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State Bar status verified as active for Meryl Macklin, Jonathan G. Fetterly not admitted to this court - Local counsel secured. 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No. 54), this case\n\nis DISMISSED WITHOUT PREJUDICE under Fed. R. Civ. P. 41(a)(1)(A)(i). The Clerk is\n\ndirected to close the file.\n\n It is so ORDERED.\n\n\n\n _______________________________________\n WILLIAM L. CAMPBELL, JR.\n CHIEF UNITED STATES DISTRICT JUDGE\n\n\n\n\n Case 3:26-cv-00603 Document 55 Filed 06/09/26 Page 1 of 1 PageID #: 1105\n\f","ocr_status":1,"date_upload":"2026-06-11T14:21:42.773656-07:00","document_number":"55","attachment_number":null,"pacer_doc_id":"16906430882","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order Dismissing Case","acms_document_guid":""}],"date_created":"2026-06-09T09:15:06.576015-07:00","date_modified":"2026-06-11T14:21:28.381423-07:00","date_filed":"2026-06-09","time_filed":"10:20:02","entry_number":55,"recap_sequence_number":"2026-06-09.002","pacer_sequence_number":252,"description":"ORDER DISMISSING CASE: Pursuant to the Notice of Voluntary Dismissal filed by the Plaintiffs (Doc. No. 54 ), this case is DISMISSED WITHOUT PREJUDICE under Fed. R. Civ. P. 41(a)(1)(A)(i). The Clerk is directed to close the file. Signed by Chief Judge William L. Campbell, Jr on 06/09/2026. (ad) (Entered: 06/09/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/466770319/","id":466770319,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/482017807/","id":482017807,"tags":[],"absolute_url":"/docket/73315644/54/hale-v-lee/","date_created":"2026-06-09T06:22:42.801241-07:00","date_modified":"2026-06-11T14:21:28.318082-07:00","sha1":"1e34f1d378a043b3728bed36b7e0dcaa46bfd7d3","page_count":3,"file_size":174656,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.54.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.54.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" IN THE UNITED STATES DISTRICT COURT\n FOR THE MIDDLE DISTRICT OF TENNESSEE\n\n VICKI HALE, EARLE FISHER, )\n TELISE TURNER, HEDY WEINBERG, )\n STEPHEN COHEN, CHARLES \u2018CHAZ\u2019 )\n MCIVER MOLDER, CHANEY )\n MOSLEY, JUSTIN PEARSON, and the )\n TENNESSEE DEMOCRATIC PARTY, )\n )\n Plaintiffs, ) CASE NO. 3:26-cv-00603\n )\n v. ) THREE-JUDGE COURT\n )\n BILL LEE, Governor, )\n TRE HARGETT, Secretary of State; )\n MARK GOINS, Tennessee Coordinator )\n of Elections; all in their official capacity )\n only, )\n )\n Defendants. )\n\n NOTICE OF VOLUNTARY DISMISSAL\n\n Plaintiffs, through their counsel, file this Notice of Voluntary Dismissal of this action,\n\nwithout prejudice, pursuant to Rule 41(a)(1)(A)(i) of the Federal Rules of Civil Procedure.\n\n Dated: June 8, 2026 Respectfully submitted,\n\n\n /s/ David W. Garrison\n DAVID W. GARRISON (No. 24968)\n SCOTT P. TIFT (No. 27592)\n JOSHUA A. FRANK (No. 33294)\n BARRETT JOHNSTON MARTIN & GARRISON, PLLC\n 200 31st Ave North\n Nashville, TN 37203\n Telephone: (615) 244-2202\n Facsimile: (615) 252-3798\n dgarrison@barrettjohnston.com\n stift@barrettjohnston.com\n jfrank@barrettjohnston.com\n\n JOHN SPRAGENS (No. 31445)\n SPRAGENS LAW PLC\n\n 1\n\n Case 3:26-cv-00603 Document 54 Filed 06/08/26 Page 1 of 3 PageID #: 1102\n\f 915 Rep. John Lewis Way S., Suite 100\n Nashville, TN 37203\n Telephone: (615) 983-8900\n Facsimile: (615) 682-8533\n john@spragenslaw.com\n\n Attorneys for Plaintiffs\n\n\n\n\n 2\n\nCase 3:26-cv-00603 Document 54 Filed 06/08/26 Page 2 of 3 PageID #: 1103\n\f CERTIFICATE OF SERVICE\n\n I hereby certify that a copy of this Notice of Voluntary Dismissal was filed electronically\nwith the Clerk\u2019s office and served upon Defendants using the Court\u2019s CM/ECF system on June 8,\n2026, through their counsel of record as indicated below:\n\n ZACHARY L BARKER\n ANDREW D. DENNING\n Office of the Tennessee Attorney General\n P.O. Box 20207\n Nashville, TN 37202-0207\n Phone: (615) 532-4098\n Zachary.Barker@ag.tn.gov\n Andrew.Denning@ag.tn.gov\n\n\n TAYLOR A.R. MEEHAN\n BRYAN K. WEIR\n Consovoy McCarthy PLLC\n 1600 Wilson Blvd., Suite 700\n Arlington, VA 22209\n taylor@consovoymccarthy.com\n bryan@consovoymccarthy.com\n\n /s/ David W. Garrison\n DAVID W. GARRISON\n BARRETT JOHNSTON\n MARTIN & GARRISON, PLLC\n\n\n\n\n 3\n\n Case 3:26-cv-00603 Document 54 Filed 06/08/26 Page 3 of 3 PageID #: 1104\n\f","ocr_status":1,"date_upload":"2026-06-09T06:22:44.208880-07:00","document_number":"54","attachment_number":null,"pacer_doc_id":"16906430218","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Notice of Voluntary Dismissal","acms_document_guid":""}],"date_created":"2026-06-09T06:22:42.768198-07:00","date_modified":"2026-06-11T14:21:28.289205-07:00","date_filed":"2026-06-08","time_filed":null,"entry_number":54,"recap_sequence_number":"2026-06-08.003","pacer_sequence_number":248,"description":"NOTICE of Voluntary Dismissal by Stephen Cohen, Earle Fisher, Vicki Hale, Charles McIvor Molder, Chaney Mosley, Justin Pearson, Tennessee Democratic Party, The, Telise Turner, Hedy Weinberg (Garrison, David) (Entered: 06/08/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/466717242/","id":466717242,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/481962678/","id":481962678,"tags":[],"absolute_url":"/docket/73315644/52/hale-v-lee/","date_created":"2026-06-08T14:08:27.856877-07:00","date_modified":"2026-06-11T14:21:28.233590-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"52","attachment_number":null,"pacer_doc_id":"16906430110","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Motion to Appear Pro Hac Vice","acms_document_guid":""}],"date_created":"2026-06-08T14:08:27.832955-07:00","date_modified":"2026-06-11T14:21:28.214363-07:00","date_filed":"2026-06-08","time_filed":"15:31:05","entry_number":52,"recap_sequence_number":"2026-06-08.001","pacer_sequence_number":244,"description":"MOTION for attorney Jonathan G. Fetterly to Appear Pro Hac Vice (Fee due within 10 days) by Stephen Cohen, Earle Fisher, Vicki Hale, Charles McIvor Molder, Chaney Mosley, Justin Pearson, Tennessee Democratic Party, The, Telise Turner, Hedy Weinberg. (Attachments: # 1 Attachment - Certificate of Good Standing)(ad) (Entered: 06/08/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/466717234/","id":466717234,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/481962669/","id":481962669,"tags":[],"absolute_url":"/docket/73315644/53/hale-v-lee/","date_created":"2026-06-08T14:08:27.474699-07:00","date_modified":"2026-06-11T14:21:28.271134-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"53","attachment_number":null,"pacer_doc_id":"16906430142","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Motion to Appear Pro Hac Vice","acms_document_guid":""}],"date_created":"2026-06-08T14:08:27.450175-07:00","date_modified":"2026-06-11T14:21:28.256658-07:00","date_filed":"2026-06-08","time_filed":"15:34:39","entry_number":53,"recap_sequence_number":"2026-06-08.002","pacer_sequence_number":246,"description":"MOTION for attorney Meryl Macklin to Appear Pro Hac Vice (Fee due within 10 days) by Stephen Cohen, Earle Fisher, Vicki Hale, Charles McIvor Molder, Chaney Mosley, Tennessee Democratic Party, The, Telise Turner, Hedy Weinberg. (Attachments: # 1 Attachment - Certificate of Good Standing)(ad) (Entered: 06/08/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/466429374/","id":466429374,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/481668000/","id":481668000,"tags":[],"absolute_url":"/docket/73315644/51/hale-v-lee/","date_created":"2026-06-05T07:21:11.310616-07:00","date_modified":"2026-06-11T14:21:28.190326-07:00","sha1":"ff289b5de010114bcfc463720fea5c5dfbce5e21","page_count":1,"file_size":181790,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.51.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.51.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" IN THE UNITED STATES DISTRICT COURT\n MIDDLE DISTRICT OF TENNESSEE\n NASHVILLE DIVISION\n\n\nVICKI HALE, et al., )\n )\n Plaintiff(s), )\n )\n ) Case No. 3:26-cv-00603\nv. ) Judge Campbell/Frensley\n )\n )\nGOVERNOR BILL LEE, et al., )\n )\n Defendant(s). )\n\n ORDER\n\n This case is set for a Case Management Conference on June 9, 2026 at 8:30 a.m. At the\n\nconference, the parties shall be prepared to discuss whether an evidentiary hearing is necessary\n\nand the extent of any limited discovery necessary to prepare for any hearing on the motion. The\n\nparties should also be prepared to discuss whether additional briefing is necessary, identify a\n\ntarget Preliminary Injunction hearing date if necessary, and the estimated length of any hearing.\n\nAll parties shall call 1-855-244-8681, and when prompted for the access code, enter\n\n23139129180# to participate in the Case Management Conference. If a party has difficulty\n\nconnecting to the call or has been on hold for more than five (5) minutes, please call 615-736-\n\n7344.\n\n IT IS SO ORDERED.\n\n\n\n JEFFERY S. FRENSLEY\n United States Magistrate Judge\n\n\n\n\n Case 3:26-cv-00603 Document 51 Filed 06/04/26 Page 1 of 1 PageID #: 1093\n\f","ocr_status":1,"date_upload":"2026-06-05T07:36:34.284687-07:00","document_number":"51","attachment_number":null,"pacer_doc_id":"16906427594","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2026-06-05T07:21:11.200682-07:00","date_modified":"2026-06-11T14:21:28.168399-07:00","date_filed":"2026-06-04","time_filed":null,"entry_number":51,"recap_sequence_number":"2026-06-04.001","pacer_sequence_number":223,"description":"ORDER: This case is set for a Case Management Conference on June 9, 2026 at 8:30 a.m. At the conference, the parties shall be prepared to discuss whether an evidentiary hearing is necessary and the extent of any limited discovery necessary to prepare for any hearing on the motion. The parties should also be prepared to discuss whether additional briefing is necessary, identify a target Preliminary Injunction hearing date if necessary, and the estimated length of any hearing. All parties shall call 1-855-244-8681, and when prompted for the access code, enter 23139129180# to participate in the Case Management Conference. If a party has difficulty connecting to the call or has been on hold for more than five (5) minutes, please call 615-736-7344. Signed by Magistrate Judge Jeffery S. Frensley on 06/04/2026. (ad) (Entered: 06/05/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/465696738/","id":465696738,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/480906920/","id":480906920,"tags":[],"absolute_url":"/docket/73315644/50/hale-v-lee/","date_created":"2026-05-29T14:09:08.703485-07:00","date_modified":"2026-06-11T14:21:28.147455-07:00","sha1":"cf27bc729f5e4fadc8ced46d752c5f3530bd87e0","page_count":2,"file_size":206584,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.50.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.50.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" IN THE UNITED STATES DISTRICT COURT\n FOR THE MIDDLE DISTRICT OF TENNESSEE\n\n\n\nVICKI HALE, EARLE FISHER, TELISE )\nTURNER, HEDY WEINBERG, STE- )\nPHEN COHEN, CHARLES \u2018CHAZ\u2019 ) No. 3:26-cv-00603\nMCIVOR MULDER, CHANEY MOS- ) THREE-JUDGE COURT\nLEY, JUSTIN PEARSON, and THE TEN- )\nNESSEE DEMOCRATIC PARTY, )\n )\n Plaintiffs,\n )\nv. )\n )\nBILL LEE, Tennessee Governor, TRE\n )\nHARGETT, Tennessee Secretary of State,\n )\nMARK GOINS, Tennessee Coordinator\n )\nof Elections; all in their official capacity\n )\nonly,\n )\n Defendants. )\n\n\n\n NOTICE OF WITHDRAWAL\n\n Pursuant to Local Rule 83.01(g), Olivia Rogers submits this Notice of Withdrawal\n\nas counsel for Defendants. Defendants shall continue to be represented by counsel of rec-\n\nord: Taylor Meehan and Bryan Weir of Consovoy McCarthy PLLC; Zachary Barker, Sen-\n\nior Assistant Attorney General in the Office of the Tennessee Attorney General; and An-\n\ndrew Denning, Assistant Attorney General in the Office of the Tennessee Attorney Gen-\n\neral.\n\n\n\n\n 1\n\n\n\n Case 3:26-cv-00603 Document 50 Filed 05/29/26 Page 1 of 2 PageID #: 1091\n\fDated: May 29, 2026 Respectfully submitted,\n\n JONATHAN SKRMETTI\n Attorney General and Reporter\n\n /s/ Zachary L. Barker\n ZACHARY L. BARKER (BRP #035933)\n Senior Assistant Attorney General\n\n ANDREW DENNING (BPR #042208)\n Assistant Attorney General\n Office of the Tennessee Attorney General\n P.O. Box 20207\n Nashville, Tennessee 37202-0207\n Phone: (615) 532-7400\n Zachary.barker@ag.tn.gov\n Andrew.denning@ag.tn.gov\n (615) 532-4098\n\n TAYLOR A.R. MEEHAN*\n BRYAN K. WEIR*\n OLIVIA C. ROGERS*\n Consovoy McCarthy PLLC\n 1600 Wilson Blvd., Suite 700\n Arlington, VA 22209\n taylor@consovoymccarthy.com\n bryan@consovoymccarthy.com\n orogers@consovoymccarthy.com\n\n *Admitted pro hac vice\n\n Counsel for Defendants\n\n\n\n\nCase 3:26-cv-00603 Document 50 Filed 05/29/26 Page 2 of 2 PageID #: 1092\n\f","ocr_status":1,"date_upload":"2026-06-01T13:44:18.789265-07:00","document_number":"50","attachment_number":null,"pacer_doc_id":"16906420532","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Notice (Other)","acms_document_guid":""}],"date_created":"2026-05-29T14:09:08.665448-07:00","date_modified":"2026-06-11T14:21:28.129048-07:00","date_filed":"2026-05-29","time_filed":null,"entry_number":50,"recap_sequence_number":"2026-05-29.002","pacer_sequence_number":221,"description":"NOTICE by Mark Goins, Tre Hargett, Bill Lee of withdrawal of Olivia Rogers as counsel (Barker, Zachary) (Entered: 05/29/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/465634936/","id":465634936,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/480843931/","id":480843931,"tags":[],"absolute_url":"/docket/73315644/49/hale-v-lee/","date_created":"2026-05-29T09:21:08.304336-07:00","date_modified":"2026-06-11T14:21:28.105738-07:00","sha1":"1ebe00868ebb41cc01c3ad6b0d62f31d7c6b8700","page_count":4,"file_size":253571,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.49.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.49.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"MOTION GRANTED.\n\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n FOR THE MIDDLE DISTRICT OF TENNESSEE\n\n\n\n VICKI HALE, et al., )\n )\n Plaintiffs,\n ) No. 3:26-cv-00603\n v. ) JUDGE CAMPBELL\n ) MAGISTRATE JUDGE FRENSLEY\n BILL LEE, Tennessee Governor, et al.,\n )\n Defendants. )\n )\n )\n )\n AMBER SHERMAN, et al., )\n )\n Plaintiffs,\n ) No. 3:26-cv-00616\n v. ) JUDGE CAMPBELL\n ) MAGISTRATE JUDGE FRENSLEY\n TRE HARGETT, in his official capacity as\n )\n Secretary of State of Tennessee, et al.,\n )\n Defendants. )\n )\n )\n )\n TENNESSEE STATE CONFERENCE OF )\n THE NAACP, et al., )\n )\n Plaintiffs,\n ) No. 3:26-cv-00638\n v. ) JUDGE CAMPBELL\n ) MAGISTRATE JUDGE FRENSLEY\n TRE HARGETT, in his official capacity as\n )\n Secretary of State of Tennessee, et al.,\n )\n Defendants. )\n\n\n\n UNOPPOSED MOTION TO EXTEND TIME FOR DEFENDANTS\u2019\n RESPONSIVE PLEADINGS TO PLAINTIFFS\u2019 COMPLAINTS\n\n\n\n\n Case 3:26-cv-00603 Document 49 Filed 05/29/26 Page 1 of 4 PageID #: 1087\n\f Defendants move to extend the time to answer or otherwise respond to Plaintiffs\u2019\n\ncomplaints in the above-captioned matters, such that all responsive pleadings would be\n\ndue on June 26, 2026. Plaintiffs do not oppose this request.\n\n 1. The above-captioned matters have been administratively consolidated. See Hale\n\nv. Lee, No. 3:26-cv-00603, ECF No. 44, (M.D. Tenn. May 22, 2026).\n\n 2. Defendants\u2019 responses would have otherwise been due on May 29, 2026, in Hale;\n\non June 2, 2026, in Sherman; and 21 days after service is effectuated in Tennessee State Con-\n\nference of the NAACP.\n\n 3. Defendants request additional time to prepare responsive pleadings due to the\n\npress of May deadlines related to the Hale and Sherman Plaintiffs\u2019 motions for emergency\n\nrelief and other deadlines in related cases, as well as to streamline proceedings with one\n\nresponsive pleading deadline for the above-captioned matters.\n\n 4. Counsel for Hale Plaintiffs stated they do not oppose an extension of the respon-\n\nsive pleading deadline to June 26, 2026.\n\n 5. Counsel for Sherman Plaintiffs stated, \u201cPlaintiffs do not object to the extension\n\nof Defendants\u2019 deadline to move or answer to June 26, 2026, but would and do object to\n\nany delay in the resolution of their pending motion for a temporary restraining order or\n\npreliminary injunction (ECF No. 20), which was filed on May 13, 2026.\u201d\n\n 6. Counsel for NAACP Plaintiffs stated they do not oppose an extension of the re-\n\nsponsive pleading deadline to June 26, 2026.\n\n\n\n 2\n Case 3:26-cv-00603 Document 49 Filed 05/29/26 Page 2 of 4 PageID #: 1088\n\f For these reasons, Defendants respectfully request that the deadline to file respon-\n\nsive pleadings in the above-captioned cases be extended up to and including June 26,\n\n2026.\n\n\n\n\n 3\n Case 3:26-cv-00603 Document 49 Filed 05/29/26 Page 3 of 4 PageID #: 1089\n\fDated: May 27, 2026 Respectfully submitted,\n\n\n JONATHAN SKRMETTI\n Attorney General and Reporter\n\n /s/ Zachary L. Barker\n ZACHARY L. BARKER (BRP #035933)\n Senior Assistant Attorney General\n\n ANDREW DENNING (BPR #042208)\n Assistant Attorney General\n Office of the Tennessee Attorney General\n P.O. Box 20207\n Nashville, Tennessee 37202-0207\n Phone: (615) 532-7400\n Zachary.barker@ag.tn.gov\n Andrew.denning@ag.tn.gov\n (615) 532-4098\n\n TAYLOR A.R. MEEHAN*\n BRYAN K. WEIR*\n OLIVIA C. ROGERS*\n Consovoy McCarthy PLLC\n 1600 Wilson Blvd., Suite 700\n Arlington, VA 22209\n taylor@consovoymccarthy.com\n bryan@consovoymccarthy.com\n orogers@consovoymccarthy.com\n\n *Admitted pro hac vice\n\n Counsel for Defendants\n\n\n\n\n 4\nCase 3:26-cv-00603 Document 49 Filed 05/29/26 Page 4 of 4 PageID #: 1090\n\f","ocr_status":1,"date_upload":"2026-06-01T13:46:13.164790-07:00","document_number":"49","attachment_number":null,"pacer_doc_id":"16906420274","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order on Motion for Extension of Time to Answer","acms_document_guid":""}],"date_created":"2026-05-29T09:21:08.266950-07:00","date_modified":"2026-06-11T14:21:28.085969-07:00","date_filed":"2026-05-29","time_filed":"10:52:12","entry_number":49,"recap_sequence_number":"2026-05-29.001","pacer_sequence_number":218,"description":"ORDER: Motion 47 for Extension of Time to Answer Complaint GRANTED. Answer due 6/26/2026. Signed by Magistrate Judge Jeffery S. Frensley on 05/29/2026. (ad) (Entered: 05/29/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/465403071/","id":465403071,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/480606311/","id":480606311,"tags":[],"absolute_url":"/docket/73315644/47/hale-v-lee/","date_created":"2026-05-27T15:23:06.688867-07:00","date_modified":"2026-06-11T14:21:28.028517-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"47","attachment_number":null,"pacer_doc_id":"16906418555","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Motion for Extension of Time to File Answer","acms_document_guid":""}],"date_created":"2026-05-27T15:23:06.633566-07:00","date_modified":"2026-06-11T14:21:28.010305-07:00","date_filed":"2026-05-27","time_filed":"16:37:20","entry_number":47,"recap_sequence_number":"2026-05-27.002","pacer_sequence_number":210,"description":"Unopposed MOTION for Extension of Time to File Answer or Otherwise Respond by Mark Goins, Tre Hargett, Bill Lee. (Barker, Zachary) (Entered: 05/27/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/465403025/","id":465403025,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/480606265/","id":480606265,"tags":[],"absolute_url":"/docket/73315644/48/hale-v-lee/","date_created":"2026-05-27T15:23:05.118599-07:00","date_modified":"2026-06-11T14:21:28.066198-07:00","sha1":"48dfe9ae56bb04e03ebc794bbe90dfacc3527656","page_count":2,"file_size":136408,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.48.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.48.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" IN THE UNITED STATES COURT OF APPEALS\n FOR THE SIXTH CIRCUIT\n\n\n )\n )\nIn re: Appointment of Three-Judge Panel under ) Case No. 3:26-cv-603\n28 U.S.C. \u00a7 2284 ) Case No. 3:26-cv-616\n ) Case No. 3:26-cv-638\n ) Case No. 3:26-cv-694\n )\n\n ORDER\n\n This matter is before the Court upon the request of the Honorable William L. Campbell,\n\nJr., Chief Judge of the United States District Court for the Middle District of Tennessee, to appoint\n\na three-judge panel to hear four cases challenging the constitutionality of Tennessee\u2019s newly\n\nenacted congressional districts. Those matters are designated as Vicki Hale, et al. v. Bill Lee, et\n\nal., Case No. 3:26-cv-603; Amber Sherman, et al. v. Tre Hargett, et al., Case No. 3:26-cv-616;\n\nTennessee State Conference of the NAACP, et al. v. Tre Hargett, et al., Case No. 3:26-cv-638; and\n\nPamela Jeanine Moses v. Bill Lee, et al., Case No. 3:26-cv-694. They have been consolidated in\n\naccordance with Rule 42(a) of the Federal Rules of Civil Procedure. Having reviewed the request,\n\nChief Judge Jeffrey S. Sutton agrees that a three-judge panel is warranted under 28 U.S.C. \u00a7 2284.\n\n Chief Judge Sutton hereby designates the Honorable John B. Nalbandian, Circuit Judge of\n\nthe Sixth Circuit Court of Appeals, and the Honorable Greg N. Stivers, District Judge of the United\n\nStates District Court for the Western District of Kentucky, to serve with the Honorable William L.\n\nCampbell in this matter. The provisions of 28 U.S.C. \u00a7 2284(b)(2) and (3) shall apply. This\n\ndesignation shall remain in full force and effect for the duration of the proceedings in the above-\n\nlisted cases. The Clerk of this Court is directed to forward a copy of this order to the Clerk of the\n\nUnited States District Court for the Middle District of Tennessee for entry on the dockets.\n\n\n\n\n Case 3:26-cv-00603 Document 48 Filed 05/27/26 Page 1 of 2 PageID #: 1085\n\f -2-\n\n BY ORDER OF THE COURT\n\n\n\n Kelly L. Stephens, Clerk\n\n\n\n\nEntered this 27th day of May, 2026.\n\n\n\n\n Case 3:26-cv-00603 Document 48 Filed 05/27/26 Page 2 of 2 PageID #: 1086\n\f","ocr_status":1,"date_upload":"2026-05-27T15:24:04.317416-07:00","document_number":"48","attachment_number":null,"pacer_doc_id":"16906418627","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2026-05-27T15:23:05.084870-07:00","date_modified":"2026-06-11T14:21:28.050730-07:00","date_filed":"2026-05-27","time_filed":"17:10:24","entry_number":48,"recap_sequence_number":"2026-05-27.003","pacer_sequence_number":212,"description":"SIXTH CIRCUIT COURT OF APPEALS ORDER: This matter is before the Court upon the request of the Honorable William L. Campbell, Jr., Chief Judge of the United States District Court for the Middle District of Tennessee, to appoint a three-judge panel to hear four cases challenging the constitutionality of Tennessee's newly enacted congressional districts. Those matters are designated as Vicki Hale, et al. v. Bill Lee, et al., Case No. 3:26-cv-603; Amber Sherman, et al. v. Tre Hargett, et al., Case No. 3:26-cv-616; Tennessee State Conference of the NAACP, et al. v. Tre Hargett, et al., Case No. 3:26-cv-638; and Pamela Jeanine Moses v. Bill Lee, et al., Case No. 3:26-cv-694. They have been consolidated in accordance with Rule 42(a) of the Federal Rules of Civil Procedure. Having reviewed the request, Chief Judge Jeffrey S. Sutton agrees that a three-judge panel is warranted under 28 U.S.C. \u00a7 2284. Chief Judge Sutton hereby designates the Honorable John B. Nalbandian, Circuit Judge of the Sixth Circuit Court of Appeals, and the Honorable Greg N. Stivers, District Judge of the United States District Court for the Western District of Kentucky, to serve with the Honorable William L. Campbell in this matter. The provisions of 28 U.S.C. \u00a7 2284(b)(2) and (3) shall apply. This designation shall remain in full force and effect for the duration of the proceedings in the above-listed cases. BY ORDER OF THE COURT, Kelly L. Stephens, Clerk. Entered 05/27/2026. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(lh) (Entered: 05/27/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/465363328/","id":465363328,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/480565834/","id":480565834,"tags":[],"absolute_url":"/docket/73315644/46/hale-v-lee/","date_created":"2026-05-27T12:31:19.568942-07:00","date_modified":"2026-06-11T14:21:27.988646-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"46","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Appear Pro Hac Vice","acms_document_guid":""}],"date_created":"2026-05-27T12:31:19.524122-07:00","date_modified":"2026-06-11T14:21:27.968917-07:00","date_filed":"2026-05-27","time_filed":null,"entry_number":46,"recap_sequence_number":"2026-05-27.001","pacer_sequence_number":null,"description":"ORDER granting 17, 18, and 19 : Having satisfied the requirements of Local Rule 83.01(b), the Motions for Taylor Meehan, Olivia Rogers, and Bryan Weir to Appear Pro Hac Vice are granted. Signed by Clerk of Court Lynda M. Hill on 05/27/2026. (lh) (Entered: 05/27/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/465360870/","id":465360870,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/480563321/","id":480563321,"tags":[],"absolute_url":"","date_created":"2026-05-27T12:19:42.447622-07:00","date_modified":"2026-05-27T12:19:42.453259-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Appear Pro Hac Vice AND Appear Pro Hac Vice AND Appear Pro Hac Vice","acms_document_guid":""}],"date_created":"2026-05-27T12:19:42.434803-07:00","date_modified":"2026-05-27T12:19:42.434813-07:00","date_filed":"2026-05-27","time_filed":"13:43:27","entry_number":null,"recap_sequence_number":"2026-05-27.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/464975570/","id":464975570,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/480166539/","id":480166539,"tags":[],"absolute_url":"/docket/73315644/45/hale-v-lee/","date_created":"2026-05-22T10:24:48.347482-07:00","date_modified":"2026-06-11T14:21:27.947598-07:00","sha1":"ff84205e577d94bf4463d7f87430ab843f17d0d6","page_count":2,"file_size":214950,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.45.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.45.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" IN THE UNITED STATES DISTRICT COURT FOR THE\n MIDDLE DISTRICT OF TENNESSEE\n NASHVILLE DIVISION\n\nVICKI HALE, et al., )\n Plaintiffs, )\n )\nv. ) NO. 3:26-cv-00603\n )\nBILL LEE, Tennessee Governor, et al., ) JUDGE CAMPBELL\n Defendants. ) MAGISTRATE JUDGE FRENSLEY\n )\n )\nAMBER SHERMAN, et al., )\n Plaintiffs, )\n )\nv. ) NO. 3:26-cv-00616\n )\nTRE HARGETT, in his official capacity as ) JUDGE CAMPBELL\nSecretary of State of Tennessee, et al., ) MAGISTRATE JUDGE FRENSLEY\n Defendants. )\n )\n )\n TENNESSEE STATE CONFERENCE OF )\n THE NAACP, et al., )\n Plaintiffs, ) NO. 3:26-cv-00638\n )\n v. ) JUDGE CAMPBELL\n ) MAGISTRATE JUDGE FRENSLEY\n TRE HARGETT, in his official capacity as )\n Secretary of State of Tennessee, et al., )\n Defendants )\n\n NOTIFICATION OF APPLICATION FOR A THREE-JUDGE COURT\n\n Three cases challenging the constitutionality of Tennessee\u2019s newly enacted congressional\n\ndistricts have been filed in this district. The cases are: Hale v. Lee, Case No. 3:26-cv-00603;\n\nSherman v. Hargett, Case No. 3:26-cv-00616; and NAACP Tennessee v. Hargett, Case No. 3:26-\n\ncv-00638. In their complaints, the plaintiffs in Sherman and NAACP Tennessee request a three-\n\njudge court. (Sherman, Case No. 3:26-cv-00616, Doc. No. 1, \u00b6 9; NAACP Tenn., Case No. 3:26-\n\ncv-00638, Doc. No. 1, \u00b6 26). In Hale, a three-judge panel was requested by Defendants, and not\n\nopposed by Plaintiffs. (Case No. 3:26-cv-00603, Doc. Nos. 37, 38).\n\n\n Case 3:26-cv-00603 Document 45 Filed 05/22/26 Page 1 of 2 PageID #: 1079\n\f Under 28 U.S.C. \u00a7 2284(b)(1), \u201cthe judge to whom the request is presented shall, unless he\n\ndetermines that three judges are not required, immediately notify the chief judge of the circuit,\n\nwho shall designate two other judges, at least one of whom shall be a circuit judge.\u201d Accordingly,\n\npursuant to 28 U.S.C. \u00a7 2284, the Court notifies the Honorable Jeffrey S. Sutton, Chief Judge of\n\nthe United States Court of Appeals for the Sixth Circuit, of these requests so that he may designate\n\ntwo additional judges to participate in hearing and determining Plaintiffs\u2019 claims in these three\n\ncases to the extent appropriate. Because the cases involve common issues of fact and law and have\n\nbeen consolidated for purposes of case management, the Court suggests that the same three judges\n\nhear and decide the three cases.\n\n The Clerk is DIRECTED to transmit a copy of this request forthwith to the Clerk of the\n\nUnited States Court of Appeals for the Sixth Circuit.\n\n It is so ORDERED.\n\n _______________________________________\n WILLIAM L. CAMPBELL, JR.\n CHIEF UNITED STATES DISTRICT JUDGE\n\n\n\n\n 2\n\n Case 3:26-cv-00603 Document 45 Filed 05/22/26 Page 2 of 2 PageID #: 1080\n\f","ocr_status":1,"date_upload":"2026-05-22T10:46:55.032375-07:00","document_number":"45","attachment_number":null,"pacer_doc_id":"16906414392","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2026-05-22T10:24:48.310218-07:00","date_modified":"2026-06-11T14:21:27.919928-07:00","date_filed":"2026-05-22","time_filed":"11:32:07","entry_number":45,"recap_sequence_number":"2026-05-22.002","pacer_sequence_number":204,"description":"NOTIFICATION OF APPLICATION FOR A THREE-JUDGE COURT: Three cases challenging the constitutionality of Tennessee's newly enacted congressional districts have been filed in this district. The cases are: Hale v. Lee, Case No. 3:26-cv-00603; Sherman v. Hargett, Case No. 3:26-cv-00616; and NAACP Tennessee v. Hargett, Case No. 3:26-cv-00638. In their complaints, the plaintiffs in Sherman and NAACP Tennessee request a three-judge court. (Sherman, Case No. 3:26-cv-00616, Doc. No. 1, 9; NAACP Tenn., Case No. 3:26-cv-00638, Doc. No. 1, 26). In Hale, a three-judge panel was requested by Defendants, and not opposed by Plaintiffs. (Case No. 3:26-cv-00603, Doc. Nos. 37, 38 ). Accordingly, pursuant to 28 U.S.C. \u00a7 2284, the Court notifies the Honorable Jeffrey S. Sutton, Chief Judge of the United States Court of Appeals for the Sixth Circuit, of these requests so that he may designate two additional judges to participate in hearing and determining Plaintiffs' claims in these three cases to the extent appropriate. The Clerk is DIRECTED to transmit a copy of this request forthwith to the Clerk of the United States Court of Appeals for the Sixth Circuit. Signed by Chief Judge William L. Campbell, Jr on 5/22/2026. (xc: A copy of this NOTIFICATION OF APPLICATION FOR A THREE-JUDGE COURT has been electronically submitted to the Clerk of the United States Court of Appeals for the Sixth Circuit.) (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(mg) (Entered: 05/22/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/464962451/","id":464962451,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/480153108/","id":480153108,"tags":[],"absolute_url":"/docket/73315644/44/hale-v-lee/","date_created":"2026-05-22T09:21:13.088105-07:00","date_modified":"2026-06-11T14:21:27.896502-07:00","sha1":"361cc9b5e9db52db44416b7931c1b39a4f36438a","page_count":2,"file_size":213843,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.44.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.44.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":"2026-05-22T09:29:43.700283-07:00","document_number":"44","attachment_number":null,"pacer_doc_id":"16906414366","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2026-05-22T09:21:13.034671-07:00","date_modified":"2026-06-11T14:21:27.875332-07:00","date_filed":"2026-05-22","time_filed":"11:17:04","entry_number":44,"recap_sequence_number":"2026-05-22.001","pacer_sequence_number":201,"description":"ORDER TO ADMINISTRATIVELY CONSOLIDATE CASES: Defendants in the first-filed case, Hale v. Lee, Case No. 3:26-cv-00603, filed a motion to consolidate that case with the next filed case Sherman v. Hargett, Case No. 3:26-cv-00616. (See Doc. No. 39 in Case No. 3:26-cv-00603). The third case, NAACP Tennessee v. Hargett, Case No. 3:26-cv-00638, was filed the following day and was not included in the motion. The Court finds these cases warrant consolidation under Fed. R. Civ. P. 42(a). Accordingly, Defendants' motion to consolidate (Doc. No. 39 in Case No. 3:26-cv-00603) GRANTED IN PART. Pending further consideration and possible further consolidation, the cases will be consolidated for purposes of case management and so that they may be heard and decided before the same district judge and three-judge panel. This will allow coordination of scheduling and motions practice and will avoid the possibility of inconsistent outcomes. The individual case files shall remain open, and the parties shall make filings in the relevant case pending further order of the Court. Signed by Chief Judge William L. Campbell, Jr on 5/22/2026. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(mg) (Entered: 05/22/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/464864678/","id":464864678,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/480053541/","id":480053541,"tags":[],"absolute_url":"/docket/73315644/43/hale-v-lee/","date_created":"2026-05-21T13:32:58.925756-07:00","date_modified":"2026-06-23T03:51:31.937117-07:00","sha1":"effec8e85c3464e92d8c844fdcddc071113f895d","page_count":15,"file_size":294294,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.43.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.43.0.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.tnmd.109142/480053541.thumb.1068.png","thumbnail_status":1,"plain_text":"","ocr_status":null,"date_upload":"2026-05-21T13:33:02.320600-07:00","document_number":"43","attachment_number":null,"pacer_doc_id":"16906413632","is_available":true,"is_free_on_pacer":true,"is_sealed":null,"document_type":1,"description":"Memorandum Opinion of the Court","acms_document_guid":""}],"date_created":"2026-05-21T13:32:58.896343-07:00","date_modified":"2026-06-23T03:51:31.919643-07:00","date_filed":"2026-05-21","time_filed":"15:26:46","entry_number":43,"recap_sequence_number":"2026-05-21.001","pacer_sequence_number":199,"description":" MEMORANDUM OPINION OF THE COURT: Considering the relevant factors, the Court is not persuaded that a temporary restraining order should issue. Accordingly, the motion for temporary restraining order is DENIED. The Order reflecting this decision has been entered. (See Doc. No. 42 ). Signed by Chief Judge William L. Campbell, Jr on 05/21/2026. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(ad)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/464090274/","id":464090274,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479254164/","id":479254164,"tags":[],"absolute_url":"/docket/73315644/42/hale-v-lee/","date_created":"2026-05-14T12:37:19.682126-07:00","date_modified":"2026-06-11T14:21:27.797165-07:00","sha1":"ac0ddbc80a7b3db0702c6e3910ed3b5f3c010873","page_count":1,"file_size":317006,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.42.0_2.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.42.0.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.tnmd.109142/479254164.thumb.1068.png","thumbnail_status":1,"plain_text":" IN THE UNITED STATES DISTRICT COURT FOR THE\n MIDDLE DISTRICT OF TENNESSEE\n NASHVILLE DIVISION\n\nVICKI HALE, EARLE FISHER, TELISE )\nTURNER, HEDY WEINBERG, STEPHEN )\nCOHEN, CHARLES \u2018CHAZ\u2019 MCIVOR )\nMULDER, CHANEY MOSLEY, JUSTIN )\nPEARSON, and THE TENNESSEE )\nDEMOCRATIC PARTY, )\n )\n Plaintiffs, ) NO. 3:26-cv-00603\n )\nv. ) JUDGE CAMPBELL\n )\nBILL LEE, Tennessee Governor, TRE )\nHARGETT, Tennessee Secretary of State, )\nMARK GOINS, Tennessee Coordinator of )\nElections; all in their official capacity only, )\n )\n Defendants. )\n\n ORDER\n\n Pending before the Court is Plaintiffs\u2019 Motion for Temporary Restraining Order and\n\nPreliminary Injunction and for Hearing (Doc. No. 11), which is fully briefed. For the reasons stated\n\nin the forthcoming Memorandum, the motion is DENIED as to the request for a temporary restraining\n\norder. Accordingly, the hearing set for May 20, 2026, is CANCELED.\n\n It is so ORDERED.\n\n _______________________________________\n WILLIAM L. CAMPBELL, JR.\n CHIEF UNITED STATES DISTRICT JUDGE\n\n\n\n\n Case 3:26-cv-00603 Document 42 Filed 05/14/26 Page 1 of 1 PageID #: 1061\n\f","ocr_status":null,"date_upload":"2026-05-14T14:35:26.487914-07:00","document_number":"42","attachment_number":null,"pacer_doc_id":"16906406024","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2026-05-14T12:37:19.646897-07:00","date_modified":"2026-06-11T14:21:27.777232-07:00","date_filed":"2026-05-14","time_filed":"14:25:49","entry_number":42,"recap_sequence_number":"2026-05-14.002","pacer_sequence_number":195,"description":"ORDER: Pending before the Court is Plaintiffs' Motion for Temporary Restraining Order and Preliminary Injunction and for Hearing (Doc. No. 11 ), which is fully briefed. For the reasons stated in the forthcoming Memorandum, the motion is DENIED as to the request for a temporary restraining order. Accordingly, the hearing set for May 20, 2026, is CANCELED. Signed by Chief Judge William L. Campbell, Jr on 05/14/2026. (ad) (Entered: 05/14/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/464031303/","id":464031303,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479194393/","id":479194393,"tags":[],"absolute_url":"/docket/73315644/41/hale-v-lee/","date_created":"2026-05-14T07:42:46.806655-07:00","date_modified":"2026-06-11T14:21:27.755106-07:00","sha1":"32640d3fc903f195e5c15edfb016132ebc7c160f","page_count":5,"file_size":199444,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.41.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.41.0.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.tnmd.109142/479194393.thumb.1068.png","thumbnail_status":1,"plain_text":" IN THE UNITED STATES DISTRICT COURT\n FOR THE MIDDLE DISTRICT OF TENNESSEE\n\n VICKI HALE, EARLE FISHER, )\n TELISE TURNER, HEDY WEINBERG, )\n STEPHEN COHEN, CHARLES \u2018CHAZ\u2019 )\n MCIVER MOLDER, CHANEY )\n MOSLEY, JUSTIN PEARSON, and the )\n TENNESSEE DEMOCRATIC PARTY, )\n )\n Plaintiffs, ) CASE NO. 3:26-cv-00603\n )\n v. ) JUDGE CAMPBELL\n )\n BILL LEE, Governor, )\n TRE HARGETT, Secretary of State; )\n MARK GOINS, Tennessee Coordinator )\n of Elections; all in their official capacity )\n only, )\n )\n Defendants. )\n\nREPLY IN SUPPORT OF PLAINTIFFS\u2019 MOTION FOR TEMPORARY RESTRAINING\n ORDER\n\n This case is unique because the Tennessee General Assembly waited until two months after\n\nthe March 10 candidate qualifying deadline to draw new congressional districts, and to reset the\n\ncandidate qualifying deadline (and withdrawal deadline) to May 15, tomorrow. This represents a\n\nmaterial difference between this case and the cases relied upon by the State:\n\n In the Abbott case, the Texas legislature drew new districts at some point prior to the\n\nDistrict Court\u2019s November 18, 2025, decision enjoining the new maps. And, that was well before\n\nthe December 8, 2025, candidate qualifying deadline and the March 3, 2026, congressional\n\nprimary.1 See LULAC v. Abbott, 809 F. Supp. 3d 502, 516 (W.D. Tex. 2025), rev\u2019d sub nom. Abbott\n\nv. LULAC, No. 25-845, 2026 WL 1127246 (U.S. Apr. 27, 2026).\n\n\n\n1\n See Texas Secretary of State\u2019s website publishing Important Election Dates\n(https://www.sos.state.tx.us/elections/voter/important-election-dates.shtml)\n 1\n\n Case 3:26-cv-00603 Document 41 Filed 05/14/26 Page 1 of 5 PageID #: 1056\n\f Similarly, in the Rucho case, the North Carolina legislature drew new districts in 2016, and\n\nthe district court enjoined the new maps on January 9, 2018, well before the February 28, 2018,\n\ncandidate qualifying deadline and the May 8, 2018, primary election.2 See Common Cause v.\n\nRucho, 279 F. Supp. 3d 587, 599 (M.D.N.C.), vacated and remanded, 585 U.S. 1012, 138 S. Ct.\n\n2679, 201 L. Ed. 2d 1066 (2018).\n\n Here, by redistricting two months after the candidate qualifying deadline, the super\n\nmajority had the opportunity to assess the strength of the opposition party\u2019s congressional\n\ncandidates, who had been exercising their First Amendment rights to speech and association for\n\nmonths within set congressional districts, and then impede those candidates\u2019 free speech and\n\nassociation by drawing them into vastly different territories than the territories they had been\n\ncampaigning in for months. The General Assembly\u2019s redistricting effort was not the political\n\ngerrymandering permitted by the Rucho decision, where a legislature draws districts based on\n\npolitical partisanship demographics. The General Assembly\u2019s redistricting effort was targeted\n\ngovernmental retaliation against specific Candidate Plaintiffs, as well as the Voter Plaintiffs who\n\nhad supported them, with the effect of infringing their First Amendment rights to speech and\n\nassembly.\n\n If these constitutional violations, which only apply during this 2026 election, are\n\nsanctioned here in deference to a doctrine of judicial restraint that would have applied months ago\n\nbut should not apply months after the candidate qualifying deadline, then the General Assembly\n\nwill have license moving forward to neutralize its political opposition by violating the First\n\nAmendment rights of voters and candidates every two years by redrawing legislative districts\n\nsufficiently after the candidate qualifying deadline for the super majority to assess which\n\n\n\n2\n See https://ballotpedia.org/North_Carolina_state_legislative_Democratic_primaries,_2018\n 2\n\n Case 3:26-cv-00603 Document 41 Filed 05/14/26 Page 2 of 5 PageID #: 1057\n\fopposition party candidates stand the greatest chance of prevailing and then to undercut those\n\ncandidates\u2019 chances of success through redistricting. The Court should not allow this egregious\n\nabuse of power to result in Plaintiffs\u2019 First Amendment rights being violated this year and opening\n\nthe door for the same to occur in cycle after cycle for years to come.\n\n Initially, Plaintiffs moved this Court to set a hearing on their application for TRO (Doc.\n\nNo. 11) in hopes that such a hearing would advance their effort to seek relief expeditiously;\n\nhowever, they have since withdrawn such request (Doc. No. 32). Both sides have briefed the Court\n\non Plaintiffs\u2019 Motion, and both sides \u201chave stated that they do not intend to present live testimony\n\nduring the [May 20, 2026] hearing.\u201d (Doc. No. 31). Moreover, both sides have relied on sworn\n\nwritten testimony, and the State\u2019s testimony does not contradict Plaintiffs testimony. Plaintiffs rely\n\nupon: (1) uncontradicted testimony from State and County officials noting how redistricting so\n\nlate in the election process will lead to the disenfranchisement of voters; (2) uncontradicted\n\ntestimony from congressional candidates attesting to their activity protected by the First\n\nAmendment that has now been violated by the Act; and (3) uncontradicted testimony from a\n\nprofessional who works with voting data as to how the Act changed congressional district lines\n\nthat favored candidates of one political viewpoint over others. The State relies on written testimony\n\nnoting some differences between the circumstances now from the circumstances in 2022, but those\n\ndifferences are immaterial to the question as to whether a dramatic change in congressional district\n\nboundaries will result in the disenfranchisement of voters. 3\n\n\n3\n The State suggests that the Act at issue was the result of the General Assembly prioritizing\nthe \u201cnonracial consideration[]\u201d of obtaining a \u201cpartisan advantage\u201d (Doc. No. 40), but does not\nrefute Plaintiffs\u2019 evidence that the congressional boundaries were drawn to protect Republican\nincumbent Representatives and to exclude the only Democratic incumbent Representative and\nother top performing Democratic candidates. The changes to the congressional district boundaries\nare not based on voters\u2019 partisan affiliation or voting history but rather based on the political\nviewpoints and speech of qualified candidates. The State offers no sworn testimony to the contrary.\n\n 3\n\n Case 3:26-cv-00603 Document 41 Filed 05/14/26 Page 3 of 5 PageID #: 1058\n\f The issues are fully briefed, both sides rely on sworn declarations, and neither side intends\n\nto call live witnesses at a hearing. This Court should rule on Plaintiffs\u2019 Motion for Temporary\n\nRestraining Order today, expeditiously, in advance of tomorrow\u2019s 12:00 p.m. candidate qualifying\n\ndeadline (and candidate withdrawal deadline).\n\n Dated: May 14, 2026 Respectfully submitted,\n\n\n /s/ David W. Garrison\n DAVID W. GARRISON (No. 24968)\n SCOTT P. TIFT (No. 27592)\n JOSHUA A. FRANK (No. 33294)\n BARRETT JOHNSTON MARTIN & GARRISON, PLLC\n 200 31st Ave North\n Nashville, TN 37203\n Telephone: (615) 244-2202\n Facsimile: (615) 252-3798\n dgarrison@barrettjohnston.com\n stift@barrettjohnston.com\n jfrank@barrettjohnston.com\n\n JOHN SPRAGENS (No. 31445)\n SPRAGENS LAW PLC\n 915 Rep. John Lewis Way S., Suite 100\n Nashville, TN 37203\n Telephone: (615) 983-8900\n Facsimile: (615) 682-8533\n john@spragenslaw.com\n\n Attorneys for Plaintiffs\n\n\n\n\n 4\n\n Case 3:26-cv-00603 Document 41 Filed 05/14/26 Page 4 of 5 PageID #: 1059\n\f CERTIFICATE OF SERVICE\n\n I hereby certify that a copy of this Reply in Support of Plaintiffs\u2019 Motion for Temporary\nRestraining Order was filed electronically with the Clerk\u2019s office and served upon Defendants\nusing the Court\u2019s CM/ECF system on May 14, 2026, through their counsel of record as indicated\nbelow:\n\n Zachary L Barker\n Andrew D. Denning\n Office of the Tennessee Attorney General\n P.O. Box 20207\n Nashville, TN 37202-0207\n Phone: (615) 532-4098\n Zachary.Barker@ag.tn.gov\n Andrew.Denning@ag.tn.gov\n\n\n /s/ David W. Garrison\n DAVID W. GARRISON\n BARRETT JOHNSTON\n MARTIN & GARRISON, PLLC\n\n\n\n\n 5\n\n Case 3:26-cv-00603 Document 41 Filed 05/14/26 Page 5 of 5 PageID #: 1060\n\f","ocr_status":1,"date_upload":"2026-05-14T07:56:13.012896-07:00","document_number":"41","attachment_number":null,"pacer_doc_id":"16906405541","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Reply to Response to Motion","acms_document_guid":""}],"date_created":"2026-05-14T07:42:46.758013-07:00","date_modified":"2026-06-11T14:21:27.736389-07:00","date_filed":"2026-05-14","time_filed":null,"entry_number":41,"recap_sequence_number":"2026-05-14.001","pacer_sequence_number":190,"description":"REPLY to Response to re 11 MOTION for Temporary Restraining Order and Preliminary Injunction and for Hearing, 33 Emergency MOTION Expedited Ruling re 11 MOTION for Temporary Restraining Order and Preliminary Injunction and for Hearing Emergency MOTION to Expedite filed by Stephen Cohn, Earle Fisher, Vicki Hale, Charles McIvor Molder, Chaney Mosley, Justin Pearson, Tennessee Democratic Party, The, Telise Turner, Hedy Weinberg. (Garrison, David) (Entered: 05/14/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/464015602/","id":464015602,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73315644/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479178217/","id":479178217,"tags":[],"absolute_url":"/docket/73315644/40/hale-v-lee/","date_created":"2026-05-14T05:14:33.634411-07:00","date_modified":"2026-06-11T14:21:27.703215-07:00","sha1":"c13dfbb407353d8841a48b472ed905694ab72498","page_count":29,"file_size":528040,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.40.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.40.0.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.tnmd.109142/479178217.thumb.1068.png","thumbnail_status":1,"plain_text":" IN THE UNITED STATES DISTRICT COURT\n FOR THE MIDDLE DISTRICT OF TENNESSEE\n\n\n\nVICKI HALE, EARLE FISHER, TELISE )\nTURNER, HEDY WEINBERG, STEVEN )\nCOHEN, CHARLES \u2018CHAZ\u2019 MCIVER ) No. 3:26-cv-00603\nMOLDER, CHANEY MOSLEY, JUSTIN ) CHIEF JUDGE CAMPBELL\nPEARSON, and the TENNESSEE DEMO- )\nCRATIC PARTY, )\n )\n Plaintiffs,\n )\nv. )\n )\nBILL LEE, Governor, TRE HARGETT,\n )\nSecretary of State; MARK GOINS, Ten-\n )\nnessee Coordinator of Elections; all in\n )\ntheir official capacity only,\n )\n Defendants. )\n\n\n\n DEFENDANTS\u2019 RESPONSE IN OPPOSITION TO PLAINTIFFS\u2019\n MOTION FOR A TEMPORARY RESTRAINING ORDER\n AND PRELIMINARY INJUNCTION\n\n\n\n\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 1 of 29 PageID #: 979\n\f TABLE OF CONTENTS\nINTRODUCTION ........................................................................................................................ 1\n\nBACKGROUND ........................................................................................................................... 3\n\nARGUMENT................................................................................................................................. 6\n\n I. Plaintiffs are not likely to succeed on the merits. .................................................... 6\n\n A. Plaintiffs are unlikely to establish standing............................................................. 6\n\n B. Plaintiffs are unlikely to succeed on the merits of Count I. ................................. 10\n\n C. Plaintiffs are unlikely to succeed on the merits of Count II................................. 18\n\n II. Purcell precludes Plaintiffs\u2019 extraordinary request for preliminary relief. ........ 20\n\n III. Plaintiffs will not suffer irreparable harm absent an injunction. ........................ 23\n\n IV. The balance of harms and public interest demands denial of Plaintiffs\u2019 requested\n relief. ............................................................................................................................ 24\nCONCLUSION ........................................................................................................................... 26\n\n\n\n\n ii\n Case 3:26-cv-00603 Document 40 Filed 05/13/26 Page 2 of 29 PageID #: 980\n\f INTRODUCTION1\n\n Plaintiffs come to this Court with a solution in search of a problem. They ask to\n\nstop ongoing, orderly election preparations on the theory that chaos, confusion, and dis-\n\nenfranchisement will ensue if those election preparations are allowed to continue. Dkt. 1,\n\nCompl. \u00b679. But it\u2019s Plaintiffs\u2019 request for extraordinary preliminary relief\u2014not the\n\nState\u2019s process\u2014that would sow chaos. The State has appropriated more than $3.1 mil-\n\nlion for election officials to implement recently enacted changes to Tennessee\u2019s congres-\n\nsional districts before the 2026 primary elections in August. See Decl. of Andrew Dodd\n\n\u00b6\u00b64, 7, 13 (attached as Ex. 1). State officials are already working to meet those deadlines\n\nwith that substantial additional funding. Id. So are the counties. Id. \u00b618; see Decl. of Will\n\nBurns \u00b6\u00b63-9 (attached as Ex. 3). Right here in Davidson County, the Elections Adminis-\n\ntrator told the Tennessean that he is \u201c100% confident\u201d about his office\u2019s ability to imple-\n\nment the recently enacted changes.2\n\n Plaintiffs cannot conflate those ongoing preparations with materially different cir-\n\ncumstances in 2022. Presently, state and local officials are working to implement the\n\n\n\n\n 1 Federal law requires a three-judge court to preside over challenges to \u201cthe constitu-\ntionality of the apportionment of congressional districts.\u201d 28 U.S.C. \u00a72284(a). That in-\ncludes this constitutional challenge to the use of the 2026 congressional districts, unless\nthe Court deems Plaintiffs\u2019 action \u201cwholly insubstantial and frivolous.\u201d Shapiro v.\nMcManus, 577 U.S. 39, 45-46 (2015) (quotations omitted); see Dkt. 37.\n 2 See Evan Mealins, Nashville Elections Chief Confident Office Can Make Changes By Pri-\n\nmary, Tennessean (May 8, 2026) (attached as Ex. 2).\n 1\n\n\n Case 3:26-cv-00603 Document 40 Filed 05/13/26 Page 3 of 29 PageID #: 981\n\fState\u2019s newly enacted congressional districts with substantial funding for overtime, addi-\n\ntional staff, and whatever other resources officials might need. Dodd Decl. \u00b6\u00b64-7. In 2022,\n\nstate officials faced court-imposed changes to the state senate map with three times as\n\nmany districts, three times as many elections, different candidate qualifying deadlines,\n\ndifferent ballots, and without millions in available funding. Id. \u00b6\u00b68-13. There is no pre-\n\nsent state of \u201cchaos,\u201d contra Compl. \u00b679, only hardworking state officials effectuating the\n\nState\u2019s newly enacted laws, Dodd Decl. \u00b6\u00b614-16, 18.\n\n It is Plaintiffs\u2019 request for preliminary relief that, if granted, will risk chaos and\n\nerrors. A court order stopping the State\u2019s elections preparations mid-stream will \u201ccaus[e]\n\nmuch confusion and upset[] the delicate federal-state balance in elections.\u201d Abbott v.\n\nLeague of United Latin Am. Citizens, 146 S. Ct. 418, 419 (2025) (per curiam). There is no\n\nconstitutional basis for that disruption. Their theories of harm are predicated on Tennes-\n\nsee\u2019s relaxed candidate qualifying requirements, allowing candidates to choose their dis-\n\ntricts for their campaigns. Binding precedent dooms their claims.\n\n At bottom, this suit is an invitation to play politics, not law. Even though Supreme\n\nCourt and Sixth Circuit precedent forecloses their claims, Plaintiffs ask for an order to\n\nreinstate the \u201cexisting Congressional District map\u201d\u2014by which they mean the now-re-\n\npealed 2022 districts. Compl. \u00b684. The operative law in Tennessee is the 2026 Plan. The\n\nState is actively preparing for forthcoming elections consistent with that current law, not\n\na repealed one. Plaintiffs\u2019 request for extraordinary relief should be denied.\n\n\n\n 2\n Case 3:26-cv-00603 Document 40 Filed 05/13/26 Page 4 of 29 PageID #: 982\n\f BACKGROUND\n\n On April 29, 2026, the Supreme Court decided Louisiana v. Callais, 608 U.S. ___,\n\n2026 WL 1153054 (2026). The Court held that Louisiana\u2019s existing redistricting plan was\n\nracially gerrymandered and clarified that States need not put racial considerations before\n\nnonracial considerations when they draw congressional districts. Among those nonracial\n\nconsiderations, a State may advance its \u201cpolitical goals\u201d in redistricting. Id. at *13 (slip op.\n\nat 24-25). Likewise, in Alexander v. South Carolina Conference of the NAACP, 602 U.S. 1, 20-\n\n21 (2024), the Supreme Court confirmed that a State may prioritize nonracial considera-\n\ntions in redistricting without being faulted for racially gerrymandering.\n\n With those clarifications, Tennessee convened a special session to redraw its nine\n\ncongressional districts. The special session began on May 5, 2026, three months before\n\nTennessee\u2019s primary elections on August 6, 2026. That special session repealed a statute\n\nprohibiting mid-decade redistricting, 2026 Tenn. Pub. Ch. 1, 2d Extra. Sess. \u00a71, and re-\n\nplaced the existing congressional districts with redrawn districts more favorable to Re-\n\npublican candidates, 2026 Tenn. Pub. Ch. 3, 2d Extra. Sess. \u00a71. The Legislature made its\n\nnonracial considerations open and obvious: \u201cTennessee is a conservative state,\u201d the \u201ccon-\n\ngressional representation in Washington should reflect that,\u201d and the \u201cmap ensures that\u201d\n\nit does.3 The Legislature also took the opportunity to redraw districts without using any\n\n\n\n 3\n Statement of Sen. John Stevens, Senate Judiciary Comm. Tr. 6:24-7:1 (May 6, 2026)\n(attached as Ex. 4); see also id. at 60:14-66:13, 66:23-67:1 (Sen. Stevens) (noting redistricting\nby the Democratic Party in New York and California); id. at 66:23-67:1 (observing \u201cwho\u2019s\n\n 3\n Case 3:26-cv-00603 Document 40 Filed 05/13/26 Page 5 of 29 PageID #: 983\n\fracial data.4 That was a conscious choice to \u201creduc[e] the risk of future legal challenges\u201d\n\nand \u201cprotect[] the state from costly litigation.\u201d5\n\n The Legislature also revised candidate qualification requirements and deadlines.\n\n2026 Tenn. Pub. Ch. 2, 2d Extra. Sess. \u00a71-2. The changes to candidate qualifying relax the\n\nrequirements in the following ways: Any candidates who have already qualified remain\n\nqualified. Id. Any such candidate may choose whether she wants to run in the district\n\nwhere she already qualified or in a different district, or she may withdraw. Id.; see Dodd\n\nDecl. \u00b64.6 Candidate qualifying is also reopened for a brief period to allow any new can-\n\ndidate to qualify. 2026 Tenn. Pub. Ch. 2, 2d Extra. Sess. \u00a71; see Dodd Decl. \u00b619. But those\n\nchanges avoid timing concerns by ending candidate qualifying on May 15, followed by\n\nthe parties\u2019 certification by May 17, so that counties can begin preparing ballots as early\n\n\n\ngoing to control the House of Representatives\u201d was up for grabs and stating \u201c[w]e want\nRepublicans to maintain control of the House of Representatives\u201d); id. at 70:7-11, 71:8-11,\n72:3-8 (Sen. Stevens) (\u201cWe are attempting to maximize the chances that the congressional\ndelegation of Tennessee will maintain a Republican majority in the United States House\nof Representatives. That\u2019s our intent.\u201d).\n 4 Statement of Speaker Cameron Sexton, House Cong. Redistricting Comm. Tr. 68:1-3\n\n(May 6, 2026) (Ex. 5) (\u201c[T]he map that was generated was based on population and poli-\ntics[.] [N]o racial data was used, and no incumbents were paired together.\u201d); id. at 80:15-\n18 (Speaker Sexton) (similar).\n 5\n Ex. 4, Statement of Sen. John Stevens, Senate Judiciary Comm. Tr. 69:12-14; see also\nid. at 68:19-22 (Sen. Stevens) (similar).\n 6 Sixteen candidates now reside beyond the district boundaries where they qualified.\n\nDodd Decl. \u00b617. Those candidates are Republicans, Independents, and Democrats who\ninitially qualified in CD-4, CD-5, CD-6, CD-8, and CD-9. See id. The relaxed qualification\nrequirements allow these candidates to choose to continue their campaigns in the district\nwhere they qualified or in the district where they now reside, or to withdraw. 2026 Tenn.\nPub. Ch. 2, 2d Extra. Sess. \u00a71.\n\n 4\n Case 3:26-cv-00603 Document 40 Filed 05/13/26 Page 6 of 29 PageID #: 984\n\fas May 18. See Dodd Decl. \u00b69. Those ballots, moreover, are anticipated to have fewer\n\ncandidates than the 2022 elections. Id. \u00b610.\n\n To implement these changes, the State appropriated $3.1 million for state and local\n\nelection officials. 2026 Tenn. Pub. Ch. 4, 2d Extra. Sess. \u00a72. The additional funding will\n\npay for overtime and additional staff, expedited services from vendors, and notices to\n\nvoters and other miscellaneous items, including training, signage, and voter education.\n\nDodd Decl. \u00b613.\n\n With that substantial funding, state and local election officials have already begun\n\nimplementing the 2026 Plan and preparing for the 2026 primary elections. Id. \u00b6\u00b613-16, 18.\n\nImmediately upon the enactment of the 2026 Plan, the Division of Elections made infor-\n\nmation about the 2026 districts available on its website. Id. \u00b615. Contrary to Plaintiffs\u2019\n\nclaim (at 16) that voters have been left \u201cin the dark,\u201d a \u201cvoter look-up\u201d function went live\n\nlast Thursday, May 7, 2026, and allows any voter to identify his or her 2026 congressional\n\ndistrict by typing in his or her address. Id.7 Counties are also making preparations to no-\n\ntify voters. See Burns Decl. \u00b65. For candidates, the Division overnighted letters to already-\n\nqualified candidates, advised them of the revised congressional districts, and advised\n\nthem that they remained qualified to run in their existing district or a district of their\n\nchoosing. Dodd Decl. \u00b616. Additionally, the Division is in close coordination with local\n\n\n 7\n 2026 Congressional Redistricting Revised District Boundaries, Tennessee Secretary of\nState (last updated May 12, 2026), https://sos.tn.gov/announcements/2026-congressional-\nredistricting.\n\n 5\n Case 3:26-cv-00603 Document 40 Filed 05/13/26 Page 7 of 29 PageID #: 985\n\felections officials. Before the 2026 Plan even passed, the Division sent a memorandum\n\nasking counties to begin planning for changes to districts. Id. \u00b614. And as soon as the\n\nGovernor signed the 2026 Plan, the Division sent another memorandum to county elec-\n\ntion commissions that outlined next steps to implement the 2026 Plan and advised them\n\nof the amended candidate qualifying information. Id.\u00b615. Since last week, counties have\n\nalready worked substantial overtime and made substantial progress toward implement-\n\ning the 2026 Plan. Id. \u00b618.\n\n ARGUMENT\n\n A \u201cpreliminary injunction is an extraordinary and drastic remedy, one that should\n\nnot be granted unless the movant, by a clear showing, carries the burden of persuasion.\u201d\n\nEnchant Christmas Light Maze & Market Ltd. v. Glowco, LLC, 958 F.3d 532, 539 (6th Cir.\n\n2020). To do so, a plaintiff must establish that (1) \u201che is likely to succeed on the merits,\u201d\n\n(2) he is likely to suffer irreparable harm in the absence of preliminary relief, (3) \u201cthe bal-\n\nance of equities tips in his favor,\u201d and (4) \u201can injunction is in the public interest.\u201d Id. at\n\n535-36; EOG Res. v. Lucky Land Mgmt., 134 F.4th 868, 885 (6th Cir. 2025) (holding that all\n\nfour factors are \u201cprerequisite[s]\u201d). Plaintiffs have not cleared any one of those hurdles.\n\nI. Plaintiffs are not likely to succeed on the merits.\n\n A. Plaintiffs are unlikely to establish standing.\n\n Plaintiffs\u2019 alleged harm is too speculative for standing. Standing requirements\n\n\u201cprevent the judicial process from being used to usurp the powers of the political\n\n\n\n\n 6\n Case 3:26-cv-00603 Document 40 Filed 05/13/26 Page 8 of 29 PageID #: 986\n\fbranches.\u201d Clapper v. Amnesty Int\u2019l USA, 568 U.S. 398, 408 (2013). Plaintiffs\u2019 \u201cinjury must\n\nbe \u2018concrete, particularized, and actual or imminent\u2019\u201d for standing, not merely a \u201c\u2018possible\n\nfuture injury.\u2019\u201d Id. at 409. \u201cAt the preliminary injunction stage, \u2026 the plaintiff must make\n\na \u2018clear showing\u2019 that she is \u2018likely\u2019 to establish each element of standing,\u201d that is, actual\n\nor imminent injury, causation, and redressability. Murthy v. Missouri, 603 U.S. 43, 58\n\n(2024) (citation omitted).\n\n 1. With respect to Count I, Plaintiffs make no \u201cclear showing\u201d that there will be\n\n\u201cchaos\u201d or \u201cconfusion\u201d or \u201cdisenfranchisement,\u201d contra Dkt. 12, Memo. in Support of PI\n\nat 13-17. Plaintiffs\u2019 declarations do not suggest they are confused, only that they disap-\n\nprove of the Legislature\u2019s recently enacted laws. See, e.g., Dkt. 11-3, Weinberg Decl. \u00b611\n\n(\u201cI am very disturbed that this week the Tennessee [Legislature] has approved new geo-\n\ngraphic boundaries \u2026 .\u201d); Dkt. 11-8, Pearson Decl. \u00b69 (critiquing provision \u201callowing\n\nnew candidates \u2026 to now join the race\u201d); see Already, LLC v. Nike, Inc., 568 U.S. 85, 99\n\n(2013) (observing that standing must be based \u201con an injury more particularized and\n\nmore concrete than the mere assertion that something unlawful benefited the plaintiff\u2019s\n\ncompetitor\u201d). Nor are statements that declarants are \u201cconcerned\u201d there might be election\n\nissues sufficient to make a clear showing of imminent and non-speculative harm. See Dkt.\n\n28, Byrd Decl. \u00b610; Dkt. 29, Perkins Decl. \u00b64. Plaintiffs \u201ccannot manufacture standing\n\nmerely by inflicting harm on themselves based on their fears of hypothetical future harm\n\nthat is not certainly impending.\u201d Clapper, 568 U.S. at 416.\n\n\n\n 7\n Case 3:26-cv-00603 Document 40 Filed 05/13/26 Page 9 of 29 PageID #: 987\n\f Nor can Plaintiffs make that \u201cclear showing,\u201d Murthy, 603 U.S. at 58 (citation omit-\n\nted), with assertions that the present circumstances can be equated to the \u201cfederal redis-\n\ntricting in 2022.\u201d Contra Dkt. 12 at 14-15. Despite manifold factual distinctions between\n\n2022 and today, Dodd Decl. \u00b6\u00b67-13, Plaintiffs contend what happened in 2022 can predict\n\nthe future. Dkt. 12 at 14-15. But \u201cthe past\u201d cannot \u201cin itself show a present case or contro-\n\nversy,\u201d Murthy, 603 U.S. at 59 (quotation omitted), especially not with all the material\n\ndifferences between present-day circumstances and 2022. See Anderson v. Raffensperger,\n\n497 F. Supp. 3d 1300, 1309 (N.D. Ga. 2020) (concluding earlier elections \u201creveal little about\n\nelections today\u201d); see also Sumpter v. Wayne County, 868 F.3d 473, 491 (6th Cir. 2017) (find-\n\ning allegations of imminent injury \u201cfurther diminished\u201d by defendants\u2019 changed policy).\n\n The attached declaration from the Division of Elections details those differences\n\nand undermines any possible claim of an imminent injury. Presently, state and local offi-\n\ncials have $3.1 million allocated for overtime and additional staff to implement new dis-\n\ntrict lines. Dodd Decl. \u00b6\u00b67, 13. No such funding was available in 2022, which created the\n\n\u201crisk of incomplete or inaccurate work.\u201d Id. Nor was the congressional plan even at issue\n\nin 2022. Id. \u00b611. The 2022 litigation was about the State Senate plan with 33 senate dis-\n\ntricts, as compared to Tennessee\u2019s newly enacted congressional plan, which has only 9\n\ncongressional districts, requires no changes for 53 counties, and only substitutes district\n\nnumbers in the remaining 32 counties. Id. The qualifying timeline is also different. Pres-\n\nently, \u201ccounties could potentially begin preparing their ballots and Division review could\n\n\n\n 8\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 10 of 29 PageID #: 988\n\fbegin as soon as May 18,\u201d which is earlier than the contemplated timeline in the 2022\n\nlitigation. Id. \u00b69. And those forthcoming ballots are also far simpler than those required\n\nin 2022 because there are fewer candidates. Id. \u00b610.\n\n With election preparations already underway, and with the assistance of \u201csignifi-\n\ncant funds to meet those deadlines,\u201d Dodd Decl. \u00b67, Plaintiffs\u2019 predicted harm \u201cis too\n\nspeculative to satisfy the well-established requirement that threatened injury must be\n\n\u2018certainly impending.\u2019\u201d Clapper, 568 U.S. at 401 (citation omitted). Their concerns \u201cof pos-\n\nsible future injury are not sufficient.\u201d Id. at 409 (quotation omitted).\n\n 2. For Count II, Plaintiffs\u2019 standing arguments are similarly speculative without\n\nany cognizable harm. See, e.g., Gill v. Whitford, 585 U.S. 48, 54 (2018) (remanding for plain-\n\ntiffs to \u201cattempt to demonstrate standing\u201d). Plaintiffs contend voters and candidates have\n\nalready developed associational bonds with each other through fundraising, get-out-the\n\nvote efforts, and campaigning, and that the 2026 Plan breaks those associational bonds.\n\nDkt. 12 at 19. But allegations that new district lines cause a party to have \u201cdifficulty rais-\n\ning money, attracting candidates, and mobilizing voters,\u201d or make \u201cfundraising, attract-\n\ning volunteers, [and] campaigning\u201d more difficult are not cognizable First Amendment\n\ninjuries. Rucho v. Common Cause, 588 U.S. 684, 713-14 (2019). Federal courts are not the\n\nappropriate tribunals to adjudicate those nebulous harms. See id. at 714 (\u201cHow much of\n\na decline in voter engagement is enough to constitute a First Amendment burden?\u201d). And\n\n\n\n\n 9\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 11 of 29 PageID #: 989\n\fregardless, Tennessee\u2019s newly enacted qualification requirements allow candidates to\n\nchoose their district. 2026 Tenn. Pub. Ch. 2, 2d Extra. Sess. \u00a71.\n\n Bost v. Illinois State Board of Elections, 607 U.S. 71 (2026), is inapposite. Contra Dkt.\n\n12 at 20. Bost held that candidates have standing to challenge a state law permitting elec-\n\ntion officials to count mail-in ballots received after election day because\u2014for purposes of\n\na justiciable preemption claim\u2014they had \u201can obvious personal stake in how the result is\n\ndetermined and regarded.\u201d Bost, 607 U.S. at 77-79. Unlike Bost, Plaintiffs assert a general-\n\nized grievance about the 2026 Plan\u2019s lines and then fault relaxed qualifying requirements\n\nallowing candidates to choose their district. But see Gill, 585 U.S. at 66. These assertions\n\nof harm are simply the \u201cgeneral legal, moral, ideological, or policy objection to a particu-\n\nlar government action\u201d that standing rules are designed to screen out. FDA v. All. for\n\nHippocratic Med., 602 U.S. 367, 381 (2024); cf. Green Party of Tenn. v. Hargett, 700 F.3d 816,\n\n829 (6th Cir. 2012) (holding that plaintiffs were not injured by a requirement that did not\n\n\u201caffect [their] ability to get on the ballot\u201d).\n\n B. Plaintiffs are unlikely to succeed on the merits of Count I.\n\n Plaintiffs claim the 2026 Plan and relaxed qualifying deadlines violate the First and\n\nFourteenth Amendment under the Anderson-Burdick test. Dkt. 12 at 12-18. Where it ap-\n\nplies, Anderson-Burdick requires \u201cbalanc[ing] an election law\u2019s burdens on voters\u2019 rights\n\nagainst the state\u2019s interests in the law as a threshold inquiry to determine the level of\n\nscrutiny that courts should apply to the law.\u201d Lichtenstein v. Hargett, 83 F.4th 575, 589 (6th\n\n\n\n 10\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 12 of 29 PageID #: 990\n\fCir. 2023). No Anderson-Burdick balancing applies here. And even if it did, Plaintiffs\u2019 spec-\n\nulation about possible election administration issues does not warrant the extraordinary\n\nremedy of a preliminary injunction.\n\n 1. Anderson-Burdick does not apply \u201cto all election-related challenges.\u201d Lichtenstein,\n\n83 F.4th at 593. It covers only \u201cthree types of claims.\u201d Id. at 590. First, it applies to \u201cballot-\n\naccess claims\u201d for laws limiting \u201ccandidates who could appear on a ballot.\u201d Id. (emphasis\n\nomitted). Second, it applies to \u201cpolitical-party associational claims\u201d for laws like open\n\nprimary requirements. Id. at 590-91. Third, it applies \u201cto claims that election laws violate\n\na voter\u2019s right to vote,\u201d such as challenges to laws requiring photo ID. Id. at 591.\n\n Count I does not fit within any one of these groups. Id. For starters, Anderson-Bur-\n\ndick cannot apply to Plaintiffs\u2019 complaints about the 2026 Plan itself, contra Dkt. 12 at 14-\n\n16. Plaintiffs cannot point to any case where Anderson-Burdick applied to redistricting. See\n\nJackson v. Tarrant County, 158 F.4th 571, 593 (5th Cir. 2025) (\u201c[W]e are aware of no cases\n\napplying Anderson-Burdick to redistricting decisions.\u201d). This Court would thus have to\n\n\u201cexpand Anderson-Burdick\u2019s balancing test into uncharted territory\u201d if applied here. Lich-\n\ntenstein, 83 F.4th at 591. That forecloses preliminary relief: challengers \u201cseek[ing] to ex-\n\ntend the constitution[\u2019s] guarantees to new territory\u201d cannot make \u201ca showing of a like-\n\nlihood of success on the merits.\u201d L.W. v. Skrmetti, 83 F.4th 460, 471 (6th Cir. 2023).\n\n Nor does Anderson-Burdick apply to Plaintiffs\u2019 complaints about the State\u2019s relaxed\n\nqualifying deadlines for candidates. See Dkt. 12 at 13-14. While Anderson-Burdick applies\n\n\n\n 11\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 13 of 29 PageID #: 991\n\fto laws \u201climiting a candidate\u2019s ability to get on the ballot,\u201d Lichtenstein, 83 F.4th at 590,\n\nTennessee\u2019s recently enacted law does not limit opportunities for candidates. It expands\n\nthose opportunities. Plaintiffs cannot possibly assert that the law, relaxing qualification\n\nrequirements, impedes candidates getting on the ballot. A candidate who has already\n\nqualified remains qualified; that candidate may choose his or her district; and any new\n\nprospective candidates can qualify now too. Dodd Decl. \u00b64.8\n\n 2. To shoehorn their claim into Anderson-Burdick, Plaintiffs attempt to style it as a\n\n\u201cright to vote\u201d claim based on speculation about \u201cchaos\u201d and \u201cconfusion\u201d and \u201cdisen-\n\nfranchisement\u201d in forthcoming elections. Dkt. 12 at 12-18. That, too, stretches Anderson-\n\nBurdick beyond its reach. A \u201cright to vote\u201d claim for Anderson-Burdick ordinarily involves\n\nlaws that \u201cmak[e] it too difficult to cast a ballot,\u201d such as photo ID laws, or \u201crules gov-\n\nerning absentee[]ballot[s]\u201d and \u201cearly voting.\u201d Lichtenstein, 83 F.4th at 591-92. In other\n\nwords, the laws themselves are challenged as \u201celection regulation[s]\u201d that make it harder\n\nto vote. Ohio Democratic Party v. Husted, 834 F.3d 620, 626 (6th Cir. 2016).\n\n But here, Plaintiffs contend the newly enacted laws will create downstream elec-\n\ntion administration issues that they speculate may burden the right to vote. Dkt. 12 at 12-\n\n\n\n\n 8\n Plaintiffs also fault (at 16) changes to notice requirements. But voters can already\nfind their districts by typing in their address on the Secretary of State\u2019s website. See Dodd\nDecl. \u00b615. Applying Anderson-Burdick to police the sufficiency of a State\u2019s already-suffi-\ncient notice requirements would again require extending the doctrine to new territory.\nSee Lichtenstein, 83 F.4th at 590-94. But see Skrmetti, 83 F.4th at 471.\n\n 12\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 14 of 29 PageID #: 992\n\f17. But the \u201cConstitution contains no universal \u2018cost-benefit balancing\u2019 provision\u201d for an-\n\nything that could affect voting. Lichtenstein, 83 F.4th at 593. That theory of potential down-\n\nstream harm would expand Anderson-Burdick \u201cto all election-related challenges\u201d when\n\nthe Sixth Circuit has been careful not to do so. Id. There is no logical endpoint. A plaintiff\n\ncould challenge any election law even if it did not directly regulate voting based on al-\n\nleged (speculative) downstream harm. Extending the Anderson-Burdick test as Plaintiffs\n\nrequest would \u201cconflict[] with both text and precedent.\u201d Id.\n\n 3. Even if Anderson-Burdick applied, the new law easily satisfies it. Anderson-Bur-\n\ndick allows courts, in limited contexts, \u201cto balance an election law\u2019s burden on voters\u2019\n\nrights against the state\u2019s interests in the law\u201d to determine, \u201cas a threshold inquiry,\u201d\n\nwhether rational basis or some other level of scrutiny applies. Lichtenstein, 83 F.3d at 589.\n\nMinimal burdens \u201cneed only satisfy something approaching rational-basis review,\u201d\n\nwhile \u201csevere burdens must satisfy something approaching strict scrutiny; and laws in\n\nbetween must satisfy a level of scrutiny commensurate with their burdens.\u201d Id.\n\n a. At most, rational-basis review applies here because any burden on voting is\n\nminimal. See, e.g., Crawford v. Marion Cnty. Election Bd., 553 U.S. 181, 197-98 (2008) (plu-\n\nrality op.) (finding minimal burden); Kowall v. Benson, 18 F.4th 542, 547-48 (6th Cir. 2021).\n\nContrary to Plaintiffs\u2019 forecasting of chaos and confusion, state and local officials are\n\n\n\n\n 13\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 15 of 29 PageID #: 993\n\fworking overtime with substantial funding to implement the 2026 Plan for primary elec-\n\ntions, which remain nearly three months away. See Dodd Dec. \u00b6\u00b614-16, 18; Burns Decl.\n\n\u00b6\u00b67-8.9\n\n Plaintiffs exaggerate the burden by conflating the present election preparation ef-\n\nforts with 2022 litigation. See Dkt. 12 at 13-16. The present-day changes to the State\u2019s 9\n\ncongressional districts are materially distinguishable from that earlier litigation involving\n\n33 senate districts redrawn after the 2020 census. Dodd Decl. \u00b611. The maps themselves\n\nare different\u2014with three times as many districts and corresponding elections at issue in\n\n2022. Id. The election deadlines are different\u2014on an earlier timeline than the proposed\n\nadjustments to candidate qualifying in 2022. Id. \u00b69. The ballots are different\u2014with far\n\nfewer candidates on the ballot than in 2022. Id. \u00b610. And, as for \u201cthe most significant\n\n\n\n\n 9\n Plaintiffs submitted supplemental declarations from one Davidson County Election\nCommissioner, Dkt. 28, and one Montgomery County Election Commissioner, Dkt. 29.\nThese declarations posit that it is \u201cunclear how the Commission is going to be able to\ncomply with the new map\u201d and \u201cballot permutations by the statutory deadline.\u201d Dkt. 29,\nPerkins Decl. \u00b64; see also Dkt. 28, Byrd. Decl. \u00b65. County election commissions are multi-\nmember bodies. Tenn. Code Ann. \u00a72-12-103(a). The views of two commissioners from\ntwo counties are not a basis for enjoining ongoing election preparations across the State.\nAs for Davidson County, the Commission Chairman (and former Coordinator of Elec-\ntions for the entire State) avers that the county will be able to create all ballots, handle\nsplit precincts, timely notify voters with new voter registration cards by the first week of\nJuly, and otherwise complete all required preparations. Burns Decl. \u00b6\u00b63-9. As for Mont-\ngomery County, Plaintiffs\u2019 declarant also signed an open letter last week stating she \u201cop-\npose[d] the corrupt redrawing of our Congressional district.\u201d Charles Uffelman, Open\nLetter (May 5, 2026), available at https://clarksvillenow.com/local/local-elected-officials-\ncandidates-sign-letter-opposing-gerrymandering-effort-opinion/.\n\n 14\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 16 of 29 PageID #: 994\n\fdifference\u201d according to the Division of Elections, the funding is different. Id. \u00b613. Pres-\n\nently, the State is providing more than $3.1 million in funding to state and local officials\n\ncharged with implementing any changes to districts. Id. The lack of funding in 2022 was\n\nwhat risked \u201cincomplete and inaccurate work.\u201d Id.\n\n Plaintiffs\u2019 allegations fail to account for these material distinctions. Those distinc-\n\ntions further confirm that any burden on voters on election day is speculative at best\u2014\n\nand certainly not above the \u201cminimal\u201d threshold. See, e.g., Husted, 834 F.3d at 632 (holding\n\n\u201c\u2018the character and magnitude of the asserted injury\u2019\u201d \u201cresult[ed] only in a minimal bur-\n\nden\u201d on right to vote and thus a standard \u201cakin to rational basis\u201d review applied (citation\n\nomitted)); Ohio Council 8 Am. Fed\u2019n of State v. Husted, 814 F.3d 329, 338 (6th Cir. 2016)\n\n(treating the burden as \u201cminimal\u201d based on \u201cthe expansive ability of the plaintiffs to ex-\n\nercise their associational and expressive rights in other ways\u201d).\n\n If the burden is only minimal, rational-basis review applies, asking \u201cwhether the\n\nlimits are rationally related to a legitimate government interest.\u201d Kowall, 18 F.4th at 548.10\n\nPlaintiffs cannot prevail under that deferential standard. The State\u2019s policy changes are\n\n\u201cpresumed constitutional, and the burden is on plaintiffs to negate \u2018every conceivable\n\nbasis which might support it.\u2019\u201d In re City of Detroit, 841 F.3d 684, 701 (6th Cir. 2016). The\n\n\n\n\n 10\n Similarly, if the Court concludes that Anderson-Burdick doesn\u2019t apply at all, then ra-\ntional-basis review applies, and Defendants satisfy that standard for the same reasons.\nSee Kowall, 18 F.4th at 546-48.\n\n 15\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 17 of 29 PageID #: 995\n\fState has a constitutional \u201cprerogative to prescribe the \u2018Times, Place, and Manner of hold-\n\ning Elections for Senators and Representatives.\u2019\u201d Husted, 834 F.3d at 626 (quoting U.S.\n\nConst. art. I, \u00a74, cl.1). And \u201c[f]ederal law \u2026 generally defers to the states\u2019 authority to\n\nregulate the right to vote.\u201d Id. Consistent with those background principles, the State may\n\nadvance its stated goals in redistricting\u2014both political goals and the mitigation of future\n\nlitigation risk by redistricting without racial data. Supra pp.3-4; see Alexander, 602 U.S. at\n\n6 (\u201c[A] legislature may pursue partisan ends \u2026.\u201d); see also Callais, 2026 WL 1153054, at\n\n*13 (slip op. at 24-26) (concluding states may prioritize political goals but face legal liabil-\n\nity if allowing race to predominate).\n\n b. Even if intermediate scrutiny applied, Plaintiffs cannot prevail. Intermediate\n\nscrutiny under Anderson-Burdick is \u201ca \u2018flexible\u2019 analysis, \u2018weighing the burden on the\n\nplaintiffs against the state\u2019s asserted interests and chosen means of pursuing it.\u201d Husted,\n\n834 F.3d at 627 (citation omitted). The purported burden is small for the reasons already\n\nstated. Supra I.B.3.a. And Plaintiffs\u2019 speculation about chaos and confusion is unfounded.\n\nId. The same day the law was enacted, the Division of Elections updated the \u201cvoter look-\n\nup\u201d function for voters to identify their districts, and election preparations are proceed-\n\ning apace. Dodd Decl. \u00b6\u00b67, 14-16, 18; see also Burns Decl. \u00b6\u00b65-7 (noting Davidson County\n\naffected voters will be notified with new voter registration cards and on the county web-\n\nsite and explaining how funding assistance allowed the county to create a \u201cspecial redis-\n\ntricting team\u201d to implement changes).\n\n\n\n 16\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 18 of 29 PageID #: 996\n\f As for the interests justifying the law under that \u201cflexible\u201d scrutiny, Husted, 834\n\nF.3d at 627, the State may redraw districts not only to obtain a partisan advantage but\n\nalso to avoid the litigation risks of the old map. Two weeks ago, the Supreme Court af-\n\nfirmed Louisiana unconstitutionally elevated race above other nonracial considerations,\n\nsuch as politics. Callais, 2026 WL 1153054 at *4, *13 (slip op. at 3, 24-25). So while Plaintiffs\n\ncomplain of a \u201clast-minute change[],\u201d Dkt. 12 at 17, the State moved quickly after Callais\n\nclarified the State could lawfully prioritize the policy goal of sending a \u201cconservative\u201d\n\ndelegation to Washington. Supra pp.3-4. And the State\u2019s decision to redistrict on the heels\n\nof Callais and thereby \u201c[a]void[] the expense of litigation is a legitimate government in-\n\nterest.\u201d Neinast v. Bd. of Trs. of Columbus Metro. Libr., 346 F.3d 585, 594 (6th Cir. 2003). To\n\naccommodate the new timeline, moreover, the State allowed already-qualified candi-\n\ndates to pick their districts and allows new candidates to qualify too. 2026 Tenn. Pub. Ch.\n\n2, 2d Extra. Sess. \u00a71. The State\u2019s \u201cchosen means of pursuing\u201d its interests, then, satisfy\n\nAnderson-Burdick\u2019s intermediate scrutiny.11\n\n In short, Anderson-Burdick does not apply to Count I. Even if it did, it does not\n\ncompel the extraordinary remedy of a preliminary injunction.\n\n\n\n\n 11\n Applying strict scrutiny would be error. See, e.g., Thompson v. DeWine, 959 F.3d 804,\n811 (6th Cir. 2020) (per curiam) (staying injunction after district court\u2019s application of\nstrict scrutiny instead of intermediate scrutiny).\n\n 17\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 19 of 29 PageID #: 997\n\f C. Plaintiffs are unlikely to succeed on the merits of Count II.\n\n Supreme Court and Sixth Circuit precedents foreclose Count II, making Plaintiffs\u2019\n\nodds of success on the merits near zero. Plaintiffs contend that before the 2026 redistrict-\n\ning, they \u201cengaged in associational conduct,\u201d such as \u201cpolitical organizing, volunteering,\n\nspeaking, campaigning, and donating.\u201d Dkt. 12 at 19. In so doing, Plaintiffs claim they\n\n\u201ccreated \u2026 associational bonds \u2026 within their previous districts, relying on Tennessee\u2019s\n\nexisting congressional district map.\u201d Id. Invoking Anderson-Burdick, Plaintiffs argue the\n\n2026 redistricting will \u201cseverely burden Plaintiffs\u2019 right to associate.\u201d Id. at 20.12\n\n Anderson-Burdick is inapplicable. As with Count I, Anderson-Burdick does not apply\n\nto allegations of associational harm arising from the redrawing of district lines or relaxed\n\nqualifying deadlines. See Jackson, 158 F.4th at 593; see also Lichtenstein, 83 F.4th at 593-94.\n\n Supreme Court precedent, moreover, forecloses Plaintiffs\u2019 associational claim. For\n\ndecades, the Supreme Court contemplated a constitutional right for voters and candi-\n\ndates to associate in their preferred districts with their preferred candidates. See Gill, 585\n\nU.S. at 60-70. Then came Rucho v. Common Cause. Plaintiffs there contended that new dis-\n\ntrict plans violated their \u201cFirst Amendment right to association.\u201d 588 U.S. at 713. They\n\n\n\n 12 Plaintiffs filed a supplemental brief contending that some Candidate Plaintiffs\u2019 ad-\ndresses were targeted by the redistricting changes, not as a separate count but seemingly\nto shore up their current allegations. See Dkt. 24 at 6-8. Described in the Division\u2019s at-\ntached declaration, more than a dozen candidates identifying as Republicans, Democrats,\nor Independents now reside in a different district than where they qualified\u2014not just\nCandidate Plaintiffs. See Dodd Decl. \u00b617. But the law allows the candidates to choose\ntheir district. 2026 Tenn. Pub. Ch. 2, 2d Extra. Sess. \u00a71.\n\n 18\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 20 of 29 PageID #: 998\n\fcontended they \u201cface[d] difficulty raising money, attracting candidates, and mobilizing\n\nvoters to support the political causes and issues such Plaintiffs sought to advance.\u201d Id.\n\n(quotations omitted). The Supreme Court was unequivocal in response: \u201c[T]here are no\n\nrestrictions on speech, association, or any other First Amendment activities in the district-\n\ning plans at issue. The plaintiffs are free to engage in those activities no matter what the\n\neffect of a plan may be on their district.\u201d Id. at 713-14.\n\n Here too, nothing in the 2026 Plan nor the accompanying changes to election dead-\n\nlines stop Plaintiffs from associating with whomever they wish. Plaintiffs can still\n\n\u201cknock[] on doors, ma[ke] phone calls and text messages, attend[] community forums,\n\nneighborhood meetings, civic association gatherings, and faith community events.\u201d Con-\n\ntra Dkt. 12 at 19. And nothing stops a voter from supporting her preferred candidates. See\n\nRucho, 588 U.S. at 713-14.\n\n Likewise, the Sixth Circuit has long rejected alleged harms like Plaintiffs\u2019 alleged\n\nassociational harm. In the Sixth Circuit, a law affecting a candidate\u2019s campaign for office\n\nimposes no First Amendment burden because there is \u201cno fundamental right to run for\n\nelective office,\u201d let alone in a congressional district drawn to the candidate\u2019s liking.\n\nZielasko v. Ohio, 873 F.2d 957, 961 (6th Cir. 1989); see also Kowall, 18 F.4th at 547 (\u201c[C]andi-\n\ndates do not have a fundamental right to run for office.\u201d).13 Likewise, the new law does\n\n\n 13\n For this reason and others, Plaintiffs\u2019 supplemental brief and declarations faulting\nthe 2026 Plan because (some) Candidate Plaintiffs were moved from CD-9 to CD-5, or vice\nversa, are not evidence of any constitutional infirmity. See Dkt. 24 at 6-7; Dkt. 26 at 1-2;\n\n 19\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 21 of 29 PageID #: 999\n\f\u201cnot \u2018impose constitutionally suspect burdens on [voters\u2019] right to associate or to choose\n\namong candidates\u2019 \u2026 because no one is guaranteed the right to vote for a specific indi-\n\nvidual.\u201d Zielasko, 873 F.2d at 961 (quoting Anderson v. Celebrezze, 460 U.S. 780, 788 (1983)).\n\n\u201cIn the absence of any fundamental right,\u201d even if Anderson-Burdick applied, only \u201ca ra-\n\ntional basis level of scrutiny\u201d applies. Id. And Plaintiffs lose under that deferential stand-\n\nard. Supra I.B.3.a.\n\n 2. Plaintiffs\u2019 claims are also vastly overstated. As Rucho observed, district lines do\n\nnot restrict \u201cspeech, association, or any other First Amendment activities.\u201d 588 U.S. at\n\n713. As for Tennessee\u2019s relaxed candidate qualifying requirements allowing candidates to\n\nchoose their districts, they are the opposite of a law \u201climiting a political party\u2019s ability\u201d to\n\nassociate. Lichtenstein, 83 F.4th at 591 (emphasis added). Plaintiffs cannot establish a \u201clike-\n\nlihood of success on the merits.\u201d Glowco, 958 F.3d at 539 (cleaned up). And that\u2019s \u201cfatal\u201d\n\nto their motion. Id.\n\nII. Purcell precludes Plaintiffs\u2019 extraordinary request for preliminary relief.\n\n Plaintiffs ask for a temporary restraining order or preliminary injunction with the\n\neffect of stopping ongoing preparations mid-stream. Purcell v. Gonzalez, 549 U.S. 1 (2006)\n\n\n\n\nDkt. 27 at 3-4. The redistricting affected candidates of all parties. Dodd Decl. \u00b617 (identi-\nfying 16 candidates of varying parties affected by redistricting lines). And the relaxed\ncandidate qualifying provisions allow Plaintiffs to run in either CD-9 or CD-5. See 2026\nTenn. Pub. Ch. 2, 2d Extra. Sess. \u00a71.\n\n 20\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 22 of 29 PageID #: 1000\n\f(per curiam), precludes that relief. Just as the Supreme Court stayed and summarily re-\n\nversed a federal court that stopped ongoing elections preparations after mid-decade re-\n\ndistricting in Texas, it would be error to stop Tennessee\u2019s. See Abbott, 146 S. Ct. at 419;\n\nAbbott v. LULAC, ___ S. Ct. ___, 2026 WL 1127246 (Apr. 27, 2026) (Mem.).\n\n The Supreme Court \u201chas repeatedly emphasized that lower federal courts should\n\nordinarily not alter the election rules on the eve of an election.\u201d Republican Nat\u2019l Comm. v.\n\nDemocratic Nat\u2019l Comm., 589 U.S. 423, 424-25 (2020) (per curiam); see Merrill v. Milligan,\n\n142 S. Ct. 879, 879 (2022) (Mem.) (Kavanaugh, J., concurring) (\u201c[F]ederal appellate courts\n\nshould stay injunctions when, as here, lower federal courts contravene th[e] [Purcell] prin-\n\nciple.\u201d). As early as Reynolds v. Sims, the Supreme Court has emphasized federal courts\n\nmust stay their hand even in the face of constitutional claims. 377 U.S. 533, 585 (1964).\n\n\u201cSims has been the guidon to a number of courts that have refrained from enjoining im-\n\npending elections,\u201d Chisom v. Roemer, 853 F.2d 1186, 1190 (5th Cir. 1988), even for \u201cundis-\n\nputed\u201d constitutional violations,\u201c Sw. Voter Registration Educ. Project v. Shelley, 344 F.3d\n\n914, 918 (9th Cir. 2003) (per curiam).\n\n Purcell squarely applies to the present circumstances in Tennessee. Contra Dkt. 12\n\nat 21-23. Implementation of the 2026 Plan is ongoing, and candidate qualifying is under-\n\nway, ending this Friday, for the State\u2019s August primaries. Dodd Decl. \u00b6\u00b613-16, 18. The\n\nSupreme Court has stayed preliminary injunctions under Purcell on similar (or earlier)\n\n\n\n\n 21\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 23 of 29 PageID #: 1001\n\ftimelines. See Abbott, 146 S. Ct. at 419; Merrill, 142 S. Ct. at 879; see also Ardoin v. Robinson,\n\n142 S. Ct. 2892, 2892-93 (2022) (Mem.); Robinson v. Callais, 144 S. Ct. 1171 (2024) (Mem.).\n\n Plaintiffs claim that Purcell does not apply when \u201cStates disrupt elections.\u201d Dkt. 12\n\nat 21. That argument cannot be squared with the Supreme Court\u2019s recent stay involving\n\nTexas\u2019s mid-decade congressional redistricting. See Abbott, 146 S. Ct. at 419. As exempli-\n\nfied by the Abbott stay, the Purcell doctrine limits the judicial power, not the State\u2019s pre-\n\nrogative to determine the time, place, and manner of holding congressional elections. Id.;\n\ncontra Dkt. 12 at 22. Plaintiffs get that principle exactly backwards. \u201cTo reason that Purcell\n\nsomehow constrains a state legislature\u2019s power to set rules would \u2018turn Purcell on its\n\nhead.\u2019\u201d OPAWL-Bldg. AAPI Feminist Leadership v. Yost, 118 F.4th 770, 775, n.1 (6th Cir.\n\n2024) (quoting Democratic Nat\u2019l Comm. v. Wis. State Legislature, 141 S. Ct. 28, 31 (2020)\n\n(Mem.) (Kavanaugh, J., concurring in denial of application to vacate stay)). Purcell \u201ccon-\n\nstrains the equitable powers of the federal courts, not the sovereign powers of state leg-\n\nislatures.\u201d Id. While policymakers might debate the wisdom of a State\u2019s decision \u201cto toy\n\nwith its election laws close to a State\u2019s elections,\u201d it is \u201cquite another thing for a federal\n\ncourt to swoop in and re-do a State\u2019s election laws in the period close to an election.\u201d\n\nMerrill, 142 S. Ct. at 880-81 (Kavanaugh, J., concurring). Purcell precludes the latter, not\n\nthe former, as Plaintiffs\u2019 own cited authority confirms. See, e.g., Tenn. Conf. of the NAACP\n\nv. Lee, 105 F.4th 888, 890 (6th Cir. 2024) (per curiam) (staying court\u2019s injunction, conclud-\n\ning it came too close to election day).\n\n\n\n 22\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 24 of 29 PageID #: 1002\n\f Plaintiffs\u2019 Purcell arguments also confuse the status quo. The 2026 Plan, as well as\n\nthe changes to candidate qualifying requirements, including suspension of the residency\n\nrequirement, are now the status quo. Detailed in the attached declarations, state and local\n\nofficials are already implementing the 2026 Plan. Dodd Decl. \u00b6\u00b613-16, 18. Likewise, al-\n\nready-qualified candidates and new candidates will submit their paperwork by Friday\n\nso that ballots can be prepared as early as Monday. Id. \u00b6\u00b64, 9. And the 2026 Plan has been\n\nlive on the Secretary of State\u2019s website for voters to use the \u201cvoter look-up\u201d function since\n\nlast week. Id. \u00b615. Any court order will derail that status quo and interrupt ongoing elec-\n\ntion preparations mid-stream. Purcell precludes that disruption. See, e.g., Abbott, 146 S. Ct.\n\nat 418 (issuing stay over arguments that earlier enacted districts were the status quo);\n\nMerrill, 142 S. Ct. at 881 (Kavanaugh, J., concurring).\n\nIII. Plaintiffs will not suffer irreparable harm absent an injunction.\n\n Plaintiffs have not established irreparable harm. While they speculate the 2026\n\nPlan will cause downstream election administration issues, voter confusion, or possible\n\ndisenfranchisement, Dkt. 12 at 23-24, that speculation is unfounded and cannot establish\n\nirreparable harm. See Memphis A. Philip Randolph Inst. v. Hargett, 978 F.3d 378, 391 (6th\n\nCir. 2020) (irreparable harm requires \u201cboth certain and immediate\u201d injury, not \u201cspecula-\n\ntive or theoretical\u201d (citation omitted)). For all the reasons already explained, Plaintiffs\n\ncannot substantiate their speculation. Supra I.B.3.a. They cannot conflate the present cir-\n\ncumstances, including the $3.1 million provisioned for state and local officials, with 2022\n\n\n\n 23\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 25 of 29 PageID #: 1003\n\flitigation. Dodd Decl. \u00b6\u00b67-13; Burns Decl. \u00b6\u00b65-7. Primary elections are months away.\n\nTennessee holds one of the latest primary elections in the country, August 6. Early voting\n\ndoesn\u2019t begin until July 17. And while candidates now have additional days to qualify,\n\nqualifying ends promptly to allow ballots to be prepared as soon as May 18. Dodd Decl.\n\n\u00b69. And more than a month remains before the federal deadline for military and overseas\n\ncitizen ballots. See 52 U.S.C. \u00a720302(a)(8); Tenn. Code Ann. \u00a72-6-503(a). All told, the State\n\nhas the time and resources to implement the 2026 Plan; if officials may continue that im-\n\nportant work, Plaintiffs won\u2019t suffer irreparable harm.\n\nIV. The balance of harms and public interest demands denial of Plaintiffs\u2019 re-\n quested relief.\n\n Because Defendants are government officials, the balance-of-equities and public-\n\ninterest factors \u201cmerge.\u201d Wilson v. Williams, 961 F.3d 829, 844 (6th Cir. 2020) (citation omit-\n\nted). It is \u201cin the public interest\u201d to enforce the State\u2019s democratically enacted laws,\n\nThompson v. DeWine, 976 F.3d 610, 619 (6th Cir. 2020), and \u201c[a]ny time\u201d such a law is\n\nenjoined, the State \u201csuffers a form of irreparable injury,\u201d Lichtenstein v. Hargett, 489 F.\n\nSupp. 3d 742, 787 (M.D. Tenn. 2020) (cleaned up).\n\n A. Any balancing of the harms compels the denial of Plaintiffs\u2019 requested relief. If\n\nan injunction is entered, \u201cTennessee will suffer irreparable harm from its inability to en-\n\nforce the will of its legislature.\u201d L.W. v. Skrmetti, 73 F.4th 408, 421 (6th Cir. 2023) (granting\n\nstay pending appeal). That is doubly true in the election context. The \u201cinability\u201d to con-\n\nduct elections under a \u201cduly enacted\u201d redistricting plan \u201cclearly inflicts irreparable\n\n\n 24\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 26 of 29 PageID #: 1004\n\fharm\u201d on the State and the members of the public it represents. Abbott v. Perez, 585 U.S.\n\n579, 602 n.17 (2018). If, after the 2026 election, the Court\u2019s \u201cjudgment is ultimately re-\n\nversed, the State cannot run the election over again, this time applying\u201d its congressional\n\nmap. Veasey v. Perry, 769 F.3d 890, 896 (5th Cir. 2014). \u201c[T]he State has a significant interest\n\nin ensuring the proper and consistent running of its election machinery, and this interest\n\nis severely hampered by [an] injunction.\u201d Id. Unsurprisingly, the Supreme Court regu-\n\nlarly stays injunctions against redistricting plans to preserve the status quo until appellate\n\nreview concludes, Abbott, 146 S. Ct. at 419, even in circumstances where appellate review\n\ncame out in Plaintiffs\u2019 favor, see, e.g., Robinson, 144 S. Ct. at 1171; Merrill, 142 S. Ct. at 879.\n\n B. Finally, the public interest likewise compels the denial of Plaintiffs\u2019 request for\n\nextraordinary relief. Redistricting \u201cis a legislative task\u201d that \u201ccourts should make every\n\neffort not to pre-empt.\u201d Wise v. Lipscomb, 437 U.S. 535, 539-40 (1978) (White, J.) (collecting\n\ncases); accord Wygant v. Lee, ___ S.W.3d ___, 2025 WL 3537313, at *25 (Tenn. Dec. 10, 2025).\n\nThe 2026 Plan and the associated changes to the State\u2019s election laws, all enacted by the\n\nGeneral Assembly, are themselves \u201ca declaration of public interest.\u201d Virginian Ry. Co. v.\n\nSystem Fed\u2019n No. 40, 300 U.S. 515, 552 (1937); see Berman v. Parker, 348 U.S. 26, 32 (1954)\n\n(\u201cwhen the legislature has spoken, the public interest has been declared in terms well-\n\nnigh conclusive\u201d). That legislative action is entitled the presumption of good faith. See,\n\ne.g., Alexander, 602 U.S. at 6, 10-11; cf. Williamson v. Lee Optical of Okla., 348 U.S. 483, 487-\n\n\n\n\n 25\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 27 of 29 PageID #: 1005\n\f88 (1955). That presumption is a factor \u201cto be considered in favor of applicants in balanc-\n\ning hardships.\u201d Walters v. Nat\u2019l Ass\u2019n of Radiation Survivors, 468 U.S. 1323, 1324 (1984)\n\n(Rehnquist, J., in chambers).\n\n CONCLUSION\n\n For all these reasons, the Court should deny Plaintiffs\u2019 motion for a temporary\n\nrestraining order and preliminary injunction.\n\n\n\n\n 26\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 28 of 29 PageID #: 1006\n\fDated: May 13, 2026 Respectfully submitted,\n\n\n JONATHAN SKRMETTI\n Attorney General and Reporter\n\n /s/ Zachary L. Barker\n ZACHARY L. BARKER (BRP #035933)\n Senior Assistant Attorney General\n\n ANDREW DENNING (BPR #042208)\n Assistant Attorney General\n Office of the Tennessee Attorney General\n P.O. Box 20207\n Nashville, Tennessee 37202-0207\n Phone: (615) 532-7400\n Zachary.barker@ag.tn.gov\n Andrew.denning@ag.tn.gov\n (615) 532-4098\n\n TAYLOR A.R. MEEHAN (PHV pending)\n BRYAN K. WEIR (PHV pending)\n OLIVIA C. ROGERS (PHV pending)\n Consovoy McCarthy PLLC\n 1600 Wilson Blvd., Suite 700\n Arlington, VA 22209\n taylor@consovoymccarthy.com\n bryan@consovoymccarthy.com\n orogers@consovoymccarthy.com\n\n Counsel for Defendants\n\n\n\n\nCase 3:26-cv-00603 Document 40 Filed 05/13/26 Page 29 of 29 PageID #: 1007\n\f","ocr_status":1,"date_upload":"2026-05-14T07:55:36.493690-07:00","document_number":"40","attachment_number":null,"pacer_doc_id":"16906405257","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Response in Opposition to Motion","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479194700/","id":479194700,"tags":[],"absolute_url":"/docket/73315644/40/1/hale-v-lee/","date_created":"2026-05-14T07:55:04.400279-07:00","date_modified":"2026-05-18T03:16:56.090938-07:00","sha1":"486397a4f6862c9c57b1abb018b55694ff0084ed","page_count":6,"file_size":1259130,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.40.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.40.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"EXHIBIT\n\nCase 3:26-cv-00603 Document 40-1 Filed 05/13/26 Page 1 of 6 PagelD #: 1008\n\fUNITED STATES DISTRICT COURT\nFOR THE MIDDLE DISTRICT OF TENNESSEE\nNASHVILLE DIVISION\n\nVICKI HALE, EARLE FISHER, TELIZE TURNER, )\nHEDY WEINBERG, STEPHEN COHEN, CHARLES )\n\u2018CHAZ\u2019 MCIVER MOLDER, CHANEY MOSLEY, _)\nJUSTIN PEARSON, and the TENNESSEE\nDEMOCRATIC PARTY,\n\nPlaintiffs,\n\nNo. 3:26-cv-00603\nChief Judge Campbell\n\nVv.\n\nBILL LEE, Governor of Tennessee,\n\nTRE HARGETT, Secretary of State of Tennessee,\nMARK GOINS, Tennessee Coordinator of Elections;\nall in their official capacity only,\n\nNee Ne Ne Ne ee ee ee Ne Ne ee ee ee\u201d\n\nDefendants.\n\nDECLARATION OF ANDREW DODD\n\nSTATE OF TENNESSEE _ )\n)\nCOUNTY OF DAVIDSON _)\n\nI, ANDREW DODD, having first been duly sworn according to law, makes oath upon my\npersonal knowledge as follows:\n\n1. I am over the age of eighteen, and I am competent to testify on the matters set forth herein.\n\na I am an employee of the Division of Elections, Tennessee Department of State, and have\nbeen since 2011. I became an Assistant Coordinator of Elections in July 2023 and continue to serve\nin that role. I am also a licensed attorney and have been licensed in Tennessee since 2011.\n\n3. The State Coordinator of Elections is appointed by and serves at the pleasure of the\nTennessee Secretary of State. The Coordinator of Elections serves as the chief administrative\nelection officer of the State, and his statutory duties are set forth in Tenn. Code Ann. \u00a7 2-11-202.\nAs Assistant Coordinator, I am charged with assisting the Coordinator with these statutory duties,\nwhich include, among other things, the following duties:\n\nCase 3:26-cv-00603 Document 40-1 Filed 05/13/26 Page 2 of 6 PagelD #: 1009\n\fe Advise election commissions, primary boards, and administrators of elections as to\nthe proper methods of performing their duties;\n\ne Authoritatively interpret the election laws for all persons administering them;\n\ne Furnish instructions for election officials as to their duties in the conduct of\nelections and copies of election laws manual and updating materials to the election\ncommissions, primary boards, and administrators; and\n\ne Provide materials for and conduct training programs for persons administering the\nelection laws.\n\n4. On May 7, 2026, the Tennessee General Assembly adopted Public Chapter No. 3 which\nrevised Tennessee\u2019s nine (9) U.S. House congressional districts. The primary election for these\ncongressional districts is August 6, 2026. Since the deadline for candidates to qualify for this\nprimary election has already passed, Public Chapter No. 2 \u201cgrandfathers\u201d in candidates already\nqualified and provides a special qualifying period for additional candidates for U.S. House of\nRepresentatives to qualify. Specifically, Public Chapter No. 2 provides that already qualified\ncandidates have three options:\n\ne Runin the district that has the same district number that appeared on the candidate\u2019s\noriginal nominating petition;\n\ne Run inanew district that has a different district number than what appeared on the\nnominating petition by filing a notarized statement with the Coordinator of\nElections by noon on May 15; or\n\ne Withdraw by filing a notarized statement with the Coordinator of Elections by noon\non May 15.\n\nAny existing qualified candidate who takes no action will automatically remain qualified in the\ndistrict listed on their original nominating petition.\n\nS For additional candidates who desire to qualify, Public Chapter No. 2 provides a special\nqualifying period that began as of the effective date of the Act through noon on May 15. A person\ncan qualify as a candidate for a congressional district by filing a nominating petition with the\nsignatures of twenty-five voters registered in a county that is wholly or partially within that district\nwithin the special qualifying period.\n\n6. The political parties retain their ability to remove candidates who do not meet the bona fide\nrequirements under their rules; however, any determination that a newly qualified candidate should\nbe removed from the ballot must be filed with the Coordinator of Elections by noon on May 17.\nCandidates who are disqualified by a political party may not appeal the party\u2019s decision.\n\no The Division of Elections acknowledges that the revised congressional districts and special\nqualifying period will make it more difficult for our staff and for the county election commissions\nto meet deadlines and prepare for the August 6 election. The State has appropriated significant\nfunds to meet those deadlines.\n\n8. While this not the first time the Division has opined on meeting election deadlines, there\nare several significant factual differences between the present circumstances and possible election\n\nCase 3:26-cv-00603 Document 40-1 Filed 05/13/26 Page 3 of 6 PagelD #: 1010\n\fdeadlines that were the subject of 2022 litigation regarding the Tennessee State Senate redistricting\nplan.\n\n9. First, the Act provides a May 15 qualifying deadline and no deadline for a candidate to\nwithdraw thereafter; a May 17 noon deadline for parties to disqualify a candidate, and no appeal\nprocess\u2014meaning that counties could potentially begin preparing their ballots and Division review\ncould begin as soon as May 18. That is earlier than the timeline contemplated in the 2022 litigation.\n\n10. Second, the ballot for the August 2026 election is not nearly as large as the ballot was for\nthe August 2022 election. The 2022 ballot included all five Supreme Court Judges (retention\nquestion); eleven Court of Appeals judges (retention question); ten Court of Criminal Appeal\njudges (retention question); all trial court judges, which may have involved contested races (circuit,\nchancery, criminal and probate); all District Attorneys General, which may have involved\ncontested races, and all Public Defenders, which may have involved contested races. As most of\nthese offices all have eight (8) year terms, they are not on the August 2026 ballot unless there is a\nvacancy.\n\n11. Third, the plan at issue today is different than the plan that was at issue in 2022. In 2022,\nthe challenged State Senate Plan redistricted ninety-five (95) counties into thirty-three (33)\nSenatorial districts. The 2026 congressional plan redistricts the counties into nine (9) U.S. House\ncongressional districts. And while the plan redistricts all ninety-five counties, under the new\nredistricting map, boundaries in fifty-three (53) counties remain unchanged, and in thirty-two (32)\ncounties wholly in one district, the only change is a change in district numbers. In one (1) county\n(Campbell County), the boundary did not change, but voters who were previously in the 3\ncongressional district are now in the 6\" congressional district. In total, forty-three (43) counties\nare required to make updates to make changes to boundaries and/or district numbers.\n\n12. Additionally, the General Assembly is currently not in session, so there are no additional\nlaws anticipated concerning election administration. While we are also assisting counties with the\nregistration of individuals with a previous felony conviction, the Tennessee General Assembly\nenacted legislation in 2025 that significantly changed the process for a person with a felony\nconviction to have his or her voting rights restored. That process that relies heavily on a judicial\nprocess has reduced the time our office and the county election commissions must spend in\ndetermining whether a person with a previous felony conviction is eligible to register to vote.\n\n13. Finally, perhaps the most significant difference between 2022 and the present situation is\nthat when the General Assembly enacted Public Chapter No. 4, it appropriated significant funds\n($3,154,700.00) to assist county election officials in meeting deadlines and performing their duties\nfor the August election. This funding will allow election officials to:\n\ne Pay for overtime and/or hire additional staff\n\ne Pay vendors for services performed on an expedited basis\n\ne Pay for mailing notices to voters, if any\n\ne Pay for miscellaneous items such as additional training, signage, voter\neducation, etc.\n\nCase 3:26-cv-00603 Document 40-1 Filed 05/13/26 Page 4 of 6 PagelID #: 1011\n\fNone of this funding was available in 2022, meaning that the counties would have had to fund all\nthese items, which may have put the county in a position of needing to spend money that was not\nappropriated or running the risk of incomplete or inaccurate work.\n\n14. The Division of Elections is committed to performing its statutory duties in preparing for\nthe August election and assisting the county election commissions to appropriately prepare for that\nelection. The performance of those duties has already begun. The Division of Elections has\nalready sent a memo to the counties asking them to begin planning for the changes. Also, upon\npassage of the Act, the Division immediately sent a memo to the county election commissions\noutlining the steps they should take to implement the revised congressional districts. The Division\nalso prepared and sent candidate qualifying information to the county election commissions. A\ncopy of this memo is attached.\n\n15. The Division also worked with the GIS staff in the Division of Property Assessments in\nthe Comptroller\u2019s office. The GIS staff has mapping software that allows a voter to look up their\naddress and determine which district they are in. The Division of Elections worked with GIS staff\nto ensure that it published the redistricted map on its website and that the \u201cvoter look-up\u201d function\nis available. The map and a link to the \u201cvoter-look-up\u201d function was also published on the\nDivision\u2019s website on the same day the law was enacted.\n\n16. The Division sent letters by overnight delivery on Thursday, May 7, via Federal Express\nto all fifty-three (53) candidates who had previously qualified, advising them of the revised\ncongressional districts and their options. A copy of this letter is attached. Fifty-two (52) out of\nfifty-three (53) letters were delivered by Friday, May 8. The remaining letter (to Congressman\nScott DesJarlais) was delivered Monday, May 11. Division staff also personally called all\ncandidates to ensure that they were fully informed.\n\n17. Division of Elections staff reviewed the residential address provided on each qualified\ncandidate\u2019s nominating petition. Thirty-seven (37) out of fifty-three (53) candidates reside in the\nsame district in which they originally qualified. Sixteen (16) candidates listed below now reside\nin a different district. Two (2) candidates, Joyce E. Neal and Wendell \u201cWells\u201d Blankenship, have\nfiled notarized statements to run in their new districts instead of the districts in which they\noriginally qualified as of Tuesday, May 12.\n\nOriginal District | Candidate Party Revised District\n4th Victoria Broderick Democratic 9th\n5th Charlie Hatcher Republican 9th\n5th Mike Cortese Democratic 4th\n5th Chaz Molder Democratic 9th\n5th Joyce E. Neal Democratic 4th\n5th Lowell Andre Reynolds Independent 7th\n6th Natisha Brooks Republican 7th\n6th Lore Bergman Democratic 7th\n6th Andrew J. Koontz Independent 7th\n8th Leonard Perkins Democratic 5th\n\nCase 3:26-cv-00603\n\nDocument 40-1\n\nFiled 05/13/26\n\nPage 5 of 6 PagelD #: 1012\n\n\fOriginal District | Candidate Party Revised District\n8th Pamela Jeanine \"P.\" Moses Independent 5th\n9th Steve Cohen Democratic 5th\n9th DeVante R. Hill Democratic 8th\n9th Justin J. Pearson Democratic 5th\n9th Wendell \"Wells\" Blankenship | Independent 8th\n9th Dennis Clark Independent 8th\n\n18. | When Public Chapter No. 3 was signed on Thursday, May 7, county election commissions\nbegan taking the necessary steps required under the public chapter:\n\ne By early Thursday evening, GIS staff from the Comptroller\u2019s Division of Property\nAssessments had provided lists to eleven (11) of twelve (12) counties split by congressional\ndistrict boundaries totaling 831,241 affected addresses based on address points contained\nin 911 data on file with the office. (No data was needed for Jefferson County since its\nboundaries and district numbers did not change.)\n\ne Counties have begun to incur costs related to redistricting. For example, Shelby County\nhas reported their IT staff worked overtime over the Mother\u2019s Day holiday weekend.\n\ne County election commissions have reported 540,711 updates to voter records across thirty-\none (31) of the forty-three (43) counties required to make updates by the end of the day on\nTuesday, May 12. Fifty-two (52) counties have no updates to make under this plan.\n\n19. During the special qualifying period, I am aware of thirty (30) petitions that have been\nissued by the Division of Elections and county election commissions to candidates who had not\npreviously qualified. Four (4) petitions have been filed by these candidates with the Coordinator\nof Elections as of the close of business on May 12. Candidates have until noon on Friday, May 15,\nto file.\n\nPursuant to 28 U.S.C. \u00a7 1746, I declare under the penalty of perjury under the laws of the\nUnited States of America that the foregoing is true and correct.\n\nQO FESS\n\nANDREW DO\n\n05 [\u00ab3// Zoee\n\nDate\n\nCase 3:26-cv-00603 Document 40-1 Filed 05/13/26 Page 6 of 6 PagelD #: 1013\n","ocr_status":1,"date_upload":"2026-05-14T08:03:16.977440-07:00","document_number":"40","attachment_number":1,"pacer_doc_id":"16906405258","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit Exhibit 1 - Declaration of Andrew Dodd","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479194701/","id":479194701,"tags":[],"absolute_url":"/docket/73315644/40/2/hale-v-lee/","date_created":"2026-05-14T07:55:04.472146-07:00","date_modified":"2026-05-14T07:55:04.472166-07:00","sha1":"","page_count":3,"file_size":462850,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"40","attachment_number":2,"pacer_doc_id":"16906405259","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Exhibit Exhibit 2 - Tennessean Article","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/479194702/","id":479194702,"tags":[],"absolute_url":"/docket/73315644/40/3/hale-v-lee/","date_created":"2026-05-14T07:55:04.497881-07:00","date_modified":"2026-05-18T03:15:47.159434-07:00","sha1":"c87d1ca63003b073824290cafb50271d8786741a","page_count":10,"file_size":8246362,"filepath_local":"recap/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.40.3.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.tnmd.109142/gov.uscourts.tnmd.109142.40.3.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"EXHIBIT\n\nCase 3:26-cv-00603 Document 40-3 Filed 05/13/26 Page 1 of 10 PagelD #: 1017\n\fUNITED STATES DISTRICT COURT\nFOR THE MIDDLE DISTRICT OF TENNESSEE\nNASHVILLE DIVISION\n\nVICKI HALE, EARLE FISHER, TELIZE TURNER,\nHEDY WEINBERG, STEPHEN COHEN, CHARLES\n\u2018CHAZ\u2019 MCIVER MOLDER, CHANEY MOSLEY,\nJUSTIN PEARSON, and the TENNESSEE\nDEMOCRATIC PARTY,\n\nPlaintiffs,\n\nNo. 3:26-cv-00603\nChief Judge Campbell\n\nVv.\n\nBILL LEE, Governor of Tennessee,\n\nTRE HARGETT, Secretary of State of Fennessee,\nMARK GOINS, Tennessee Coordinator of Elections;\nall in their official capacity only,\n\nDefendants.\n\n)\n)\n)\n)\n)\n)\n)\n)\n)\n)\n)\n)\n)\n)\n)\n)\n\nDECLARATION OF WILL BURNS\n\nI, WILL BURNS, declare the following:\n\ni. I am over the age of eighteen, and I am competent to testify on the matters set forth herein.\n\na Tam the Chairman of the Davidson County Election Commission (\u201cDCEC\u201d). I previously\nserved as the Coordinator of Elections for the State of Tennessee, and in that role, I oversaw the\nadministration of Tennessee elections and worked with county election commissions statewide.\n\n5. The DCEC will be able to create all the versions of the ballot needed for the August\nelection. Through a collaborative effort between the Davidson County Election Commission, the\nMetro Nashville GIS Team, and the Tennessee Comptroller of the Treasury team, we are working\nthrough the following steps to ensure that all voters in Davidson County are assigned to the correct\nU.S. Congressional district, based on their home address. Those steps are as follows:\n\nStep 1: GIS Data Entry and District Boundary Mapping \u2014 Our team has imported the\n\nnew U.S. Congressional district shapefiles into GIS software and is aligning all precinct\nand voter address layers with the redrawn boundaries.\n\nCase 3:26-cv-00603 Document 40-3 Filed 05/13/26 Page 2 of 10 PagelD #: 1018\n\n\f\f\fStep 2: Veter Registration Database Update \u2014 Our team will next import the updated\nstreet and district file into the PowerProfile voter database and reassign all affected voters\nto their new U.S. Congressional districts.\n\nStep 3: Accuracy Reviews \u2014 Steps | and 2 will be repeated until 100% of all registered\nvoters in Davidson County are assigned to the correct U.S. Congressional district.\n\n4. Split precincts existed under the previous U.S. Congressional district map, and Under the\nnew U.S. Congressional district map, there are 347 split precincts. Ballots will be created based\non the number of split precincts in Davidson County. Of those split precincts, 44 are new split\nprecincts resulting from the 2026 congressional redistricting. The DCEC will be able to handle\nthis number of new split precincts.\n\n5. The DCEC will be able to timely notify voters of their precinct changes. All registered\nvoters in Davidson County affected by the redistricting will receive a new voter registration card.\nThe vendor who will print and mail these cards has been scheduled to complete the job no later\nthan the first week of July.\n\n6. The DCEC will be able to update its website with the information about new congressional\ndistricts. The Davidson County Election Commission website (nashville.gov/vote) has links to the\nSecretary of State\u2019s website (https://sos.tn.gov/announcements/2026-congressional-redistricting)\nwith information about the redistricting. The link to this information is titled \u201c2026 Congressional\nRedistricting Information\u201d and appears at three locations on the DCEC website. These can be\nfound as follows: From the DCEC homepage click on the \u201cFind 2026 Election Information\u201d tab. A\nlink to \u201c2026 Congressional Redistricting Information\u201d can be found in two locations\u2014at the top\nof the new page as well as under the heading \u201cAugust 6, 2026: State & Federal Primary, County\nGeneral, Oak Hill Municipal Election\u201d found on that same page. The third location is found by\nclicking on the \u201cNavigation\u201d tab, from there click on \u201cCandidates,\u201d and the redistricting link is at\nthe top of the \u201cCandidates for Elected Office Information\u201d page.\n\n7. The funds appropriated by the Tennessee General Assembly have provided the DCEC with\nfinancial flexibility to create a special redistricting team with DCEC employees and focus their\nwork on the completion of this project, including any necessary overtime work. The appropriated\nfunds have also been used to temporarily replace some members of the special redistricting team\nwith seasonal employees to keep our election planning activities on schedule. With this financial\nsupport, we are confident we will be able to fully complete this project before our deadline of\n12:00 PM on Friday, June 19, 2026.\n\n8. During every step of implementing the new U.S. Congressional Districts, the DCEC will\nundertake multiple checks to ensure proper voter assignment and issuance of ballots. The DCEC\nhad already formed a plan to ensure accurate voter assignments for the upcoming redistricting after\nthe 2030 census. The DCEC has moved forward with implementing that plan in 2026.\n\nCase 3:26-cv-00603 Document 40-3 Filed 05/13/26 Page 5 of 10 PagelD #: 1021\n\n\f\f\f9. The DCEC wili be able to send out military and overseas ballots in a timely manner. 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