Case: 1:16-cv-07832 Document #: 25 Filed: 08/30/16 Page 1 of 5 PageID #:333 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION PATRICK HARLAN, et al., Plaintiffs, v. CHARLES W. SCHOLTZ, Chairman, Illinois State Board of Elections, et al., Defendants. ) ) ) ) ) ) ) ) ) ) Case No. 1:16-cv-7832 Hon. Samuel Der-Yeghiayan UNCONTESTED MOTION OF AMERICAN CIVIL LIBERTIES UNION OF ILLINOIS, CHICAGO LAWERS’ COMMITTEE FOR CIVIL RIHTS UNDER LAW, LEAGUE OF WOMEN VOTERS OF ILLINOIS, BETTER GOVERNMENT ASSOCIATION, AND ILLINOIS CAMPAIGN FOR POLITICAL REFORM FOR LEAVE TO FILE BRIEF AMICI CURIAE IN OPPOSITION TO PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION The American Civil Liberties Union of Illinois, Chicago Lawyers’ Committee for Civil Rights Under Law, League of Women Voters of Illinois, the Better Government Association, and the Illinois Campaign for Political Reform (collectively “amici”), by their counsel, respectfully request leave to file the attached brief amici curiae in this matter. In support of this motion, the amici state as follows: 1. Amici are nonprofit, nonpartisan organizations that advocate for full and equal access to the franchise. 2. The American Civil Liberties Union of Illinois is the state affiliate of the American Civil Liberties Union (“ACLU”), a nationwide, nonprofit, nonpartisan organization with more than 500,000 members dedicated to the principles of liberty and equality embodied in the Constitution. For decades, the ACLU has been at the forefront of litigation and advocacy protecting the right to vote and ensuring equal access to the ballot for all Americans. Case: 1:16-cv-07832 Document #: 25 Filed: 08/30/16 Page 2 of 5 PageID #:334 3. The Chicago Lawyers’ Committee for Civil Rights Under Law, Inc. (“Chicago Lawyers’ Committee”) is a non-profit, non-partisan organization and is the public interest law consortium of Chicago’s leading law firms. Chicago Lawyers’ Committee was established in 1969 with the mission to promote and protect civil rights, particularly the civil rights of lowincome, minority, and disadvantaged people. The Voting Rights Project of Chicago Lawyers’ Committee prevents, reduces, and eliminates barriers to voting for African Americans, Latinos, and other minority residents within Illinois. 4. The League of Women Voters of Illinois is a non-partisan political organization that encourages informed and active participation in government and elections, works to increase understanding of public policy issues, and seeks to influence public policy through education and advocacy. 5. The Better Government Association is a 93-year-old non-partisan, non-profit organization that works for integrity, transparency, and accountability in government by exposing corruption and inefficiency; identifying and advocating effective public policy; promoting public participation in government; and engaging and mobilizing the electorate to achieve authentic and responsible reform. 6. The Illinois Campaign for Political Reform (ICPR) is a non-profit and non- partisan public interest organization that conducts research and advocates reforms to promote public participation and to encourage integrity, accountability, and transparency in both Illinois government and election processes. ICPR facilitates bipartisan dialogue around a range of reform issues in order to advance honest, open, and accountable government and reinvigorate public confidence and civic involvement. ICPR has been supportive of many efforts to increase voting access in Illinois. 2 Case: 1:16-cv-07832 Document #: 25 Filed: 08/30/16 Page 3 of 5 PageID #:335 7. The plaintiffs in this case are requesting extraordinary relief: a preliminary injunction to change the rules less than three months ahead of an election, in a way that is likely to affect tens of thousands of voters. Amici respectfully suggest that it will be helpful to the Court to have a broad range of viewpoints available to make this critical decision in such a short time. 8. Amici do not repeat the arguments presented by the parties but instead seek to “help the court beyond the help that the lawyers for the parties are able to provide,” Ryan v. CFTC, 125 F.3d 1062, 1063 (7th Cir. 1997). Amici present a perspective that the parties to the case do not: that of the voters who will be turned away from the polls if plaintiffs’ request is granted. Furthermore, in light of that perspective, amici present a remedy that is different from that proposed by the plaintiffs: an injunction expanding Election Day registration in polling places to all counties in Illinois. 9. Counsel for plaintiffs and intervenor have indicated that they do not object to this motion. Counsel for defendants have said that they take no position on this motion. For the foregoing reasons, amici respectfully request that the Court enter an order granting it leave to file the attached brief amici curiae in opposition to plaintiffs’ motion for preliminary injunction. Dated: August 30, 2016 Respectfully submitted, /s/ Rebecca K. Glenberg Counsel for Amici Curiae American Civil Liberties Union of Illinois, Chicago Lawyers’ Committee for Civil Rights Under the Law, League of Women Voters of Illinois, Better Government Association, and Illinois Campaign for Political Reform 3 Case: 1:16-cv-07832 Document #: 25 Filed: 08/30/16 Page 4 of 5 PageID #:336 Rebecca K. Glenberg ROGER BALDWIN FOUNDATION OF ACLU, INC. 180 N. Michigan Ave., Suite 2300 Chicago, IL 60601-7401 Telephone: 312-201-9740 Fax: 312-288-5225 rglenberg@aclu.org Ami D. Gandhi CHICAGO LAWYERS’ COMMITTEE FOR CIVIL RIGHTS UNDER LAW, INC. 100 N. LaSalle St., Suite 600 Chicago, IL 60602 Telephone: 312-888-4193 Fax: 312-630-1127 agandhi@clccrul.org 4 Case: 1:16-cv-07832 Document #: 25 Filed: 08/30/16 Page 5 of 5 PageID #:337 CERTIFICATE OF SERVICE I, Rebecca K. Glenberg, certify that I caused a copy of the MOTION FOR LEAVE TO FILE BRIEF AMICI CURIAE to be served to counsel of record via the ECF system of the U.S. District Court, Northern District of Illinois, Eastern Division, on this 30th day of August, 2016. /s/ Rebecca K. Glenberg 5