Case 1:17-cv-02989-AT Document 579 Filed 08/15/19 Page 15 of 153
formalism in favor of flexible practicality. See Provident Tradesmens
Bank & Trust Co. v. Patterson, 390 U.S. 102, 118–19 (1968).
City of Marietta v. CSX Transp., Inc., 196 F.3d 1300, 1305 (11th Cir. 1999). “The
‘complete’ relief concept of Rule 19(a)(1) ‘refers to relief as between the persons
already parties, not as between a party and the absent [party] whose joinder is
sought.’” Heinrich v. Goodyear Tire & Rubber Co., 532 F. Supp. 1348, 1359–60
(D. Md. 1982) (citations omitted). In making this determination, “pragmatic
concerns, especially the effect on the parties and the litigation, control.” Focus on
the Family v. Pinellas Suncoast Transit Auth., 344 F.3d 1263, 1280 (11th Cir.
2003); accord Challenge Homes, Inc. v. Greater Naples Care Ctr., Inc., 669 F.2d
667, 669 (11th Cir. 1982).
The State Defendants previously argued in filings before the Court that
preceded Plaintiffs’ renewed preliminary injunction motions that the Secretary of
State plays a limited role in both county and municipal elections. (See Doc. 367.)
In response to Plaintiffs’ motions for immediate relief in time for the Fall 2019
elections, the State Defendants have scaled back their objection, focusing on
municipalities only. The State Defendants now appear to recognize that counties
have no leeway in how to conduct their elections under Georgia’s election code,
despite their prior contradictory assertion that “municipalities and counties have
authority to determine . . . the method of said elections . . .” (Doc. 367 at 2)
(emphasis added).
See also O.C.G.A. § 21-2-300 (“The equipment used for
casting and counting votes in county, state, and federal elections shall be the
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