A federal judge ruled Tuesday that a Bucks County man accused of voting twice in the 2020 election cannot use President Donald Trump’s November pardon to immediately dismiss the charges against him.
U.S. District Judge Joseph Leeson Jr. denied a motion by Matthew Laiss to throw out the federal case, finding that Laiss must first apply to the U.S. Office of the Pardon Attorney to seek coverage under Trump’s proclamation, which granted clemency to dozens of people involved in efforts to challenge the 2020 election.
Federal prosecutors allege that after moving from Pennsylvania to Florida in August 2020, Laiss voted twice in the November 2020 election — once by mail in Bucks County and once in person in Florida — while maintaining voter registration in both states.
In Bucks County, elections are administered by the county Board of Elections, which oversees voter registration and the processing of mail-in ballots. Pennsylvania also participates in interstate data-sharing programs such as the Electronic Registration Information Center, which helps states identify potential duplicate voter registrations across state lines.
Federal authorities have brought similar cases in recent years. In one separate prosecution, a Pennsylvania man pleaded guilty to voting in Pennsylvania and Florida during the 2020 presidential election, illustrating how double-voting allegations can lead to federal charges.
“This Court finds that Laiss has not yet applied to the Office of the Pardon Attorney, or received a certificate of pardon, which the plain language of the Pardon requires him to do,” Judge Leeson wrote in his decision.
Laiss’s attorney had sought to have the charges dismissed, arguing that Trump’s November pardon covered his client’s case.
Trump issued the pardon in November to 77 people connected to efforts to challenge the outcome of the 2020 presidential election, including members of his legal team and the so-called fake electors who attempted to submit alternative slates of electoral votes to Congress.
The proclamation also granted what Trump described as a “full, complete, and unconditional pardon to all United States citizens” for conduct related to the 2020 election — language that Laiss has cited in arguing that the clemency should apply to his case.
In his ruling, Leeson said the court lacked authority to determine whether Trump’s November pardon applied to Laiss, because the proclamation itself assigns that role to the Justice Department’s Office of the Pardon Attorney.
Under the terms of the proclamation, the attorney general, acting through the pardon attorney, is responsible for determining whether individuals are eligible for a certificate of pardon, a step the judge said must occur before a court can dismiss pending charges.
Leeson distinguished Trump’s November proclamation from pardons that name specific individuals, noting that the broader language of the election-related pardon explicitly contemplates an administrative review process, rather than immediate court enforcement.
With the motion to dismiss denied, Laiss’s federal case will proceed through the court system. He faces charges related to voting twice in the 2020 election, which carry potential penalties under federal election law.
Before the ruling, Laiss’s attorney argued in court filings that the plain language of Trump’s November pardon — which refers broadly to “all United States citizens” — should apply to his client’s case. Federal prosecutors countered that the proclamation required individuals seeking coverage to apply through the Office of the Pardon Attorney, and that Laiss could not bypass that process by asking the court to dismiss the charges.
In denying the motion, Leeson made clear that defendants seeking relief under Trump’s proclamation must first pursue the administrative process outlined in the pardon itself. The decision signals that courts will require that step before considering whether the pardon applies in pending election-related prosecutions.
The ruling clarifies that defendants seeking to rely on Trump’s November pardon must first follow the administrative process outlined in the proclamation, as opposed to asking courts to dismiss charges outright. That requirement could influence how similar pardon claims are handled in other election-related cases stemming from the 2020 election.
The decision also reflects that federal prosecutors continue to pursue election-related charges through the court system, even as Trump has issued broad pardons tied to efforts to challenge the 2020 results.
Laiss can seek coverage under Trump’s November pardon by formally applying through the Justice Department’s Office of the Pardon Attorney, while his federal criminal case continues. Unless he receives a certificate of pardon through that process, the prosecution will move forward in court.
The ruling makes clear that courts will not apply Trump’s broad proclamation to pending cases without the procedural steps outlined in the pardon itself, a finding that could influence how similar claims are raised in other election-related cases.
