LINDSAY DYDA, v. MICHIGAN SECRETARY OF STATE - Articles

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LINDSAY DYDA, v. MICHIGAN SECRETARY OF STATE

Posted by: Azya Thornton on Jul 20, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: Philip L. Ellison, OUTSIDE LEGAL COUNSEL PLC, Hemlock, Michigan, for Appellant.

Attorneys 2: ON BRIEF: Erik A. Grill, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellees.

Judge(s): SILER, DAVIS, and RITZ, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Bay City

DAVIS, Circuit Judge. Lindsay Dyda does not have a Social Security Number for religious reasons. Based on certain federal regulations and state law, the Michigan Department of State denied her application for a driving permit because she did not provide a Social Security Number. Dyda sued Josette Tabor, a help desk worker at the Department, and Michigan Secretary of State Jocelyn Benson under 42 U.S.C. § 1983, asserting that their actions violated the Free Exercise Clause of the First Amendment. After receiving interpretive guidance from the federal agency responsible for the regulations, the Department is now prepared to process Dyda’s application without a Social Security Number. Dyda appeals the district court’s ruling that her claims for declaratory and injunctive relief are moot and that Tabor is entitled to qualified immunity. We affirm.

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