Reported / Citable
Background
Valencia Williams alleged that she submitted a petition shortly after 2:00 a.m. on August 17, 2026, seeking placement on Texas’s list of write-in candidates for the 18th Congressional District. The filing deadline was 5:00 p.m. that day. Williams said that a Secretary of State legal-department employee told her before the deadline that her petition required no corrections, but the Secretary of State later rejected it.
Williams sued the Texas Secretary of State and sought emergency injunctive relief requiring her inclusion on the write-in candidate list. She alleged that she relied on the employee’s statement and characterized the rejection as based on clerical technicalities. She did not comply with the court’s order directing her to produce correspondence concerning her application.
The Court’s Holding
Judge Andrew S. Hanen dismissed the case without prejudice for lack of subject-matter jurisdiction. The Texas Secretary of State, as sued, was a state agency protected by Eleventh Amendment sovereign immunity, and Williams had not shown either a state waiver or congressional abrogation of that immunity.
The court held that Ex parte Young did not supply an exception. Williams sued the agency rather than the Secretary of State in his official capacity, and she did not allege that Texas’s write-in-candidate requirements or the agency’s conduct violated federal law or the Constitution. Her allegation that she relied on an assurance that her application was error-free sounded in equitable estoppel under state law, not a federal claim.
Key Takeaways
- An Ex parte Young claim must be directed at a state official, not the state or a state agency.
- Prospective injunctive relief does not alone overcome sovereign immunity; the complaint must allege an ongoing violation of federal law.
- A claimed erroneous assurance by a state employee, framed as equitable estoppel, does not itself create federal jurisdiction.
Why It Matters
The order underscores a threshold pleading requirement in election-related federal litigation: a candidate seeking ballot-related relief against a state actor must identify a federal constitutional or statutory violation and name a proper state official defendant. A dispute over the handling of an application under state procedures, without more, will not invoke the Ex parte Young exception.