The U.S. Court of Appeals for the Fourth Circuit issued a published opinion remanding a case between the Public Interest Legal Foundation and South Carolina's Election Commission back to the district court for further proceedings. The decision, filed January 16, 2026, centers on disputes over voter registration practices under the National Voter Registration Act of 1993.
In *Public Interest Legal Foundation, Inc. v. Jenny Wooten* (4th Cir. 2026), the appeals court reviewed a case originally filed in the U.S. District Court for the District of South Carolina at Columbia. The lawsuit names Jenny Wooten in her official capacity as Interim Executive Director of the South Carolina Election Commission as the defendant.
The Public Interest Legal Foundation, a conservative legal organization focused on election integrity issues, brought the original lawsuit against the state election commission. The case involves alleged violations of the National Voter Registration Act, commonly known as the "Motor Voter" law, which Congress enacted in 1993 to expand voter registration opportunities while maintaining accurate voter rolls.
Judge Berner wrote the majority opinion for the three-judge panel, with Chief Judge Diaz and Judge Wynn joining. The court heard oral arguments on October 23, 2025, before issuing its decision nearly three months later. The published nature of the opinion indicates the court views the case as establishing important legal precedent for future election law disputes.
The case attracted significant attention from election law advocacy groups. The Center for Election Confidence, Inc. and the Republican National Committee filed amicus briefs supporting the Public Interest Legal Foundation's position. The involvement of the Republican National Committee signals the broader political implications of voter registration and election integrity disputes.
Senior District Judge Joseph F. Anderson, Jr. presided over the original case in the district court. The case number 3:24-cv-01276-JFA indicates the lawsuit was filed in 2024, making it a relatively recent addition to ongoing litigation over election administration practices.
The legal teams representing both sides include experienced election law practitioners. Tracey Colton Green of Burr & Forman LLP argued for the South Carolina Election Commission, supported by additional counsel including Mary Elizabeth Crum, Michael R. Burchstead, and Thomas W. Nicholson from the State Election Commission. The Public Interest Legal Foundation was represented by Carolyn Carter Valdes, with additional counsel including J. Christian Adams and Noel H. Johnson.
Amicus counsel included Christopher Mills of Spero Law LLC representing the Center for Election Confidence, and Lee E. Goodman, Michael A. Columbo, and Josiah Contarino of Dhillon Law Group representing the Republican National Committee.
The National Voter Registration Act requires states to maintain accurate voter registration lists while providing expanded opportunities for eligible citizens to register. The law includes provisions for removing deceased voters and those who have moved, but also contains specific procedures states must follow when conducting list maintenance activities.
Disputes under the NVRA often center on whether states are properly maintaining their voter rolls or improperly removing eligible voters. Conservative groups like the Public Interest Legal Foundation frequently argue that states are not doing enough to remove ineligible voters, while civil rights organizations typically argue that aggressive list maintenance efforts disenfranchise legitimate voters.
The Fourth Circuit's decision to remand rather than rule definitively on the merits suggests the appeals court found procedural or factual issues that require further development in the district court. Remands typically occur when the appeals court determines that the lower court needs to consider additional evidence, apply different legal standards, or address issues not fully resolved in the initial proceedings.
South Carolina has been the subject of various election-related lawsuits in recent years, as states nationwide face increased scrutiny over their election administration practices. The outcome of this case could influence how South Carolina and other states in the Fourth Circuit implement voter registration list maintenance procedures.
The case's resolution will likely impact ongoing debates about election integrity and voter access. As states continue to balance maintaining accurate voter rolls with ensuring eligible citizens can exercise their voting rights, federal court decisions provide important guidance for election administrators.
The remand means the district court will need to reconsider aspects of the case based on the Fourth Circuit's guidance. This could result in additional proceedings, settlement negotiations, or a new trial depending on the specific issues the appeals court identified for further review. The ultimate resolution could establish new precedent for NVRA compliance in the Fourth Circuit, which includes Maryland, North Carolina, South Carolina, Virginia, and West Virginia.