Valenti v. Lawson (7th Cir. 2018)

Valenti v. Lawson, 889 F.3d 427 (7th Cir. 2018)

Nature of Case: Appellant was an individual required to register as a sex offender in Indiana due to a 1993 conviction from California. Indiana law precluded him from entering onto school property due to his status, which was where the state of Indiana had designated as his polling place. Appellant brought a § 1983 lawsuit seeking injunctive and delcaratory relief under the First and Fourteenth Amendments. Federal district court granted summary judgment to state defendants, and Appellant appealed.

Holding: 7th Circuit Court of Appeals affirmed. Because states were free to disenfranchise people convicted of felonies, Appellant had only a statutory right to vote under Indiana law. This law, in turn, when subjected to a rational basis analysis, survived Appellant’s challenge. Indiana had a rational basis for precluding people who were convicted of sex offenses from entering onto school property, and additionally the state provided alternative methods for voting.