of the written instructions on the absentee ballot, or the obligation of elections officials to compare signatures. As noted in Plaintiffs reply brief, courts routinely enter injunctive relief close to an election where, as here, the relief deals solely with back-end procedures implemented after ballots or registration forms have already been submitted, including procedures implemented after Election Day. Pls. Reply Br. at 11 n.3. In sum, the equites in Hand tilted strongly in favor of a stay, serving both elections officials and voters because it allowed state officials to continue 5 See Gabby Deutch, Florida Felons Want Their Voting Rights Restored, The Atlantic, Sept. 13, 2018, available at: (last visited October 27, 2018 (estimating 1.5 million felons in Florida. 13

15 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 15 of 22 reenfranchising voters under the powers entrusted to it by statute. Those same considerations point in the opposite direction here: denying a stay of the TRO will similarly prevent permanent disenfranchisement, without requiring elections officials to do anything they do not already know how to do, nor anything that a statute expressly prohibits. Denying a stay would still allow the State to enforce the signature match procedures, adopt an identity verification process the Secretary himself endorsed, all while allowing absentee voters who have done everything right to have their votes counted in this election. C. Unspecified Administrative Burdens Do Not Cause Irreparable Harm The Secretary elsewhere asserts that the TRO will require other significant administrative burdens, including significant changes to how at least some counties track absentee ballot rejections; changes to the systems for tracking absentee ballot voters; and more. Sec y Stay Br. at 12 (citing Dkt. No (Harvey Supp. Decl But this assertion does not explain how these harms are irreparable in other words, how such changes are somehow irreversible. In any event, this vague assertion is light on specifics. For example, how many counties out of the 159 counties track absentee ballot rejections, and which ones? What changes to the systems is the Secretary specifically referring to? What more? 14

16 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 16 of 22 Rather than articulating how the Election Director s Supplemental Declaration establishes irreparable harm, the Secretary merely cites it and leaves this Court to decipher the Declaration for itself. Based on the Declaration, it appears that the Secretary s alleged burden focuses primarily on an administrative procedural change involving the manual recategorization of mismatch voters in the enet system. See Dkt. No (Harvey Supp. Decl Putting aside the fact that it is not clear how these harms accrue to the Secretary, who is not responsible for this recategorization work, the Secretary has failed to establish how these administrative procedural changes are irreparable to him. Nor are generic allegations about a resource drain for state and local officials sufficient to justify a stay. U.S. Student Ass n Found. v. Land, 546 F.3d 373, 387 (6th Cir The Secretary does not indicate how long it takes, for instance, to recategorize a single voter in enet, how many more hours it would take, how many extra employees (if any it would require, or how many counties (the unknown number of counties who use enet would have to do it. Even in Fish v. Kobach, No JAR, 2016 WL (D. Kan. May 25, 2016, where the defendant provided considerable detail in terms of how much time and money it would take to make certain changes to each voter s record, the court still found that the expenditures were not so burdensome as to be irreparable, id. at *3. And 15

17 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 17 of 22 that case involved changing the records of thousands of voters, while this TRO involves changing the records of mere hundreds, as discussed below. The district court s denial of a stay was subsequently affirmed by the Tenth Circuit. See Exhibit A. The vague assertions of harm in this case do not justify a stay. The fact that the TRO impacts a small fraction of Georgia s absentee voters further reduces the burden on elections officials. See Land, 546 F.3d at 387 (change is not a precipitate alteration to the state s entire voting methodology since the injunction affects a small fraction of Michigan voters. Notably, it does not appear to establish any significant burden in applying the TRO to rejected absentee ballot applications, which number far higher than rejected absentee ballots, so the alleged burden seems only to deal with absentee ballots. And the Secretary has repeatedly insisted that the number of absentee voters with perceived signature mismatches is low. See Sec y Stay Br. at 10 (only nine absentee ballots rejected on this basis so far; Dkt. No (Harvey Decl. 11 (rejected absentee ballots due to signature mismatch constituted 0.009% of all ballots in 2014 and 0.01% of all ballots in By that estimate, there were only about 234 absentee ballot signature match rejections in 2014 and about 405 absentee ballot signature 16

18 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 18 of 22 match rejections in And the Elections Director concedes that due to the limited number of ballots that have been rejected for the reason that the signature does not match, [county officials] believe that they can make [the] update. Harvey Supp. Decl. 7. Lastly, a stay is not a matter of right, even if irreparable injury might otherwise result to the [applicant]. Nken v. Holder, 556 U.S. 418, 438 (2009. As discussed below, other factors weigh against a stay. IV. A STAY WOULD SUBSTANTIALLY INJURE PLAINTIFFS Plaintiffs will be substantially injured by a stay. The Secretary speculates that Plaintiffs will divert the same amount of resources towards this issue regardless of whether a stay applies, but that is simply false. As this Court correctly found, the organizational Plaintiffs will not bear the same burden of assisting and warning voters once the State is required to assist voters whose ballots are challenged as illegitimate and once the urgency of warning voters is 6 At least 4,045,613 ballots were cast in See Secretary of State, Georgia Breaks All-Time Voting Record, available at: (last visited October 26, % of that number is about ,596,947 total ballots were cast in See Georgia Election Results, available at: (last visited October 26, % of that number is about

19 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 19 of 22 diminished by way of due process protections. Order at 16. If a stay is issued, Plaintiffs will have to continue diverting substantial resources towards ensuring that absentee voters are not permanently disenfranchised because of a signature mismatch and away from other voter education and mobilization efforts that can only be accomplished during this critical period before Election Day. V. A STAY WOULD NOT BE IN THE PUBLIC INTEREST, AND WILL RESULT IN PERMANENT DISENFRANCHISEMENT Lastly, a stay would not be in the public interest, for the reasons this Court already provided. Order at As this Court has recognized, without a TRO, absentee voters who cannot vote in-person, and whose applications or ballots are rejected due to a signature mismatch, will be permanently disenfranchised without a TRO. Absentee voters who receive rejection notices after Election Day will also be permanently disenfranchised. Respectfully submitted, this 27th of October, 2018 s/ Sean J. Young Sean J. Young (Ga. Bar No AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF GEORGIA, INC. P.O. Box Atlanta, GA (phone (fax syoung@acluga.org 18

20 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 20 of 22 Sophia Lin Lakin Dale E. Ho AMERICAN CIVIL LIBERTIES UNION 125 Broad Street, 18th Floor New York, NY (phone Attorneys for Plaintiffs

21 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 21 of 22 CERTIFICATE OF COMPLIANCE I hereby certify that the foregoing brief has been prepared in accordance with the font type and margin requirements of LR 5.1, using font type of Times New Roman and a point size of 14. s/ Sean J. Young Sean J. Young (Ga. Bar No AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF GEORGIA, INC. P.O. Box Atlanta, GA (phone (fax syoung@acluga.org

22 Case 1:18-cv LMM Document 36 Filed 10/27/18 Page 22 of 22 CERTIFICATE OF SERVICE I hereby certify that on October 27, 2018, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system. Counsel for Defendants have entered notices of appearance in this case, and will thus receive electronic notice of the filing. Date: October 27, 2018 s/ Sean J. Young Sean J. Young (Ga. Bar No AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF GEORGIA, INC. P.O. Box Atlanta, GA (phone (fax syoung@acluga.org

23 Georgia Muslim Voter Project et al v. Kemp et al, Docket No. 1:18-cv (N.D. Ga. Oct 16, 2018, Court Docket General Information Court Federal Nature of Suit Docket Number United States District Court for the Northern District of Georgia; United States District Court for the Northern District of Georgia Civil Rights - Voting[441] 1:18-cv The Bureau of National Affairs, Inc. All Rights Reserved. Terms of Service // PAGE 23