Farrakhan v. Washington

Facts

Upon conviction of an infamous crime in the state of Washington, such a defendant was disenfranchised, and none has had his voting rights restored. Ps were convicted of felonies in Washington state and consequently disenfranchise under Article VI, Section 3 of the Washington State Constitution. Ps' challenged the disenfranchisement scheme on federal constitutional grounds and as violative of the Voting Rights Act. They sought both declaratory and injunctive relief to enjoin D from applying the voting restriction and related statutory provisions against all felons. Ps presented statistical evidence of the disparities in arrest, bail and pre-trial release rates, charging decisions, and sentencing outcomes in certain aspects of D’s criminal justice system. One such statistic showed that although African-Americans constituted 3% of Washington’s overall population, they accounted for 37% of the “persistent offender” sentences handed down by Washington courts. The district court determined that D's felon disenfranchisement scheme does disenfranchises a disproportionate number of African-American, Hispanic-American, and Native-American minorities, the cause of this disparate impact on their right to vote was external to the felon disenfranchisement provision itself. Thus, there was no causal connection between the voting qualification and the prohibited discriminatory result. The district court held that evidence of discrimination in the criminal justice system was not significant for purposes of the “totality of the circumstances” analysis used in determining whether a challenged voting practice results in a denial of minority voting rights under Section 2. It held there was no evidence that the enactment of D’s disenfranchisement provision “was motivated by racial animus, or that its operation by itself has a discriminatory effect.” Ps appealed.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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