Ohio Democratic Party v. LaRose

Citations

• 159 N.E.3d 1241
• 2020 Ohio 4778

Syllabus

We agree with the trial court that the Secretary of State's interpretation of R.C. 3509.05 is not reasonable and that the statute neither prescribes nor prohibits ballot drop boxes at locations other than the boards of elections. However, the trial court abused its discretion in granting a preliminary injunction against enforcement of the directive as the directive does not violate R.C. 3509.05. Thus, we conclude that while the Secretary of State was not statutorily required to limit the location of drop boxes, as he did in Directive 2020-16, he also was not statutorily required to allow for additional drop boxes. If the Secretary of State wants to permit additional drop boxes as allowed by statute, he has the authority to do so, and nothing in this decision prohibits him from rescinding Directive 2020-16 and issuing a new directive.