Case: Priorities USA v. Benson
3:19-cv-13188 | U.S. District Court for the Eastern District of Michigan
Filed Date: Oct. 30, 2019
Closed Date: May 8, 2020
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Case Summary
This case is about Michigan’s signature matching laws for absentee ballot applications and absentee ballots. In Michigan, city or township clerks compared an absentee voter’s signatures on both their ballot application and their absentee ballot against the signature on file, taken from either the government’s electronic database or the voter’s voter registration application. If the clerk determined the signatures did not match, the application or the ballot would be rejected. If an application or ballot was rejected for a signature mismatch, state law did not provide a mechanism for challenging that determination or even require election officials to notify voters of the rejection.
On October 30, 2019, Priorities USA, a non-profit voter-centric progressive advocacy and service organization, filed this lawsuit in the U.S. District Court for the Eastern District of Michigan. Represented by private counsel, they sued the Michigan Secretary of State under 42 U.S.C. § 1983. They sought declaratory relief, an injunction preventing enforcement of the signature matching laws, and attorneys’ fees. They claimed the error-prone signature matching process placed an undue burden on the right to vote, in violation of the First and Fourteenth Amendments to the U.S. Constitution, and also violated the equal protection and procedural due process guarantees of the Fourteenth Amendment.
In response, the defendant filed a motion to dismiss on December 12, arguing that, among other reasons, the complaint should be dismissed because 1) the plaintiff was organization and did not allege that
it had members who vote in Michigan and therefore lacked standing, 2) the plaintiff did not allege that it would incur any particularized injury as a result of the challenged statutes, and 3) the claims made in the complaint are hypothetical and therefore not ripe.
Shortly after, on December 30, the plaintiff filed an amended complaint adding as a plaintiff a registered voter whose 2018 absentee ballot had been wrongfully rejected for signature mismatch without any opportunity to appeal. In response, the defendant filed a motion to dismiss the amended complaint on January 13, 2020, arguing that plaintiffs lacked standing.
On February 25, 2020, the plaintiffs requested a preliminary injunction that would 1) order the Secretary to direct local officials to provide voters notice of signature mismatch determinations, implement cure procedures, and confirm rejections with the board of election inspectors; and 2) order the Secretary to provide formal signature matching training for all clerks and boards of election inspectors.
On March 24, 2020, the court granted the Michigan Legislature’s motion to intervene as defendants and denied defendant's motion to dismiss.
On April 21, 2020, the plaintiffs filed a motion to voluntarily dismiss the case. The plaintiffs had recently learned that after they filed their preliminary injunction request, the Secretary of State issued guidance to election officials that largely provided the relief that plaintiffs had requested. Accordingly, on May 8, 2020, the court dismissed the case without prejudice.
Summary Authors
John McGinnis (6/26/2025)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/16401103/parties/priorities-usa-v-benson/
Cleland, Robert Hardy (Michigan)
Anderson, Jacki Lynn (Michigan)
Elias, Marc E. (Michigan)
Grill, Erik A. (Michigan)
Meingast, Heather S. (Michigan)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/16401103/priorities-usa-v-benson/
Last updated April 12, 2026, 4:33 a.m.
Case Details
State / Territory:
Case Type(s):
Special Collection(s):
Law Firm Antiracism Alliance (LFAA) project
Key Dates
Filing Date: Oct. 30, 2019
Closing Date: May 8, 2020
Case Ongoing: No
Plaintiffs
Plaintiff Description:
A non-profit, voter-centric progressive advocacy and service organization and an absentee voter whose ballot was wrongfully rejected for signature mismatch
Plaintiff Type(s):
Non-profit NON-religious organization
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
State
Michigan Secretary of State
Defendant Type(s):
Case Details
Causes of Action:
Constitutional Clause(s):
Due Process: Procedural Due Process
Other Dockets:
Eastern District of Michigan 3:19-cv-13188
Available Documents:
Outcome
Prevailing Party: Defendant
Relief Granted:
Source of Relief:
Issues
Voting:
Case Summary of Priorities USA v. Benson, Civil Rights Litig. Clearinghouse, http://www.dev.clearinghouse.net/case/44704/ (last updated 6/26/2025).