Trump Scores Major Legal Win as Two Courts Reject Key Voter-Suppression Claims and Back Stronger Election Security Measures

Texas and Minnesota Courts Uphold Election Rules—But the Two Victories Rest on Narrower Grounds Than the Politics Suggests
Election-law battles produced sharply different results this week.
In Boston, a federal judge again blocked part of President Donald Trump’s attempt to impose new federal rules on mail voting.
At almost the same time, two other courts handed victories to defenders of state election restrictions.
The U.S. Court of Appeals for the Fifth Circuit reversed an injunction against nine provisions of Texas’s 2021 election law.
And the Minnesota Supreme Court upheld the state’s requirement that absentee voters obtain a witness certification.
Taken together, the rulings show that courts are willing to uphold election safeguards in some circumstances.
But they do not establish that every rule labeled “election integrity” is lawful—or that every civil-rights challenge to an election law is simply an attempt to defeat security measures.
The Texas decision is the broader of the two.
On August 12, a unanimous three-judge Fifth Circuit panel reversed a permanent injunction against nine provisions of Senate Bill 1 under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act.
Judge Andrew Oldham wrote the opinion.
One factual correction matters immediately.
Oldham is a judge on the U.S. Court of Appeals for the Fifth Circuit, not a U.S. district judge.
He was appointed to the appellate court by Trump.
The trial-court ruling being reversed was issued by U.S. District Judge Xavier Rodriguez in the Western District of Texas.
S.B. 1 requires mail voters to provide an identification number that can be matched to state records.
It also contains procedures for curing defective applications or ballots, regulates people who assist voters and restricts compensation connected to certain election-related activities.
Disability and voting-rights organizations argued that several of those provisions created unlawful barriers for voters with disabilities.
The Fifth Circuit reversed the injunction in full.
But the reason matters.
For the mail-ballot identification provisions, the panel did not conduct a full merits review and declare every burden permissible under the ADA.
It held that the plaintiffs lacked Article III standing to seek prospective relief.
An organization seeking an injunction on behalf of its members had to identify someone facing a “substantial risk” of future injury.
The court concluded the record did not show that risk.
The opinion discussed disabled voters who had experienced problems with the new rules in 2022, including rejected applications, difficulty using the online ballot tracker and failure to place an identification number on a ballot envelope.
But the panel emphasized that those voters had since learned how to comply or had successfully voted in later elections.
It therefore found no substantial risk that they would suffer the same injury again.
The court also rejected organizational standing based merely on resources the groups chose to spend educating voters about S.B. 1.
The voter-assistance claims largely failed for similar standing reasons.
One portion did reach the merits.

The plaintiffs could challenge certain compensation provisions against local prosecutors, but the Fifth Circuit held that the ADA theory still failed because district attorneys who prosecute election crimes are not the officials who provide voting services to voters with disabilities.
They enforce criminal laws.
They do not administer the voting program itself.
That was enough for the court to reject the disability-discrimination claim against those prosecutors.
That is a significant legal victory for Texas.
Nine provisions that had been permanently enjoined are no longer blocked by that order.
Oldham’s opinion also used unusually sharp language in describing years of litigation over S.B. 1.
But the holding remains narrower than some of the political celebration around it.
Most of the claims failed because the plaintiffs could not establish standing, not because the court determined after a complete merits review that every challenged practice was harmless to voters with disabilities.
The mail-ballot rejection numbers are another place where context matters.
The Fifth Circuit noted that rejections caused by missing or mismatched identification numbers fell from roughly 11 or 12 percent to 2.7 percent within about eight months.
The court used that decline as evidence against the prediction that the named voters faced a substantial risk of future disenfranchisement.
That is relevant to standing.
It does not prove that S.B. 1 itself produced better voting outcomes than the system Texas used before the law.
The first election under the new rules tells a more complicated story.
In the March 2022 primary, about 12.4 percent of returned mail ballots were rejected—more than 24,000 ballots.
That was dramatically higher than prior statewide elections.
Fewer than 1 percent of Texas mail ballots were rejected in the 2020 presidential election, and the 2018 midterm rate was also lower than the 2.7 percent recorded in November 2022.
So the stronger conclusion is narrower.
Voters and election officials became much better at navigating S.B. 1 after its difficult first rollout.
The data do not establish that the law lowered rejection rates below pre-S.B. 1 levels.
That distinction explains why disability-rights advocates still object to the law.
Their argument is not only about the final number of rejected ballots.
They contend that equal access under disability law includes the process itself, and that extra paperwork, inaccessible systems or repeated cure procedures can burden voters even if some ultimately succeed.
The Fifth Circuit rejected the standing theory in this appeal.
That is not the same thing as proving every access concern was imaginary.
Minnesota produced a second important decision on August 12.
The Minnesota Supreme Court affirmed a lower appellate ruling and upheld the state’s witness-certification requirement for absentee ballots.
The plaintiffs in Minnesota Alliance for Retired Americans Educational Fund v. Simon argued that the rule violated the Voting Rights Act’s prohibition on certain “voucher” requirements and the Civil Rights Act’s Materiality Provision.
The state supreme court rejected both claims.
Minnesota requires an absentee voter to complete a certificate on the signature envelope and obtain an eligible witness.
Under current law, the witness generally may be a U.S. citizen who is at least 18 years old or a notary or other person authorized to administer oaths.
The witness observes specified parts of the absentee-voting process and signs the certificate.
For an unregistered absentee voter, the witness may also certify that acceptable proof of residence was displayed.
On the Voting Rights Act claim, the court held that the witness is not acting as a prohibited voucher of the voter’s legal qualifications.
The witness does not personally guarantee the voter’s citizenship, age or full residency qualification.
Instead, the witness generally attests to conduct the witness observed.
The court therefore concluded that the requirement does not violate the federal vouching prohibition.
The Minnesota Supreme Court also rejected the Civil Rights Act claim involving registered voters.
The plaintiffs argued that a ballot can be rejected because of an error or omission in the witness certification even when the mistake has nothing to do with voter eligibility.
The court interpreted the federal Materiality Provision more narrowly and held that the witness certification for registered voters is not the kind of record or paper relating to an “act requisite to voting” covered by that provision.
That left the plaintiffs without an actionable claim under the theory they presented.
That is a clear win for Minnesota’s witness rule.
But two claims in the original political framing go beyond what the court decided.
First, this was not a case about third-party ballot harvesters.
Minnesota has separate rules allowing certain voters to use an agent to pick up and return an absentee ballot.
The August 12 case did not decide whether third-party ballot collection is lawful or how broadly it should be permitted.
It decided whether the witness-certification requirement violates two specified federal civil-rights statutes.
Second, the court did not individually approve roughly 6,000 rejected ballots.
Litigation surrounding the case cited thousands of absentee ballots rejected in 2022 in connection with witness-related requirements, while the state disputed how the larger figure was being characterized.
Contemporaneous reporting also showed roughly 6,200 mail ballots deemed ineligible at one point for multiple reasons, with missing witness signatures making up a substantial share.
The Minnesota Supreme Court did not audit those individual ballots or hold that every rejection was correct.
It upheld the legal requirement itself against the two federal claims before it.
That difference matters.

A court can uphold a rule without deciding that election officials applied it correctly in every case.
It can also reject one statutory theory without resolving every possible challenge.
The Minnesota opinion was a statutory-interpretation decision.
It was not a general finding that third-party ballot collection creates fraud, and it did not hold that witness rules can never burden lawful voters.
The broader claim that the ADA, Rehabilitation Act, Voting Rights Act and Civil Rights Act have simply been “weaponized” against election security also goes beyond these rulings.
Those statutes create enforceable protections enacted by Congress.
Plaintiffs can lose because they lack standing, because a statute does not cover the practice they challenge or because the evidence does not establish discrimination.
They can also win when an election rule actually conflicts with federal law.
Unsuccessful litigation does not, by itself, prove that the civil-rights law being invoked is illegitimate.
The contrast with Judge Indira Talwani’s ruling in Boston makes that point.
Talwani, an Obama appointee, issued a nationwide preliminary injunction on August 11 preventing the U.S. Postal Service from implementing Section 3 of Trump’s March executive order for federal elections held on or before November 3.
The provision called for new ballot-mail envelope standards, unique barcodes and state-specific lists of people receiving mail ballots.
Under the proposed system, USPS would refuse certain ballot mail that did not comply with the new federal requirements.
The Trump administration has asked the U.S. Supreme Court to intervene.
That case concerns a different legal question.
Talwani’s earlier June ruling concluded that the president had exceeded his authority by attempting to regulate election administration through executive action.
States generally run the mechanics of congressional elections, while the Constitution gives Congress power to alter many of those rules.
The president does not possess a free-standing Elections Clause power to create national voting procedures by executive order.
The August injunction also emphasized the risks of changing mail-voting rules less than 90 days before the midterms.
Whether higher courts agree remains part of the litigation.
Calling Talwani an “Obama judge” identifies the president who appointed her.
Calling her a “DEI judge” does not describe a legal holding and adds no verifiable information about the case.
The serious arguments are legal.
The administration says the challenge is premature and that the Postal Service has authority to regulate the mail.
Opponents argue that postal authority cannot be used to create voter-eligibility and ballot-delivery rules that Congress never enacted.
The three decisions therefore do not fit neatly into a single partisan theory.
Texas won largely because the plaintiffs could not establish the future injury required for standing and because one ADA theory failed on the merits.
Minnesota won because its highest court interpreted two federal civil-rights statutes not to reach the witness rule in the way the plaintiffs argued.
Trump lost at the district-court level in Boston because the judge concluded that the executive branch was attempting to exercise election-regulation authority it does not possess.
Those are different questions.
The Texas rejection-rate data deserves the same discipline.
A fall from roughly 12 percent to 2.7 percent is meaningful.
It shows that the extreme rejection problems seen when S.B. 1 first took effect did not persist at the same level.
It supports the Fifth Circuit’s skepticism that the named plaintiffs necessarily face the same future harm.
But it does not show that mail voting worked better than before S.B. 1.
The evidence supports improvement over the law’s initial rollout, not a simple before-and-after victory narrative.
The better argument for supporters of the Texas and Minnesota rules is narrower.
States have legitimate authority to adopt procedures designed to verify voters, regulate assistance and define how absentee ballots are completed.
Courts will not invalidate those rules merely because advocates describe them as discriminatory.
Plaintiffs still must establish standing and show that the particular law actually violates the federal statute they invoke.

Texas and Minnesota both benefited from that principle this week.
But the rule of law runs in the other direction too.
Calling a policy “election integrity” does not immunize it from constitutional review.
State safeguards remain subject to federal civil-rights statutes.
Federal officials remain subject to constitutional limits on executive power.
And a lower rejection rate after voters learn a new system does not erase the voters whose ballots were rejected when the system first changed.
So this week’s rulings settle several important questions.
The Fifth Circuit restored nine challenged provisions of Texas S.B. 1 from the ADA and Rehabilitation Act injunction before it.
The Minnesota Supreme Court held that the state’s witness-certification requirement does not violate the two federal provisions asserted in that case.
And a federal judge in Massachusetts has, for now, prevented USPS from implementing Trump’s new mail-ballot system nationwide before the November election.
What the rulings do not settle is the larger partisan argument over whether stricter election rules are inherently security measures or inherently voter suppression.
The courts did something narrower.
They applied different laws to different policies and reached different outcomes.
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For anyone trying to understand where election-integrity litigation is actually headed, that distinction matters more than declaring that one side has won the entire fight.