United States of America v. Benson et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
JOCELYN BENSON, et al.,
Defendants.
___________________________________/
Case No. 1:25-cv-1148
Hon. Hala Y. Jarbou
OPINION
The United States brings this lawsuit against the State of Michigan and its Secretary of
State, seeking the disclosure of voting records under Title II of the Civil Rights Act of 1960 (the
“CRA”), 52 U.S.C. § 20703, the National Voter Registration Act (NVRA), 52 U.S.C. § 20507(i),
and the Help America Vote Act (HAVA), 52 U.S.C. § 21083. Before the Court are two motions
to intervene as defendants: one filed by the Michigan Alliance for Retired Americans (“MARA”),
Donald Duquette, and Keely Crimando (ECF No. 5), and the other filed by the League of Women
Voters of Michigan (the “LWVM”) (ECF No. 17). The United States opposes both motions;
Michigan takes no position on the motions.
As explained below, the Court finds that MARA, Duquette, and Crimando are entitled to
intervention as of right, and will grant their motion. However, because MARA will adequately
represent the interests of the LWVM, the Court will deny the LWVM’s motion.
I. BACKGROUND
This case arises out of the United States’ July 21, 2025, request for voter records from the
State of Michigan. (Compl. ¶ 35, ECF No. 1.) The United States sought, among other things, “a
list of the election officials who are responsible for implementing Michigan’s general program of
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voter registration list maintenance,” “a description of the steps that Michigan has taken in
furtherance of [voter registration list maintenance],” and “a current electronic copy of [Michigan’s]
computerized [statewide voter registration list].” (Id.) The United States indicated that this
information was necessary to determine whether Michigan was complying with its obligations
under the NVRA and HAVA. (Id. ¶ 43.) As to the voter registration list, the United States
specifically requested the following information about voters: their “full name, date of birth,
residential address, and either their state driver’s license number or the last four digits of their
Social Security number.” (See id. ¶ 66.) On September 9, 2025, Michigan informed the United
States that it would only provide the public statewide voter registration list, which does not include
full dates of birth, driver’s license numbers, or social security numbers. (Id. ¶ 46.) Michigan
claimed that this personal information was exempt from disclosure under Michigan law, see Mich.
Comp. Laws §§ 15.243, 168.509gg, as well as under the federal Privacy Act, 5 U.S.C. § 552a, and
the federal Driver Privacy Protection Act, 18 U.S.C. § 2721 et seq. (Compl. ¶ 48; 9/9/2025 Letter,
ECF No. 39-6.) In response, the United States brought this lawsuit seeking a declaratory judgment
and an injunction requiring Michigan to disclose the unredacted voter registration list.
II. LEGAL STANDARD
The Federal Rules of Civil Procedure provide two bases for intervention. United States v.
Michigan, 424 F.3d 438, 443 (6th Cir. 2005). Under Rule 24(a), a movant may intervene as of
right if it
claims an interest relating to the property or transaction that is the subject of the
action, and is so situated that disposing of the action may as a practical matter
impair or impede the movant’s ability to protect its interest, unless existing parties
adequately represent that interest.
Fed. R. Civ. P. 24(a)(2). “[T]o intervene as of right under Rule 24(a)(2), a proposed intervenor
must establish the following four elements: (1) the motion to intervene is timely; (2) the proposed
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intervenor has a substantial legal interest in the subject matter of the case; (3) the proposed
intervenor’s ability to protect that interest may be impaired in the absence of intervention; and
(4) the parties already before the court may not adequately represent the proposed intervenor's
interest.” Michigan, 424 F.3d at 443.
Alternatively, Rule 24(b) allows for permissive intervention when a movant “has a claim
or defense that shares with the main action a common question of law or fact.” Fed. R. Civ. P.
24(b)(1)(B). “In exercising its discretion, the court must consider whether the intervention will
unduly delay or prejudice the adjudication of the original parties’ rights.” Fed. R. Civ. P. 24(b)(3).
If a motion for permissive intervention is timely and there is a common question of law or fact,
“the district court must . . . balance undue delay and prejudice to the original parties, if any, and
any other relevant factors to determine whether, in the court’s discretion, intervention should be
allowed.” Michigan, 424 F.3d at 445.
III. ANALYSIS
1. Michigan Alliance of Retired Americans
(a) Interest in the Litigation
MARA, Duquette, and Crimando filed a timely motion to intervene under Rule 24(a) or,
in the alternative, Rule 24(b). MARA argues that it has an interest in this litigation because its
members are registered voters whose personal information will be disclosed to the Department of
Justice (DOJ) if the United States succeeds in this case. MARA also contends that the possibility
of disclosure will hinder its voter registration activities by deterring people from registering to
vote. Duquette and Crimando argue that the DOJ’s access to their personal information could chill
their speech due to fear of government retaliation.
The Court agrees that these proposed intervenors have a sufficiently substantial interest in
this case. The Sixth Circuit “has opted for a rather expansive notion of the interest sufficient to
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invoke intervention of right.” Coal. to Def. Affirmative Action v. Granholm, 501 F.3d 775, 780
(6th Cir. 2007) (quoting Mich. State AFL-CIO v. Miller, 103 F.3d 1240, 1245 (6th Cir. 1997)).
The Sixth Circuit has “cited with approval decisions of other courts ‘reject[ing] the notion that
Rule 24(a)(2) requires a specific legal or equitable interest.’” Miller, 103 F.3d at 1245 (alteration
in original) (quoting Purnell v. City of Akron, 925 F.2d 941, 948 (6th Cir. 1991)); see also Hatton
v. Cnty. Bd. of Ed., 422 F.2d 457, 461 (6th Cir. 1970) (“Although the interest claimed is of a
general and indefinite character, it would seem to the Court to be sufficient to permit intervention
[as of right].”). Here, the proposed intervenors have a privacy interest in preventing the disclosure
of their personal information to the federal government. This suffices for purposes of Rule 24(a).
Cf. Kalbers v. DOJ, 22 F.4th 816, 827 (9th Cir. 2021) (proposed intervenor had “interest in the
non-disclosure of its documents” that were potentially protected by FOIA exemption, “[a]nd there
is a direct, antagonistic relationship between [the proposed intervenor]’s interest in confidentiality
and [plaintiffs’] interest in obtaining the documents at issue”); In re Sealed Case, 237 F.3d 657,
664 (D.C. Cir. 2001) (proposed intervenors had interest in non-disclosure of their information);
Tarazi v. Oshry, No. 2:10-CV-793, 2011 WL 1326271, at *4 (S.D. Ohio Apr. 4, 2011) (same).
The United States makes several arguments as to why the intervenors lack an interest in
the case, but none are persuasive. First, it argues that intervention is inappropriate because HAVA
and the CRA do not create a private right of action.1 But the absence of a right of action is
irrelevant given that the movants are seeking to intervene as defendants rather than plaintiffs. The
United States does not explain why an intervenor-defendant would need a right of action, and the
Court sees no reason why that would be the case. See Johnson & Johnson Health Care Sys. Inc.
1 Although not relevant here, HAVA does create a private right that can be enforced under 42 U.S.C. § 1983. Sandusky
Cnty. Democratic Party v. Blackwell, 387 F.3d 565, 572–73 (6th Cir. 2004).
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v. Kennedy, No. CV 24-3188 (RC), 2025 WL 1411076, at *3 (D.D.C. May 15, 2025) (“[T]he
standards for whether a party has a cause of action as a plaintiff and whether a party can intervene,
here as a defendant, are different: as Rule 24’s plain text indicates, intervenors of right need only
an ‘interest’ in the litigation—not a cause of action or permission to sue.” (cleaned up)). The only
authority the United States cites for its position is United States v. Alabama, No. 2:06-CV-392-
WKW, 2006 WL 2290726 (M.D. Ala. Aug. 8, 2006). But contrary to the United States’
characterization, the court in Alabama did not hold that the absence of a private right of action
under HAVA precludes proposed intervenor-defendants from having an interest in the case.
Rather, the court concluded that the proposed intervenors lacked an interest because, among other
things, they asserted only general policy concerns. Id. at *4. It noted the absence of a right of
action, but recognized that this was a tangential point rather than a dispositive one. See id. at *4
n.6 (“Because the proposed intervenors move for intervention as defendants to this action, it is
unlikely that they are claiming to be plaintiffs with a private right of action under HAVA.
Nonetheless, in the interest of clarity, and because such possibility was raised by the United States,
the Court addresses this possibility.”). At most, the court implied that the presence of a right of
action might entitle a party to intervention; it did not imply that the absence of a right of action
necessarily bars intervention.
The United States also argues that HAVA and the CRA only allow suit against specific
election officials in relation to the voter information provisions, and thus the movants could not be
properly sued under these statutes. But this too is irrelevant. The United States cites no authority
indicating that a movant can only intervene as a defendant if the plaintiff has a cause of action
against it—i.e., if the movant could have been named as a defendant in the complaint. And case
law suggests the opposite. For example, the Administrative Procedure Act only authorizes suit
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against the federal government or its agents, see 5 U.S.C.A. § 702, but private parties can intervene
as defendants to argue on behalf of the agency action at issue. See, e.g., Ohio v. EPA, No. 2:15-
CV-2467, 2019 WL 417297, at *2–3 (S.D. Ohio Feb. 1, 2019); Farmer v. EPA, 759 F. Supp. 3d
101, 111 (D.D.C. 2024). Private parties can also intervene as defendants in cases alleging
constitutional violations by government actors, even though a plaintiff could not bring such a suit
against a private party. See, e.g., Grutter v. Bollinger, 188 F.3d 394, 399 (6th Cir. 1999); Coal. to
Def. Affirmative Action v. Granholm, 240 F.R.D. 368, 375–77 (E.D. Mich. 2006). Thus, the fact
that HAVA and the CRA do not authorize suit against the movants does not affect their ability to
intervene.
Next, the United States contends that the movants’ asserted interests are based on mere
speculation that disclosure of their information to the DOJ will cause harm. It asserts that the DOJ
will protect voter information from unauthorized disclosure. But this argument also misses the
mark. The movants have an interest in keeping their information private from the DOJ, whether
or not disclosure to the DOJ produces any additional harm. The law generally recognizes a privacy
interest implicated by unauthorized disclosure of personal information, even absent any
downstream effects of that disclosure. See, e.g., Patel v. Facebook, Inc., 932 F.3d 1264, 1274 (9th
Cir. 2019) (“Under the common law, an intrusion into privacy rights by itself makes a defendant
subject to liability.”); United States v. Miami Univ., 294 F.3d 797, 818 (6th Cir. 2002) (recognizing
“the inherent privacy interest” protected by the Family Educational Rights and Privacy Act);
Kanuszewski v. Mich. Dep’t of Health & Hum. Servs., 927 F.3d 396, 410 (6th Cir. 2019) (alleged
testing of blood samples constituted injury to privacy interest for standing purposes); DOJ v. Reps.
Comm. For Freedom of the Press, 489 U.S. 749, 763 (1989) (“[B]oth the common law and the
literal understandings of privacy encompass the individual’s control of information concerning his
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or her person.”); Coulter-Owens v. Time Inc., 695 F. App’x 117, 121 (6th Cir. 2017) (“[T]he
disclosure of [personal] information is a cognizable injury in fact for purposes of Article III
standing.”); Moeller v. Am. Media, Inc., 235 F. Supp. 3d 868, 873 (E.D. Mich. 2017) (“[T]he
common law has long recognized a right to personal privacy[.]” (cleaned up)). Movants thus have
a stake in this case because their inherent privacy interest is implicated by the disclosures at issue
here.
The United States also argues that the movants’ privacy interests are not implicated by
disclosures of their information to the DOJ because other federal agencies already possess that
information. However, specific government entities possess private information for specific
purposes, and there are regulations and statutes governing how that information may be transferred
between agencies. See, e.g., 5 U.S.C.A. § 552a(b) (limiting inter-agency disclosure of personal
information). It is evident that the voter information here is not already available to the DOJ, or
else they would not have requested it from Michigan or brought this lawsuit. Even if other agencies
possess the movants’ personal information, the movants still have an interest in preventing further
disclosure. Cf. Reps. Comm., 489 U.S. at 764 (even where information has already been disclosed
in “scattered” form to the public, release of compilations of that information implicated privacy
interests because it made the information more accessible).
The United States also cites the consent judgment and order in United States v. North
Carolina Board of Elections, No. 5:25-cv-00283-M-RJ (E.D.N.C. Sep. 8, 2025) (see Consent J.,
ECF No. 26-2), contending that the court there denied similar motions to intervene in a HAVA
enforcement suit because privacy arguments against disclosure “objectively proved to be
unfounded.” (Gov’t’s Mot. in Opp’n 17, ECF No. 26.) However, that court denied the motions to
intervene as moot because the United States and North Carolina reached a consent judgment.
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(Consent J. 12.) The court did not rule on whether the prospective intervenors had a privacy
interest in non-disclosure. And although the United States argues that the Court here can impose
limits on the DOJ’s use of voter information—as the court did in North Carolina Board of
Elections—such limits do not ameliorate the harm when the privacy violation complained of is the
disclosure to the DOJ itself.
The United States also contends that the potential injury to the movants is a generalized
injury that affects all Michigan voters, rather than a particularized injury that can support
intervention. As an initial matter, the requirement of a particularized injury is drawn from the
Article III standing context; here, because the movants seek to intervene as defendants, they are
not required to demonstrate standing. See Va. House of Delegates v. Bethune-Hill, 587 U.S. 658,
663 (2019) (defendant-intervenor need not demonstrate standing because intervening as defendant
does not “entail[] invoking a court’s jurisdiction”); Davis v. Lifetime Cap., Inc., 560 F. App’x 477,
488 (6th Cir. 2014) (intervention does not require Article III standing). The United States does
not cite any binding precedent requiring proposed intervenors to show a particularized injury.
While some courts have indicated as much—see, e.g., Chiles v. Thornburgh, 865 F.2d 1197, 1212
(11th Cir. 1989); Wis. Educ. Ass’n Council v. Walker, 705 F.3d 640, 658 (7th Cir. 2013)—the
Sixth Circuit’s broad definition of “interest” arguably encompasses injuries that do not qualify as
particularized under Article III.
Regardless, even if Rule 24(a) does require the kind of particularized injury that would
support Article III standing, that requirement is satisfied here because the disclosure of one’s
private information is a particularized injury. See Lujan v. Defs. of Wildlife, 504 U.S. 555, 560 n.1
(1992) (particularized injury is one that “affect[s] the [movants] in a personal and individual way”).
“The fact that an injury may be suffered by a large number of people does not of itself make that
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injury a nonjusticiable generalized grievance.” Spokeo, Inc. v. Robins, 578 U.S. 330, 339 n.7
(2016), as revised (May 24, 2016); cf. Pub. Citizen v. DOJ, 491 U.S. 440, 449–50 (1989) (“The
fact that other citizens or groups of citizens might make the same complaint after unsuccessfully
demanding disclosure under FACA does not lessen appellants’ asserted injury, any more than the
fact that numerous citizens might request the same information under the Freedom of Information
Act entails that those who have been denied access do not possess a sufficient basis to sue.”); FEC
v. Akins, 524 U.S. 11, 24 (1998) (“widely shared” injury can still establish standing, such as when
“large numbers of individuals suffer the same common-law injury (say, a widespread mass tort),
or where large numbers of voters suffer interference with voting rights conferred by law”); see
also id. at 35 (Scalia, J., dissenting) (agreeing with majority that a “widely shared” injury can
establish standing where “each individual suffers a particularized and differentiated harm”). Here,
the movants are not “raising only a generally available grievance about government—claiming
only harm to [their] and every citizen’s interest in proper application of the Constitution and laws
and seeking relief that no more directly and tangibly benefits [them] than it does the public at
large.” Lance v. Coffman, 549 U.S. 437, 439 (2007) (per curiam). Rather, the movants are raising
a grievance that is specific to them—the disclosure of their personal information—even if it is a
grievance that many people could raise. See In re Horizon Healthcare Servs. Inc. Data Breach
Litig., 846 F.3d 625, 633 n.10 (3d Cir. 2017) (“There is no doubt that the Plaintiffs complain of a
particularized injury—the disclosure of their own private information.”).
In sum, the movants have established that they have an interest in the non-disclosure of
their personal information, and thus in the outcome of this lawsuit.
(b) Impairment of Interest
As discussed above, the movants have an interest in preventing the DOJ from acquiring
their personal information. Because this case could result in an order allowing the DOJ to acquire
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that information, the outcome of this lawsuit may impair the movants’ interests. The United States
attempts to avoid this conclusion by noting that the movants have already provided the information
at issue here to the state of Michigan for voter registration purposes, and that Michigan has
disclosed the information to the Electronic Registration Information Center, an organization that
helps states maintain their voter rolls. But the United States provides no authority for the principle
that disclosing one’s personal information to a specific entity for a specific purpose eliminates
one’s interest in keeping that information private from other entities that may use it for other
purposes. Such a principle contradicts common sense: everyone’s personal information is known
by some entity or another, but that does not extinguish all privacy interests in relation to other
entities (government or otherwise). For example, as noted above, Congress has recognized that
people have a privacy interest in preventing certain federal agencies from acquiring information
already known to other agencies. See 5 U.S.C.A. § 552a(b) (limiting inter-agency disclosure of
personal information). Similarly, movants have a privacy interest in preventing the federal
government from acquiring information already known to Michigan.
In sum, the movants have sufficiently established that the outcome of this lawsuit could
impair their privacy interests.
(c) Inadequate Representation
The United States also argues that intervention is unwarranted because the movants’
interests will be adequately represented by Michigan in this lawsuit. The adequacy requirement
“is satisfied if the applicant shows that representation of his interest ‘may be’ inadequate; and the
burden of making that showing should be treated as minimal.” Trbovich v. United Mine Workers
of Am., 404 U.S. 528, 538 (1972). “Nevertheless, applicants for intervention must overcome the
presumption of adequate representation that arises when they share the same ultimate objective as
a party to the suit.” Michigan, 424 F.3d at 443–44. “An applicant for intervention fails to meet
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his burden of demonstrating inadequate representation ‘when no collusion is shown between the
representatives and an opposing party, when the representative does not have or represent an
interest adverse to the proposed intervenor, and when the representative has not failed in its
fulfillment of his duty.’” Bradley v. Milliken, 828 F.2d 1186, 1192 (6th Cir. 1987). However,
“Rule 24 is to be construed liberally, and doubt resolved in favor of the proposed intervenor.”
Kasprzak v. Allstate Ins. Co., No. 12-CV-12140, 2013 WL 1632542, at *3 (E.D. Mich. Apr. 16,
2013) (quoting Turn Key Gaming, Inc. v. Oglala Sioux Tribe, 164 F.3d 1080, 1081 (8th Cir. 1999)).
The Court agrees with MARA that Michigan is not an adequate representative of its
interests. It is true that Michigan appears to have the same objectives as MARA, in that the state
has so far refused to provide the DOJ with the requested information. But as MARA argues,
Michigan has other countervailing incentives—for example, to maintain an election system,
comply with federal law, and preserve comity with the federal government—that may ultimately
induce it to stop defending the lawsuit or give up the information at issue. Of course, inadequacy
cannot be shown based on mere “speculation” about an existing party’s future actions. Mich. State
AFL-CIO v. Callaghan, No. 13-CV-10557, 2013 WL 12621889, at *2 (E.D. Mich. Dec. 9, 2013).
But a movant can establish inadequacy with “a prediction” as to how a party may act given its
“institutional interests.” Id. For example, the Sixth Circuit has held that a township did not
adequately represent a movant’s interests where the township appeared to be defending the lawsuit
as the movant would, but its behavior could change in the future: “when the specter of monetary
damages looms large, even stout resistance might wither over time.” Wineries of the Old Mission
Peninsula Ass’n v. Township of Peninsula, 41 F.4th 767, 776 (6th Cir. 2022). Although monetary
damages are not at issue here, Wineries indicates that MARA can establish inadequacy based on
the possibility that Michigan’s litigation position will become adverse to MARA’s interests in the
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future. See id. (“What keeps the Township in the litigation today could change tomorrow,
dampening the allure of continued legal battle along the way.”). For the moment, Michigan’s
interest in compliance with federal government requests is outweighed by other considerations,
but the balance could shift at any time. That possibility sufficiently establishes the inadequacy of
Michigan’s representation. Cf. Pub. Int. Legal Found., Inc. v. Winfrey, 463 F. Supp. 3d 795, 799
(E.D. Mich. 2020) (noting that, in the permissive intervention context, “[t]he Sixth Circuit has
recognized that the interests of election officials in voting roll maintenance are sufficiently distinct
from those of elected officials and their constituents to warrant intervention by those who could
be impacted by the results of the maintenance process.”).
(d) Conclusion
In sum, MARA and the individual proposed intervenors (Duquette and Crimando) have
established their entitlement to intervene as of right. In the alternative, the Court would grant them
permissive intervention under Rule 24(b). A common question of law exists, as the movants seek
to challenge the DOJ’s ability to obtain their personal information and Michigan’s ability to
disclose it—both of which are legal arguments that Michigan has raised too. Moreover, the
substantiality of the movants’ interests and the potential divergence between their interests and
Michigan’s also weigh in favor of allowing intervention. See Coal. to Def. Affirmative Action, 501
F.3d at 784 (court can consider substantial interest and adequacy in Rule 24(b) analysis). Finally,
there is minimal prejudice to the United States because it is still early in the case and there is no
reason to think that additional defendants will unduly delay or complicate the proceedings. Thus,
the Rule 24(b) factors support permissive intervention here.
2. League of Women Voters of Michigan
The LWVM’s asserted interests in this lawsuit are similar to MARA’s: the confidentiality
of its members’ personal information, the potential deterrence effects on voter registration, its goal
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of ensuring that election information is appropriately handled, and the potential resources it may
have to expend educating voters about the DOJ’s use of their information. For the reasons
discussed above, the LWVM has established that it has a substantial interest that could be impaired
by this lawsuit. However, because the Court will grant MARA’s motion to intervene, MARA is
considered an “existing party” for purposes of the adequacy analysis. In other words, to establish
its right to intervene, the LWVM has to show not only that Michigan inadequately represents its
interests but that MARA does as well. See Wineries, 41 F.4th at 777 (adequate representation
analysis changes with each successive intervenor, and “it may be that the interests of existing
parties will come to overlap fully with the interests of any remaining proposed intervenor” (quoting
Berger v. N.C. State Conf. of the NAACP, 597 U.S. 179, 199 (2022)). The LWVM’s interests in
the case are essentially identical to MARA’s, and the LWVM provides no reason to think MARA
cannot adequately represent those interests. Thus, the LWVM is not entitled to intervention as of
right. For the same reason, the Court declines to allow permissive intervention. See Coal. to Def.
Affirmative Action, 501 F.3d at 784 (adequacy is factor in Rule 24(b) analysis).2
IV. CONCLUSION
For the reasons discussed above, the Court will grant MARA, Duquette, and Crimando’s
motion to intervene, and deny the LWVM’s motion to intervene. An order will issue in accordance
with this Opinion.
Dated: December 9, 2025 /s/ Hala Y. Jarbou
HALA Y. JARBOU
CHIEF UNITED STATES DISTRICT JUDGE
2 For the same reason that the Court is granting MARA’s motion and denying the LWVM’s motion, it could instead
grant the LWVM’s motion and deny MARA’s. But the Court is addressing the motions in the order they were filed.
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