62-CV-20-3149

STATE OF MINNESOTA

Filed in District Court
State of Minnesota
7/17/2020 3:24 PM

DISTRICT COURT

COUNTY OF RAMSEY

SECOND JUDICIAL DISTRICT
Case Type: Civil

--------------------------------------------------------------------------------------------------------------------Robert LaRose, Teresa Maples, Mary Sansom,
Gary Severson, and Minnesota Alliance for Retired
Americans,

STIPULATION AND PARTIAL
CONSENT DECREE
Court File No: 62-CV-20-3149

Plaintiffs,
v.
Steve Simon, in his official capacity as Minnesota
Secretary of State,
Defendant.

Plaintiffs Robert LaRose, Teresa Maples, Mary Sansom, Gary Severson, and Minnesota
Alliance for Retired Americans, and Defendant Steve Simon (collectively, “the Parties”) stipulate
to the following and request that this Court approve this Partial Consent Decree. This Stipulation
and Partial Consent Decree is limited only to Plaintiffs’ claims as they pertain to the November 3,
2020 general election (“November General Election”) and is premised upon the current public
health crisis facing Minnesota caused by the ongoing spread of the novel coronavirus.
I.
RECITALS
WHEREAS on May 13, 2020, Plaintiffs filed a complaint against Defendant challenging
the constitutionality and enforcement of Minnesota’s requirement that each mail-in ballot be
witnessed by a registered Minnesota voter, a notary, or person otherwise authorized to administer
oaths (“Witness Requirement”), Minn. Stat. §§ 203B.07, 204B.45, and 204B.46, and its
requirement that ballots be received by 8:00 p.m. on Election Day if delivered by mail (the

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“Election Day Receipt Deadline”), id. §§ 203B.08 subd. 3; 204B.45, and 204B.46, Minn. R
.8210.2200 subp. 1 and 8210.3000 (collectively, “Challenged Provisions”), in general and
specifically during the ongoing public health crisis caused by the spread of the novel coronavirus;
WHEREAS among other relief requested, the Complaint seeks to enjoin enforcement of
the Challenged Provisions during the November General Election due, in part, to the public health
crisis caused by the spread of the novel coronavirus;
WHEREAS the coronavirus public health crisis is ongoing and Minnesota remains under
“Stay Safe” Emergency Executive Order 20-74, which contemplates a phased reopening of
Minnesota that continues to require social distancing and mandates that “[i]ndividuals engaging in
activities outside of the home follow the requirements of [the Stay Safe Order and Minnesota
Department of Health and Centers for Disease Control and Prevention (“CDC”)] Guidelines,”
Exec. Order 20-74 ¶ 6(a), and states that individuals “at risk of severe illness from COVID-19 . .
. [are] strongly urged to stay at home or in their place of residence,” id. ¶4;
WHEREAS Minnesota remains under a peacetime emergency, declared by the governor,
because the “COVID-19 pandemic continues to present an unprecedented and rapidly evolving
challenge to our State,” Emergency Executive Order 20-78;
WHEREAS Minnesota is currently witnessing an increase in positive COVID-19 cases,
Minnesota has had over 42,000 confirmed COVID-19 cases, with over 4,300 hospitalizations and
over 1,500 fatalities, and current projections indicate that the coronavirus crisis will continue into
the fall and well into the November General Election cycle;
WHEREAS cases continue to spread and climb across the country, and the director of the
National Institute of Allergy and Infectious Diseases recently warned that the country is still “kneedeep” in the first wave of the pandemic;

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WHEREAS federal guidelines state “[e]veryone should avoid close contact” by “keeping
distance from others,” CDC, Coronavirus Disease 2019: How to Protect Yourself & Others,
https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/prevention.html (last visited
July 13, 2020), and advise that jurisdictions “offer alternative voting methods that minimize direct
contact,” including “alternatives to in-person voting” such as absentee voting, CDC,
Recommendations for Election Polling Locations: Interim guidance to prevent spread of
coronavirus

disease

2019

(COVID-19),

https://www.cdc.gov/coronavirus/2019-

ncov/community/election-polling-locations.html (last visited July 13, 2020);
WHEREAS Minnesota is anticipated to be required to maintain social distancing and
abide by CDC Guidelines until the crisis subsides;
WHEREAS the absentee voting period for the November General Election begins on
September 18, 2020, 46 days prior to the date of the election, Minn. Stat. § 203B.081 subd.1; id.
§ 204B.35, and absentee instructions, ballots, and envelopes, including the certificate of eligibility,
must be prepared in time to have a supply for every precinct available to cover absentee voting
prior to that date;
WHEREAS available public data regarding transmission of COVID-19 supports
Plaintiffs’ concerns for their safety if they are required to interact with others to cast their ballot in
the November General Election;
WHEREAS anticipated increases in absentee balloting are already being observed for the
August 11, 2020 Primary Election and will continue in the November General Election, and
coupled with corresponding shortages of elections personnel and mail delays, appear likely to
impact the November General Election and threaten to slow down the process of mailing and
returning absentee ballots;

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WHEREAS the delivery standards for the Postal Service, even in ordinary times
contemplate, at a minimum, at least a week for ballots to be processed through the postal system
and delivered to election officials, “State And Local Election Mail—User’s Guide,” United States
Postal Service, January 2020, available at https://about.usps.com/publications/pub632.pdf (last
visited, July 13, 2020);
WHEREAS the Office of Inspector General for the United States Postal Service has
reported that states with absentee ballot request deadlines less than seven days before Election
Day, including Minnesota, are at “high risk” of ballots “not being delivered, completed by voters,
and returned to the election offices in time . . . due to the time required for election commissions
to produce ballots and Postal Service delivery standards.” Office of Inspector General, U.S.P.S.,
Rpt. No. 20-235-R20, Timeliness of Ballot Mail in the Milwaukee Processing & Distribution
Center

Service

Area

6-7

(2020),

available

https://www.uspsoig.gov/sites/default/files/document-library-files/2020/20-235-R20.pdf

at
(last

visited, July 13, 2020);
WHEREAS it was recently reported: “Mail deliveries could be delayed by a day or more
under cost-cutting efforts being imposed by the new postmaster general. The plan eliminates overtime
for hundreds of thousands of postal workers and says employees must adopt a ‘different mindset’ to
ensure the Postal Service’s survival during the coronavirus pandemic.” Matthew Daly, Mail delays
likely as new postal boss pushes cost-cutting, Mpls. Star Tribune (July 15, 2020);
WHEREAS on April 28, 2020, the Wisconsin Department of Health Services reported that
52 people who voted in person or worked the polls for Wisconsin’s April 7, 2020 primary election
have tested positive for COVID-19 thus far;

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WHEREAS courts in other states have enjoined those states from enforcing witness
requirements, similar to Minnesota’s witness requirement, for primary elections this spring. See
Thomas v. Andino, -- F. Supp. 3d. --, 2020 WL 2617329 (D.S.C. May 25, 2020); League of Women
Voters of Va. v. Va. State Bd. of Elections, -- F. Supp. 3d --, 2020 WL 2158249, at *8 (W.D. Va.
May 5, 2020) (“In our current era of social distancing-where not just Virginians, but all Americans,
have been instructed to maintain a minimum of six feet from those outside their household–the
burden [of the witness requirement] is substantial for a substantial and discrete class of Virginia's
electorate. During this pandemic, the witness requirement has become both too restrictive and not
restrictive enough to effectively prevent voter fraud.”);
WHEREAS for the April 7, 2020 primary election in Wisconsin, the U.S. Supreme Court
affirmed the implementation of a postmark rule, whereby ballots postmarked by Election Day
could be counted as long as they were received within six days of Election Day, Republican Nat’l
Comm. v. Democratic Nat’l Comm., 140 S. Ct. 1205, 1207 (2020), and other courts have also
enjoined Election Day Receipt Deadlines during the current public health crisis, see Driscoll v.
Stapleton, No. DV 20-408, slip op. at 11 (Mont. Dist. Ct. May 22, 2020); see also Republican
Nat’l Comm., 140 S.Ct. at 1210 (Ginsburg, J., dissenting) (noting that, in Wisconsin, the “surge in
absentee-ballot requests has overwhelmed election officials, who face a huge backlog in sending
ballots”);
WHEREAS multiple courts have found that the pandemic requires or justifies changes to
other aspects of states’ election laws, see, e.g., People Not Politicians Oregon v. Clarno, 20-cv1053, 2020 WL 3960440 (D. Or. July 13, 2020); Cooper v. Raffensperger, -- F. Supp. 3d --, 20cv-1312, 2020 WL 3892454 (N.D. Ga. July 9, 2020); Reclaim Idaho v. Little, 20-cv-268, 2020
WL 3892454 (D. Idaho June 26, 2020); Libertarian Party of Ill. v. Pritzker, 20-cv-2112, 2020 WL

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1951687 (N.D. Ill. Apr. 23, 2020); Paher v. Cegavske, -- F. Supp. 3d --, 20-cv-243, 2020 WL
2089813 (D. Nev. Apr. 30, 2020);
WHEREAS the Parties agree that an expeditious resolution of this matter for the
November General Election, in the manner contemplated by the terms of this Stipulation and
Partial Consent Decree, will limit confusion and increase certainty surrounding the November
General Election, including in the days remaining before the September 18, 2020 deadline for
absentee ballot preparation, and is in the best interests of the health, safety, and constitutional rights
of the citizens of Minnesota, and, therefore, in the public interest;
WHEREAS the Parties wish to avoid the burden and expense of litigation over an
expedited preliminary injunction for the November General Election;
WHEREAS the Parties, in agreeing to these terms, acting by and through their counsel,
have engaged in arms’ length negotiations, and both Parties are represented by counsel
knowledgeable in this area of the law;
WHEREAS, on June 17, 2020, this Court signed and approved a stipulation and partial
consent decree implementing substantially similar relief for the August 11, 2020 primary election;
WHEREAS voters have been informed about the rule changes for the primary election,
voting has begun with those rules in place, and it would minimize confusion to have consistent
rules regarding how elections are conducted during this pandemic;
WHEREAS it is the finding of this Court, made on the pleadings and upon agreement of
the Parties, that: (i) the requirements of the Minnesota Constitution, Art. I, §§ 2, 7, and Art. VII, §
1, and U.S. Constitution, Amend. I and XIV, will be carried out by the implementation of this
Partial Consent Decree, (ii) the terms of this Partial Consent Decree constitute a fair and equitable
settlement of the issues raised with respect to the November General Election, (iii) this Partial

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Consent Decree is intended to and does resolve Plaintiffs’ claims with respect to the November
General Election; and (iv) this Partial Consent Decree is not intended to and does resolve Plaintiffs’
claims generally or with respect to any election held after the November General Election;
NOW, THEREFORE, upon consent of the Parties, in consideration of the mutual
promises and recitals contained in this Stipulation and Partial Consent Decree, including
relinquishment of certain legal rights, the Parties agree as follows:
II.
JURISDICTION
This Court has jurisdiction over the subject matter of this action pursuant to Minn. Const.
Art. VI, § 3 and Minn. Stat. § 484.01 and has jurisdiction over the Parties herein. The Court shall
retain jurisdiction of this Stipulation and Consent Decree for the duration of the term of this Partial
Consent Decree for purposes of entering all orders, judgments, and decrees that may be necessary
to implement and enforce compliance with the terms provided herein.
III.
PARTIES
This Stipulation and Partial Consent Decree applies to and is binding upon the following
parties:
A.

The State of Minnesota by Steve Simon, Secretary of State of Minnesota; and

B.

All Plaintiffs.
IV.
SCOPE OF CONSENT DECREE

A.

This Stipulation and Partial Consent Decree constitutes a partial settlement and

resolution of Plaintiffs’ claims against Defendant pending in this Lawsuit. Plaintiffs recognize that
by signing this Stipulation and Partial Consent Decree, they are releasing any claims under the
Minnesota or U.S. Constitutions that they might have against Defendant with respect to the

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Witness Requirement and Election Day Receipt Deadline in the November General Election.
Plaintiffs’ release of claims will become final upon the effective date of this Stipulation and Partial
Consent Decree.
B.

The Parties to this Stipulation and Partial Consent Decree acknowledge that this

does not resolve or purport to resolve any claims pertaining to the constitutionality or enforcement
of the Witness Requirement and Election Day Receipt Deadline for elections held after the
November General Election. Neither Party releases any claims or defenses with respect to the
Witness Requirement and Election Day Receipt Deadline related to elections occurring after the
November General Election.
C.

The Parties to this Stipulation and Partial Consent Decree further acknowledge that

by signing this Stipulation and Partial Consent Decree, the Parties do not release or waive the
following: (i) any rights, claims, or defenses that are based on any events that occur after they sign
this Stipulation and Partial Consent Decree, (ii) any claims or defenses that are unrelated to the
allegations filed by Plaintiffs in this Lawsuit, and (iii) any right to institute legal action for the
purpose of enforcing this Stipulation and Partial Consent Decree or defenses thereto.
D.

By entering this Stipulation and Partial Consent Decree, Plaintiffs are partially

settling a disputed matter between themselves and Defendant. The Parties are entering this
Stipulation and Partial Consent Decree for the purpose of resolving a disputed claim, avoiding the
burdens and costs associated with the costs of a preliminary injunction motion and hearing, and
ensuring both safety and certainty in advance of the November General Election. Nothing in this
Stipulation and Partial Consent Decree constitutes an admission by any party of liability or
wrongdoing. The Parties acknowledge that a court may seek to consider this Stipulation and Partial

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Consent Decree, including the violations alleged in Plaintiffs’ Complaint, in a future proceeding
distinct from this Lawsuit.
V.
CONSENT DECREE OBJECTIVES
In addition to partially settling the claims of the Parties, the objective of this Stipulation
and Partial Consent Decree is to ensure that Minnesota voters can safely and constitutionally
exercise the franchise in the November General Election, and to ensure that election officials have
sufficient time to implement changes for the November General Election and educate voters about
these changes before voting begins.
VI.
INJUNCTIVE RELIEF
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED FOR THE REASONS
STATED ABOVE THAT:
A.

For the November General Election Defendant shall not enforce the Witness

Requirement, with respect to voting only, as set out in Minn. Stat. § 203B.07, subd. 3 (1) and (2),
that each absentee ballot and designated mail ballot for voters previously registered in Minnesota
be witnessed by a registered Minnesota voter, a notary, or person otherwise authorized to
administer oaths, Minn. Stat. § 204B.45 - .46, and Minn. R. 8210.3000.
B.

For the November General Election Defendant shall not enforce the Election Day

Receipt Deadline for mail-in ballots, as set out in Minn. Stat. §§ 203B.08 subd. 3, 204B.45, and
204B.46 and Minn. R. 8210.2200 subp. 1, and 8210.3000, that ballots be received by 8:00 p.m. on
Election Day if delivered by mail. Instead, the deadline set forth in paragraph VI.D below shall
govern.

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C.

Filed in District Court
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Defendant shall issue guidance instructing all relevant local election officials to

count all absentee and designated mail ballots in the November General Election, as long as they
are otherwise validly cast by voters who registered in Minnesota before casting their absentee or
designated mail ballot. No witness signature will be required on those ballots.
D.

Defendant shall issue guidance instructing all relevant local election officials to

count all mail-in ballots in the November General Election that are otherwise validly cast and
postmarked on or before Election Day but received by 8 p.m. within 5 business days of Election
Day (i.e., seven calendar days, or one week). For the purposes of this Stipulation and Partial
Consent Decree, postmark shall refer to any type of imprint applied by the United States Postal
Service to indicate the location and date the Postal Service accepts custody of a piece of mail,
including bar codes, circular stamps, or other tracking marks. Where a ballot does not bear a
postmark date, the election official reviewing the ballot should presume that it was mailed on or
before Election Day unless the preponderance of the evidence demonstrates it was mailed after
Election Day.
E.

Defendant shall issue instructions to include with all absentee ballots and

designated mail ballots⸺or issue guidance instructing all relevant local election officials to
modify, amend, or print the instructions accompanying each absentee ballot and designated mail
ballot⸺to inform voters that any absentee ballot or designated mail ballot cast by a previously
registered voter in the November General Election without a witness signature will not be rejected
on that basis and that the witness signature line and associated language for witnesses to certify a
previously registered voter’s ballot, Minn. Stat. §§ 203B.07, subd. 3 (1) and (2), 204B.45,
204B.46; Minn. R. 8210.2200, subp.1; Minn. R. 8210.3000, be removed from the certification of

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eligibility altogether for absentee ballot and designated mail ballot materials sent to previously
registered voters.
F.

Defendant shall issue instructions to include with all absentee and designated mail

ballots⸺or issue guidance instructing all relevant local election officials to modify, amend, or
print instructions accompanying each absentee and designated mail ballot⸺to inform voters that
any absentee or designated mail ballot cast in the November General Election and postmarked on
or before Election Day and received by 8 p.m. within 5 business days of Election Day (i.e., seven
calendar days, or one week) will be counted.
G.

Defendant shall take additional reasonable steps to inform the public that the

Witness Requirement for voting will not be enforced for the November General Election and issue
guidance instructing all relevant city and county election officials to do the same.
H.

Defendant shall take additional reasonable steps to inform the public that the

Election Day Receipt Deadline will not be enforced for the November General Election and that
any absentee or designated mail ballot cast in the November General Election and postmarked on
or before Election Day and received by 8 p.m. within 5 business days of Election Day (i.e., seven
calendar days, or one week) will be counted.
I.

Plaintiffs will withdraw their Motion for Temporary Injunction for the November

General Election, filed on July 2, 2020, and will not file any further motions for injunctive relief
for the November General Election based on the claims raised in their Complaint of May 13, 2020.
J.

In accordance with the terms of this Stipulation and Partial Consent Decree, the

Parties shall each bear their own fees, expenses, and costs incurred as of the date of this Order with
respect to Plaintiffs’ claims raised as to the November General Election against Defendant.

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VII.
ENFORCEMENT AND RESERVATION OF REMEDIES
The Parties to this Stipulation and Partial Consent Decree may request relief from this
Court if issues arise concerning the interpretation of this Stipulation and Partial Consent Decree
that cannot be resolved through the process described below. This Court specifically retains
continuing jurisdiction over the subject matter hereof and the Parties hereto for the purposes of
interpreting, enforcing, or modifying the terms of this Stipulation and Partial Consent Decree, or
for granting any other relief not inconsistent with the terms of this Partial Consent Decree, until
this Partial Consent Decree is terminated. The Parties may apply to this Court for any orders or
other relief necessary to construe or effectuate this Stipulation and Partial Consent Decree or seek
informal conferences for direction as may be appropriate. The Parties shall attempt to meet and
confer regarding any dispute prior to seeking relief from the Court.
If either Party believes that the other has not complied with the requirements of this
Stipulation and Partial Consent Decree, it shall notify the other Party of its noncompliance by
emailing the Party’s counsel. Notice shall be given at least one business day prior to initiating any
action or filing any motion with the Court.
The Parties specifically reserve their right to seek recovery of their litigation costs and
expenses arising from any violation of this Stipulation and Partial Consent Decree that requires
either Party to file a motion with this Court for enforcement of this Stipulation and Partial Consent
Decree.
VIII.
GENERAL TERMS
A.

Voluntary Agreement. The Parties acknowledge that no person has exerted undue

pressure on them to sign this Stipulation and Partial Consent Decree. Each Party is voluntarily

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choosing to enter into this Stipulation and Partial Consent Decree because of the benefits that are
provided under the agreement. The Parties acknowledge that they have read and understand the
terms of this Stipulation and Partial Consent Decree; they have been represented by legal counsel
or had the opportunity to obtain legal counsel; and they are voluntarily entering into this Stipulation
and Partial Consent Decree to resolve the dispute among them.
B.

Severability. The provisions of this Stipulation and Partial Consent Decree shall

be severable, and should any provisions be declared by a court of competent jurisdiction to be
unenforceable, the remaining provisions of this Stipulation and Partial Consent Decree shall
remain in full force and effect.
C.

Agreement. This Stipulation and Partial Consent Decree is binding. The Parties

acknowledge that they have been advised that (i) the other Party has no duty to protect their interest
or provide them with information about their legal rights, (ii) signing this Stipulation and Partial
Consent Decree may adversely affect their legal rights, and (iii) they should consult an attorney
before signing this Stipulation and Partial Consent Decree if they are uncertain of their rights.
D.

Entire Agreement. This Stipulation and Consent Decree constitutes the entire

agreement between the Parties relating to the constitutionality and enforcement of the Witness
Requirement and Election Day Receipt Deadline as they pertain to the November General
Election. No Party has relied upon any statements, promises, or representations that are not stated
in this document. No changes to this Stipulation and Partial Consent Decree are valid unless they
are in writing, identified as an amendment to this Stipulation and Partial Consent Decree, and
signed by all Parties. There are no inducements or representations leading to the execution of this
Stipulation and Partial Consent Decree except as herein explicitly contained.

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E.

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Warranty. The persons signing this Stipulation and Partial Consent Decree

warrant that they have full authority to enter this Stipulation and Partial Consent Decree on behalf
of the Party each represents, and that this Stipulation and Partial Consent Decree is valid and
enforceable as to that Party.
F.

Counterparts. This Stipulation and Partial Consent Decree may be executed in

multiple counterparts, which shall be construed together as if one instrument. Any Party shall be
entitled to rely on an electronic or facsimile copy of a signature as if it were an original.
G.

Effective Date. This Stipulation and Partial Consent Decree is effective upon the

date it is entered by the Court. Defendant agrees to continue to initiate and implement all activities
necessary to comply with the provisions of this Stipulation and Partial Consent Decree pending
entry by the Court.
IX.
TERMINATION
This Stipulation and Partial Consent Decree shall remain in effect through the certification
of ballots for the November General Election. The Court shall retain jurisdiction to enforce the
terms of the Partial Consent Decree for the duration of this Partial Consent Decree. This Court’s
jurisdiction over this Stipulation and Partial Consent Decree shall automatically terminate after the
certification of all ballots for the November General Election.

THE PARTIES ENTER INTO AND APPROVE THIS STIPULATION AND PARTIAL
CONSENT DECREE AND SUBMIT IT TO THE COURT SO THAT IT MAY BE
APPROVED AND ENTERED. THE PARTIES HAVE CAUSED THIS STIPULATION
AND CONSENT DECREE TO BE SIGNED ON THE DATES OPPOSITE THEIR
SIGNATURES.

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SECRETARY OF STATE OF MINNESOTA

Dated: __July 17, 2020_________

By: _________________________________
Steve Simon
Secretary of State

GREENE ESPEL PLLP
Dated: __July 17, 2020________

By: /s/ Sybil L. Dunlop
Sybil L. Dunlop (Reg. No. 390186)
Samuel J. Clark (Reg. No. 388955)
222 South Ninth Street, Suite 2200
Minneapolis, MN 55402
Phone: (612) 373-0830
Fax: (612) 373-0929
Email: SDunlop@GreeneEspel.com
Email: SClark@GreeneEspel.com
PERKINS COIE LLP
Marc E. Elias*
Amanda R. Callais*
700 13th St. N.W., Suite 600
Washington, D.C. 20005-3960
Phone: (202) 654-6200
Fax: (202) 654-9106
Email: MElias@perkinscoie.com
Email: ACallais@perkinscoie.com
Abha Khanna*
1201 Third Avenue Suite 4900
Seattle, WA 98101-3099
Phone: (206) 359-8312
Fax: (206) 359-9312
Email: AKhanna@perkinscoie.com
Charles G. Curtis, Jr.*
33 East Main Street, Suite 201
Madison, Wisconsin 53703-3095
Phone: (608) 663-7460
Fax: (608) 663-7499
Email: CCurtis@perkinscoie.com

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*Admitted pro hac vice
Attorneys for Plaintiffs

IT IS SO DECREED AND ORDERED. JUDGMENT SHALL BE ENTERED IN
ACCORDANCE WITH THE FOREGOING CONSENT DECREE.
August 3, 2020
Dated: _____________________

______________________________
The Honorable Judge Sara Grewing
Judge of District Court

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