## Facts

- John Hutchinson (congressional candidate), William Reese (county commissioner candidate), and Leonard Underwood (state delegate candidate) lost the 1980 general election in West Virginia by large margins.
- They alleged a conspiracy among county election officials, private individuals, and a voting-equipment company to alter vote totals in Kanawha and Boone Counties.
- Alleged misconduct included improper opening of ballot boxes, mishandling of computer tabulation, and inadequate security for voting machines.
- In 1983, plaintiffs sued for approximately $9 million in damages under 42 U.S.C. § 1983, RICO (18 U.S.C. § 1964), and West Virginia common law.
- Claimed damages included lost salaries and benefits of the offices, as well as reputational harm and emotional distress.

## Issues

1. Whether defeated candidates may obtain monetary damages in federal court under § 1983, RICO, and state law for alleged irregularities and misconduct in state-administered elections.
2. Whether the alleged irregularities and asserted conspiracy constituted a constitutional deprivation by rendering the election process fundamentally unfair.

## Decision

- The Fourth Circuit affirmed judgment for all defendants.
- The court held federal courts are not available to award damages to defeated candidates based on alleged wrongdoing in state-run elections.
- The court concluded plaintiffs failed to prove a conspiracy or an election so fundamentally unfair as to amount to a constitutional deprivation.
- Because federal relief was unavailable on the record and theories presented, plaintiffs’ § 1983 and RICO claims failed; the disposition of the pendent state-law claims was left undisturbed.

## Legal Principles

- Federal courts generally will not adjudicate post-election damages actions by losing candidates based on alleged election misconduct.
- “Garden-variety” election irregularities and administrative errors do not, without more, rise to constitutional violations actionable under § 1983.
- Federal judicial intervention in election disputes, even for equitable relief, is reserved for rare and extraordinary circumstances involving fundamental unfairness affecting voting rights or vote counting.
- Claims requiring courts to reconstruct a counterfactual election outcome (“would have won but for” misconduct) are highly speculative and disfavored, especially when tied to large retrospective damages.
- Existing political and statutory mechanisms for contesting elections—particularly for congressional seats—counsel against recognizing broad federal damages remedies for alleged election rigging.

## Conclusion

The court refused to convert federal litigation into a vehicle for defeated candidates to obtain large damages awards based on contested allegations of election irregularities, holding that only exceptional circumstances involving a fundamentally unfair election can support federal intervention, and that plaintiffs failed to meet that threshold.


Hutchinson v. Miller, 797 F.2d 1279 (4th Cir. 1986)