Texas Democratic Party et al. v. Greg Abbott et al.

Defendant Jacquelyn Callanen’s Motion to Dismiss

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UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION

TEXAS DEMOCRATIC PARTY;

GILBERTO HINOJOSA, Chair of the 

Texas Democratic Party; JOSEPH 

DANIEL CASCINO; SHANDA MARIE 

SHANSING; and BRENDA LI GARCIA,

Plaintiffs,

and 

LEAGUE OF UNITED LATIN 

AMERICAN CITIZENS (LULAC), and 

TEXAS LEAGUE OF UNITED LATIN 

AMERICAN CITIZENS, 

Plaintiff-Intervenors, 

v. 

GREG ABBOTT, Governor of Texas; 

KEN PAXTON, Texas Attorney General; 

RUTH HUGHS, Texas Secretary of State; 

DANA DEBEAUVOIR, Travis County 

Clerk; and JACQUELYN F. CALLANEN, 

Bexar County Elections Administrator,

Defendants.

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5:20-cv-00438-FB

DEFENDANT BEXAR COUNTY ELECTIONS ADMINISTRATOR

JACQUELYN CALLANEN’S MOTION TO DISMISS

PLAINTIFFS’ SECOND AMENDED COMPLAINT AND 

PLAINTIFF-INTERVENORS’ AMENDED COMPLAINT

TO THE HONORABLE UNITED STATES DISTRICT JUDGE: 

Now comes Defendant Bexar County Elections Administrator Jacquelyn Callanen, and 

files this Motion to Dismiss pursuant to Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil 

Procedure. 

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BACKGROUND

1. Plaintiffs initiated this litigation in May 2020, this Court held a hearing and entered a 

preliminary injunction later that month, and interlocutory appellate proceedings ensued. Docket 

nos. 1, 90. Shortly after this Court’s entry of the preliminary injunction, the Texas Supreme Court 

decided a state law challenge to Texas’ eligibility restrictions on early voting by mail. In re State, 

602 S.W.3d 549 (Tex. 2020). The Fifth Circuit Court of Appeals stayed the preliminary injunction 

in June, Texas Democratic Party v. Abbott, 961 F.3d 389 (5th Cir. 2020) (Texas Democratic Party 

I), and entered an opinion vacating the preliminary injunction in October, Texas Democratic Party 

v. Abbott, 978 F.3d 168 (5th Cir. 2020), cert. denied, 141 S. Ct. 1124 (2021) (Texas Democratic 

Party II). In March 2021, after the conclusion of interlocutory appellate proceedings, this Court 

ordered Plaintiffs to file an amended complaint and indicated that this amended pleading would 

moot the Motion to Dismiss that Defendant Callanen had previously filed without prejudice to 

reurging in response to Plaintiffs’ amended complaint. Docket no. 136. 

2. Plaintiffs and Plaintiff-Intervenors challenge limitations imposed by state law on the 

eligibility of voters to early vote by mail, contending that these limitations impair voting access 

for racial and language minorities. Plaintiffs and Plaintiff-Intervenors also make related complaints

about various voting-related actions taken by state elected officials during the COVID-19 

pandemic. Plaintiffs allege that state law restrictions on eligibility to vote by mail, various 

proposals currently under consideration in the Texas Legislature, and state law that they contend 

permits poll watchers to intimidate voters and county election workers and volunteers are “part 

and parcel of recent state efforts to unconstitutionally burden voting by racial minorities.” Docket 

no. 141 at ¶¶ 22-29. Plaintiffs also complain of “[v]arious policy and administrative decisions . . . 

made by state officers” in the last decade. Docket no. 141 at ¶¶ 30-37. Plaintiffs complain that 

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“state leadership, including Defendant Secretary of State, was well aware [of] the racially 

discriminatory impacts of restricting vote by mail to older citizens and steadfastly refused to extend 

voting by mail to all eligible voters regardless of age.” Docket no. 141 at ¶ 8. Plaintiffs also 

specifically complain of the manner in which state officials administered voting procedures since 

the onset of the COVID-19 pandemic, noting that the Secretary of State did not require the wearing 

of masks in polling locations, prohibited populous counties from implementing practices to 

“facilitate voting during a pandemic” and restricted the locations at which county officials could 

place “ballot drop locations[.]” Docket no. 141 at ¶¶ 37-47. Plaintiffs also complain that, after the 

November 2020 election, Texas state officials undertook a challenge to the nationwide results of 

the presidential election contest, and complain of various election-related bills pending before the 

state legislature. Docket no. 141 at ¶¶ 48-63. 

3. Plaintiffs assert six claims. First, they allege that the age restriction placed on eligibility to 

vote early by mail by Texas Election Code § 82.003 violates the prohibition against race and 

language minority discrimination in Section 2 of the Voting Rights Act, 52 U.S.C. § 10301, 

because nonwhite voters “are disproportionately younger than the aging non-Hispanic white 

voters[.]” Docket no. 141 at ¶¶ 7, 80-82. In their second and third claims, Plaintiffs allege that this 

same age limitation on eligibility to early vote by mail, also violates the Fourteenth and Fifteenth 

Amendments of the United States Constitution. Docket no. 141 at ¶¶ 83-86. In their fourth claim, 

Plaintiffs allege that the state law age limitation on eligibility to early vote by mail, as well as the 

voting conditions created by the COVID-19 pandemic, violate voters’ equal protection rights under 

the Fourteenth Amendment under the Anderson/Burdick standard by imposing “severe burdens” 

on voters in terms of time, inconvenience, and expense, and facially discriminating between 

different classes of voters. Docket no. 141 at ¶¶ 87-90. Finally, in their fifth and sixth claims, 

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Plaintiffs allege that the state law age limitation on eligibility to early vote by mail violates the 

First and Twenty-Sixth Amendments by abridging the free speech rights of voters who are not 

eligible to early vote by mail. Docket no. 141 at ¶¶ 93-104. Plaintiffs seek declaratory and 

injunctive relief, and an award of attorney’s fees pursuant to 42 U.S.C. § 1988 and 52 U.S.C. §§ 

10310(e). Docket no. 141 at ¶¶ 106-09. Plaintiffs also request that the Court retain jurisdiction and 

require Texas to obtain preclearance with respect to its voting practices and procedures under 

Section 3(c) of the Voting Rights Act, 52 U.S.C. § 10302(c). 

4. Similarly, Plaintiff-Intervenors contend that Texas Election Code § 82.003 violates the 

First, Fourteenth, and Twenty-Sixth Amendments and Section 2 of the Voting Rights Act by 

allowing all eligible voters over age 65 to early vote by mail while restricting early voting by mail 

for younger voters. Docket no. 142 at ¶¶ 1, 11. Like Plaintiffs, Plaintiff-Intervenors also complain 

of various statements and actions of state officials, such as various election-related bills under 

consideration in the Texas Legislature, Governor Abbott’s designation of “election integrity” as 

an emergency item for the 2021 legislative session, the Secretary of State’s decision not to require 

individuals to wear masks at polling places, and the Governor’s proclamation imposing limits on 

ballot drop-off locations. Docket no. 142 ¶¶ 13, 33-35. 

5. Plaintiff-Intervenors assert four claims. First, they assert a facial challenge to Texas 

Election Code § 82.003, alleging that “[e]ven absent pandemic conditions,” its age limitation on 

eligibility to early vote by mail constitutes racial and language minority discrimination in violation 

of Section 2 of the Voting Rights Act, 52 U.S.C. § 10301. Docket no. 142 at ¶¶ 45-50. PlaintiffIntervenors also assert an Anderson/Burdick claim that the age-based limitation imposed by Texas 

Election Code § 82.003 violates their First and Fourteenth Amendment rights. Docket no. 142 at 

¶¶ 51-59. Finally, Plaintiff-Intervenors, like Plaintiffs, allege that Texas Election Code § 82.003 

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violates the Twenty-Sixth Amendment by abridging their right to vote on the basis of age. Docket 

no. 142 at ¶¶ 60-62. Plaintiff-Intervenors seek declaratory and injunctive relief and an award of 

attorneys’ fees and costs. Docket no. 142 at 18. 

6. Defendant Bexar County Elections Administrator Jacquelyn Callanen respectfully reurges 

her Motion to Dismiss. Plaintiffs’ and Plaintiff-Intervenors’ claims arise entirely from the acts and 

omissions of state officials, and assert constitutional and VRA challenges to provisions of state 

law over which the County defendants have no control. To the extent Plaintiffs might show a 

constitutional or VRA violation flowing from any restriction imposed by the Texas Election Code 

on eligibility to early vote by mail, Defendant Callanen—who performs her duties in accordance 

with state law and the guidance provided by the state’s chief elections officer—did not cause and 

cannot remedy that violation. Plaintiffs and Plaintiff-Intervenors therefore cannot establish their 

Article III standing as to their claims against Defendant Callanen, and this Court lacks subject 

matter jurisdiction over those claims, which should be dismissed pursuant to Federal Rule of Civil 

Procedure 12(b)(1). 

7. Plaintiffs and Plaintiff-Intervenors do not plead facts showing that Defendant Callanen 

violated their rights. Indeed, their pleadings make no mention of Defendant Callanen other than to 

identify her as a party. Because they do not plead facts sufficient to state any claim against 

Defendant Callanen upon which relief could be granted, she should be dismissed from this 

litigation pursuant to Federal Rule of Civil Procedure 12(b)(6). 

LEGAL STANDARDS 

8. Rule 12(b)(1) of the Federal Rules of Civil Procedure authorizes the dismissal of claims 

over which the Court lacks subject matter jurisdiction. Plaintiffs, as the party asserting jurisdiction, 

bear the burden of showing subject matter jurisdiction. Choice Inc. of Texas v. Greenstein, 691 

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F.3d 710, 714 (5th Cir. 2012). To satisfy the standing component of subject matter jurisdiction, 

Plaintiffs must show that they have suffered an (1) injury in fact—“‘an invasion of a legally 

protected interest’ that is ‘concrete and particularized’ and ‘actual or imminent, not conjectural or 

hypothetical’”—(2) that this injury is fairly traceable to the challenged conduct of the Defendant 

and (3) that it is likely to be redressed by a favorable judicial decision. Ctr. for Biological Diversity 

v. United States Envtl. Prot. Agency, 937 F.3d 533, 537 (5th Cir. 2019) (quoting Gill v. Whitford, 

138 S. Ct. 1916, 1928 (2018) and Spokeo, Inc. v. Robins, 136 S. Ct. 1540, 1547 (2016), as revised 

(May 24, 2016)). In evaluating the existence of subject matter jurisdiction, the Court may consider 

the complaint alone, the complaint supplemented by undisputed facts, or the complaint 

supplemented by undisputed facts plus the court’s resolution of disputed facts. Robinson v. TCI/US 

W. Commc’ns Inc., 117 F.3d 900, 904 (5th Cir. 1997). 

9. The sufficiency of a pleading to state a claim upon which relief can be granted under 

Federal Rule of Civil Procedure 12(b)(6) is evaluated under the two-step process outlined by the 

Supreme Court in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), and Ashcroft v. Iqbal, 556

U.S. 662 (2009). First, the Court must identify the Complaint’s factual allegations, which are 

assumed to be true, and distinguish them from any statements of legal conclusion, which are not 

entitled to the assumption of truth. Iqbal, 556 U.S. at 678, 680-81. Second, the Court must assess 

whether the assumed-as-true factual allegations set forth a plausible claim to relief. This is “a 

context-specific task that requires the reviewing court to draw on its judicial experience and 

common sense” to determine whether “the well-pleaded facts . . . permit the court to infer more 

than the mere possibility of misconduct[.]” Iqbal, 556 U.S. at 679. Ultimately, the claim is subject 

to dismissal if it lacks “factual content that allows the court to draw the reasonable inference that 

the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678.

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ANALYSIS

10. Aside from being named in the caption and identified as parties, neither Defendant 

Callanen, Defendant Debeauvoir, nor their offices are mentioned at any other point in Plaintiffs’ 

or Plaintiff-Intervenors’ pleadings. Docket no. 141 at ¶¶ 78-79; 142 at ¶¶ 21, 22, 27. Plaintiffs do 

not identify any act or decision of any local official that they contend violated their rights or caused 

them any injury. None of the injuries they allege could be redressed by local elections officials, 

who administer early voting by mail in accordance with state law and the directives of the state’s 

chief elections officer, the Secretary of State. 

11. Because Plaintiffs do not allege injuries that are fairly traceable to any conduct of 

Defendant Callanen, and because she could not redress any injury they have alleged, Plaintiffs and 

Plaintiff-Intervenors lack standing to assert their claims against her. And since Plaintiffs have not 

alleged that Defendant Callanen violated their rights in any way—their complaints’ only mention 

of her is to identify her as a party—they have not stated any viable claim against her, and she 

should be dismissed from this litigation pursuant to Federal Rule of Civil Procedure 12(b)(6). 

12. In their filings to date in this case, the Governor, Attorney General, and Secretary of State 

(the State Defendants) have represented that they “do not enforce Texas Election Code Section 

82.002 or 82.003” and therefore “lack[] the requisite connection to the enforcement of” Section 

82.002 that is required to invoke the Ex Parte Young exception to sovereign immunity as to 

Plaintiffs’ claims against them. Docket no. 39 at 19-23. Instead, they argue, “the counties and 

political subdivisions, not State officials, are responsible for administering early voting in Texas.” 

Docket no. 107 at 10. Additionally, they contend that Plaintiffs lack standing to assert claims 

against them, in part because “[a]cceptance or rejection of an application to vote by mail falls to 

local, rather than State, officials” and Plaintiffs’ alleged injuries therefore “are not ‘fairly 

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traceable’” to the State Defendants, but are “‘the result of the independent action of [a] third 

party’”—i.e., local elections officials such as Defendant Callanen. Docket nos. 39 at 23-24 

(quoting Lujan v. Defs. of Wildlife, 504 U.S. 555, 560 (1992)); 107 at 13 (arguing that Plaintiffs 

lack standing to sue the Secretary of State because “acceptance or rejection of an application to 

vote by mail falls to local, rather than State, officials.”). In making these arguments, the State 

Defendants argue by implication that the proper defendants against whom Plaintiffs may proceed 

are local elections officials such as Defendant Callanen. The State Defendants’ position—

particularly as to the Secretary of State—is contrary to controlling appellate authority, including 

at least two published Fifth Circuit opinions entered in this litigation; unsupported by state law; 

and undermined by Attorney General Paxton’s own previous opinions regarding the 

responsibilities of the Secretary of State under the Election Code. 

13. The State Defendants’ position, that invasions of federally secured rights caused by 

applications of the Texas Election Code are not traceable to or redressable by the State, has been 

rejected by the Fifth Circuit as a “circular argument” that “misses the mark” because “[t]he facial 

invalidity of a Texas election statute is, without question, fairly traceable to and redressable by the 

State itself and its Secretary of State, who serves as the ‘chief election officer of the state.’” OCAGreater Houston v. Texas, 867 F.3d 604, 613 & n.34 (5th Cir. 2017) (quoting Tex. Elec. Code § 

31.003). With respect to both sovereign immunity and standing, the state’s chief elections officer, 

the Secretary of State, is empowered by state law to “obtain and maintain uniformity in the 

application, operation, and interpretation of [the Elections] code and of the election laws[,]” and 

to “prepare detailed and comprehensive written directives and instructions relating to and based 

on this code and the election laws” to guide elections administrators, county clerks, and other local 

officials tasked with administering elections. OCA, 867 F.3d at 613 & n.34 (citing Tex. Elec. Code 

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§ 31.003). Recognizing this same state law authority, Attorney General Paxton has previously 

observed in a formal opinion that “[t]he Texas Secretary of State is the entity tasked with 

administering and applying section 82.002.” Tex. Attn’y Gen. Op. No. KP-009 (2015). The Fifth 

Circuit has twice reached the same conclusion in this case. In June of last year, in the course of 

determining whether to enter a stay of this Court’s preliminary injunction order, the Fifth Circuit 

considered and rejected the Secretary of State’s argument that she could likely show that Plaintiffs 

lacked standing to assert claims against her and that they could not overcome her sovereign

immunity in order to do so. Texas Democratic Party I, 961 F.3d at 399-402 (“Our precedent . . . 

poses a significant obstacle” to the State Defendants’ arguments). The stay panel noted that, 

although “Texas’s vote-by-mail statutes are administered, at least in in the first instance, by local 

election officials[,]” those local officials perform their duties subject to the “detailed and 

comprehensive written directives and instructions relating to” the rules set out in state law. By 

statute, it is the Secretary of State who is responsible for issuing these “detailed and comprehensive 

written directives and instructions”—and she has the power to enforce them by “issu[ing] orders 

and, if necessary, seek[ing] a temporary restraining order, injunction, or writ of mandamus.” Texas 

Democratic Party I, 961 F.3d at 399 & n.19 (citing Tex. Elec. Code § 31.005). During the 

pendency of this litigation, the State of Texas exercised that authority. Relying on Texas Election 

Code § 31.005, and acting through the Attorney General, the State sued Harris County Clerk Chris 

Hollins, seeking preliminary and permanent injunctive relief to require him to administer early 

voting by mail in accordance with the State’s interpretation of the Texas Election Code’s limits on 

voter eligibility. State v. Hollins, No. 20-0729, 2020 WL 5919729, at *1 (Tex. Oct. 7, 2020) (noting 

that the Election Code “reflect[s] the Legislature’s intent that election laws operate uniformly 

throughout the State, under the direction and guidance of the Secretary of State.”); see also 

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Richardson v. Texas Sec’y of State, No. SA-19-CV-00963-OLG, 2020 WL 6279199, at *1 n.1 

(W.D. Tex. Sept. 10, 2020) (summarizing the Hollins litigation and other recent state elections 

enforcement actions against local officials). 

14. Upon reaching the merits, another panel of the Fifth Circuit arrived at the same conclusion 

as the stay panel.1 The merits panel found that “[t]he statutory duties that matter today are the ones 

for the Secretary regarding applications for absentee ballots” and that, by virtue of her authority to 

prescribe the forms that local officials must use in almost all cases, “the Secretary has the authority 

to compel or constrain local officials” to abide by her determination regarding eligibility to early 

vote by mail. Texas Democratic Party II, 978 F.3d at 179-80. For that reason, the merits panel 

found, the Secretary of State is not entitled to sovereign immunity, and Plaintiffs have standing to 

proceed against her because she “ha[s] a role in causing the claimed injury and is in a position to 

redress it at least in part.” Texas Democratic Party II, 978 F.3d at 179. 

CONCLUSION

15. The State Defendants claim that they are powerless to enforce their interpretations of the 

Election Code, and that Plaintiffs therefore must proceed only against local elections officials. On 

two occasions in this case, the Court of Appeals has rejected that argument, finding instead that 

 

1

 In another recent opinion, the Fifth Circuit found that the Ex Parte Young exception did 

not overcome the Secretary of State’s sovereign immunity against a challenge to legislation now 

codified at Texas Election Code § 85.064, which relates to the hours of operation of temporary

branch polling places—a function in which the Court found the Secretary of State “plays no role.” 

Texas Democratic Party v. Hughs, No. 20-50683, 2021 WL 1826760, at *2 (5th Cir. May 7, 2021). 

This finding construed the relative authority of state and local officials with respect to the duties 

set out in a chapter of the Election Code not at issue in this case, and “[d]etermining whether Ex 

parte Young applies to a state official requires a provision-by-provision analysis[.]” Texas 

Democratic Party II, 978 F.3d at 179. The Hughs case is thus inapposite to this case, in which the 

Fifth Circuit has already decided twice that the Secretary of State is a proper Defendant as to the 

claimed deficiencies of Texas Election Code § 82.003. 

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the State does have the authority to compel local officials to follow its interpretations of the 

Election Code. Plaintiffs mount a challenge to the validity of a provision of the Texas Election 

Code, Section 82.003, a statute enacted by Texas’s Legislature and Governor, and enforced by its 

Secretary of State. Local election officials such as Defendant Callanen are not at liberty to 

disregard these or other provisions of state law. Plaintiffs and Plaintiff-Intervenors also complain

of various past and future actions of state officials, but neither Defendant Callanen nor any other 

local election official is mentioned in their complaints whatsoever, aside from being identified as 

parties. The injury that Plaintiffs allege is traceable to, and redressable by, the State Defendants—

not Defendant Callanen. Plaintiffs therefore lack standing to pursue their claims against her, and 

she should be dismissed from this litigation pursuant to Federal Rule of Civil Procedure 12(b)(1). 

Likewise, neither Plaintiffs nor Plaintiff-Intervenors allege facts that state any viable claim against 

Defendant Callanen, and she should therefore be dismissed from this litigation pursuant to Federal 

Rule of Civil Procedure 12(b)(6). 

WHEREFORE, PREMISES CONSIDERED, Defendant Bexar County Elections 

Administrator Jacquelyn Callanen prays that this Court grant her Motion to Dismiss pursuant to 

Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure, and dismiss her from this 

litigation. 

Respectfully Submitted, 

JOE GONZALES

Bexar County Criminal District Attorney

By: /s/ Robert Green

ROBERT D. GREEN

Bar No. 24087626

Assistant District Attorney, Civil Division

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101 W. Nueva, 7th Floor

San Antonio, Texas 78205

Phone: (210) 335-2146 

Fax: (210) 335-2773 

robert.green@bexar.org

Attorney for Defendant Bexar County Elections 

Administrator Jacquelyn Callanen

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CERTIFICATE OF SERVICE

I do hereby certify on the 14th day of May, 2021, I electronically filed the foregoing 

document with the Clerk of Court using the CM/ECF system, which provided electronic service 

upon all parties.

 /s/ Robert Green

ROBERT D. GREEN

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