Constitutional Law
Chiafalo v. Washington, 591 U.S. ___ (2020)
Study notes for Chiafalo v. Washington: professor notes, cold call prep, exam angles, and memory aids.
States can bind Electoral College members to vote in accordance with the state’s popular vote.
In Chiafalo v. Washington, the Supreme Court addressed the tensions between state laws and the discretion of Electoral College members. The case underscores the importance of fidelity to the popular vote and examines the constitutional standing of electors as agents of the electorate versus independent decision-makers. The justices emphasized the role of states in administering elections and the historical context of the Electoral College, affirming state authority to impose penalties on electors who do not adhere to the popular vote.
Furthermore, the Court ruled on the legality of Washington's law that required electors to follow the popular vote, asserting that this reflects the broader democratic principle that governs elections. Students should consider how this case illustrates the balance between federalism and states' rights, particularly in the context of presidential elections, where the implications of elector behavior can affect national outcomes significantly.
Electors Must Follow Votes (EMFV)
| Case | Distinction |
|---|---|
| Bush v. Gore | Bush v. Gore focused on the counting of votes and equal protection, while Chiafalo v. Washington addresses the binding of electors to popular vote. |
| National Association of Secretaries of State v. U.S. | This case deals with state laws regulating the voting process; Chiafalo specifically deals with elector votes post-selection. |
| Cooper v. Harris | Cooper dealt with redistricting and racial gerrymandering while Chiafalo is focused on the role of electors within the Electoral College framework. |
Binding electors ensures that the will of the voters is respected, fostering stability and trust in the electoral process.
It undermines electors' independence to make choices based on their judgment, potentially leading to unrepresentative outcomes.
This case is likely to appear in exams concerning the powers of states versus individual rights within the electoral process, examining the intersection of state law and federal electoral procedures.