Purcell v. Gonzalez

Facts of the Case

In 2004, Arizona voters approved a measure (Proposition 200) requiring voters to present proof of citizenship when registering to vote, and identification when voting on election day. Plaintiffs – some Arizona residents, Indian tribes, and community organizations – brought suit against the state of Arizona and some county officials to challenge the identification requirements. The district court denied plaintiffs’ request for a preliminary injunction, but did not at that time issue findings of fact or conclusions of law. Plaintiffs appealed the denial. The appellate court, without explanation or justification, enjoined Arizona from enforcing Proposition 200’s provisions pending disposition, after full briefing, of the appeals of the denial of a preliminary injunction. Thereafter, the district court issued its findings of fact and conclusions of law, finding that the balance of the harms and the public interest counseled in favor of denying the injunction The U.S. Supreme Court granted certiorari.


Did the U.S. Court of Appeals for the Ninth Circuit err in granting an emergency injunction regarding Proposition 200 close to election time?


In a per curiam decision, the Court held that the U.S. Court of Appeals for the Ninth Circuit erred in granting an injunction against the enforcement of Proposition 200. Because the lower court’s decision lacked any information regarding how it came to its conclusion, the Supreme Court could not properly assess this decision, so it ordered that the case be remanded.Justice John Paul Stevens wrote a concurring opinion in which he agreed because there was no discussion of the rationale for requiring identification for voter registration.

Case Information

  • Citation: 549 US 1 (2006)
  • Decided Oct 20, 2006Granted: Oct 20, 2006