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Wood v. Raffensperger: Aggrieved Georgia Voter Directed to State Court Following the 2020 Election

Emma Goodloe*

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In Wood v. Raffensperger, the U.S. Court of Appeals for the Eleventh Circuit addressed whether it had jurisdiction over an appeal from the denial of a Georgia voter’s request for emergency relief following the 2020 United States presidential election.  A Georgia voter alleged that the absentee ballot and recount procedures violated existing Georgia law as well as his federal constitutional rights.  The Eleventh Circuit affirmed the District Court’s denial of the voter’s request for emergency relief for lack of standing and mootness and ruled that it did not have jurisdiction over post-election contests involving “issues of vote counting and misconduct that may be properly filed in state courts.” The Eleventh Circuit’s decision in Wood shows that federal courts are not willing to allow voters to tie state law claims into federal claims to gain relief against state officials.  

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