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Dismissing a Defective Pro Se Application for a Temporary Restraining Order

Robert Timothy Reagan, Margaret S. Williams, Marie Leary, Catherine R. Borden, Jessica L. Snowden, Patricia D. Breen, Jason A. Cantone
September 14, 2023

Webb-Goodwin v. Butler (Lance M. Africk, E.D. La. 2:04-cv-2653)
A candidate who came in sixth in an election rife with mechanical and logistical difficulties filed a pro se federal complaint to nullify the election. The district court denied the plaintiff a temporary restraining order because the plaintiff had shown neither service on defendants nor affidavit compliance with Federal Rule of Civil Procedure 65(b). A state-court action also was dismissed for lack of service.
Subject: Voting irregularities. Topics: Enjoining elections; voting technology; pro se party; matters for state courts.

One of many Case Studies in Emergency Election Litigation.