U.S. Court of Appeals for the Fourth Circuit Opinions

A. Philip Randolph Institute v. North Carolina State Board of Elections

Docket: 24-1512

Opinion Date: September 12, 2025

Judge: DeAndrea G. Benjamin

Areas of Law: Civil Rights, Constitutional Law, Election Law

A. Philip Randolph Institute v. North Carolina State Board of Elections

Docket: 24-1512

Opinion Date: September 12, 2025

Judge: DeAndrea G. Benjamin

Areas of Law: Civil Rights, Constitutional Law, Election Law

Two nonprofit organizations challenged the constitutionality of a North Carolina statute that made it a felony for individuals with felony convictions to vote before their rights were restored, regardless of whether those individuals mistakenly believed they were eligible. The statute, originally enacted in the late 19th century, was shown to have been motivated by racial animus and to have a disproportionate impact on Black North Carolinians. In 2023, the North Carolina General Assembly amended the statute to add a requirement that a person must “know” their rights had not been restored to be prosecuted, effective January 1, 2024.

The United States District Court for the Middle District of North Carolina considered the plaintiffs’ claims under the Equal Protection and Due Process Clauses. After the statute was amended, a magistrate judge recommended dismissal for lack of standing, but the district court found the case was not moot because prosecutions under the old statute for pre-2024 conduct could still occur, potentially chilling voter participation and requiring the plaintiffs to divert resources. The district court granted summary judgment for the plaintiffs, holding the statute unconstitutional and enjoining its enforcement.

The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the case was not moot because prosecutions under the prior version of the statute could still proceed, and the plaintiffs retained a concrete interest in the outcome. On the merits, the Fourth Circuit affirmed the district court’s ruling that the challenged statute violated the Equal Protection Clause. The court found that the statute’s original enactment and reenactment were motivated by racial discrimination, and that subsequent legislative changes did not “cleanse” the statute of its discriminatory origins, as the statute itself had not been substantively reenacted or amended in a way that would warrant a presumption of legislative good faith. The court affirmed the district court’s judgment.