Anderson et al. v. Celebrezze, Secretary of State of Ohio
460 U.S. 780 (1983)
Rule of Law:
A state election law that imposes a significant burden on the voting and associational rights of an independent candidate's supporters, such as an early filing deadline, is unconstitutional under the First and Fourteenth Amendments unless it is narrowly drawn to advance a compelling state interest.
Facts:
- John Anderson announced his independent candidacy for President of the United States on April 24, 1980.
- An Ohio statute required independent candidates to file a statement of candidacy and nominating petitions by March 20, 1980, which was 229 days before the general election.
- By the time Anderson announced his candidacy, the Ohio filing deadline had already passed.
- On May 16, 1980, Anderson's supporters attempted to file a nominating petition with approximately 14,500 signatures on his behalf.
- Anthony J. Celebrezze, Jr., the Ohio Secretary of State, refused to accept the petition solely because it was submitted after the March 20 deadline.
- Anderson had previously competed in several Republican primaries but had withdrawn from the Ohio primary, making the state's 'sore loser' statute inapplicable to him.
Procedural Posture:
- John Anderson and three voters sued Ohio Secretary of State Anthony J. Celebrezze, Jr., in the U.S. District Court for the Southern District of Ohio.
- The District Court granted summary judgment for Anderson, holding the filing deadline unconstitutional and ordering Anderson's name to be placed on the ballot.
- Celebrezze, as appellant, appealed the decision to the U.S. Court of Appeals for the Sixth Circuit.
- While the appeal was pending, the 1980 general election took place with Anderson's name on the Ohio ballot.
- The Court of Appeals reversed the District Court's judgment, finding the early filing deadline to be constitutional.
- The U.S. Supreme Court granted certiorari to resolve a conflict among the Circuits on the issue.
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Issue:
Does Ohio's early filing deadline for independent presidential candidates place an unconstitutional burden on the voting and associational rights of the candidate's supporters, in violation of the First and Fourteenth Amendments?
Opinions:
Majority - Justice Stevens
Yes, Ohio's early filing deadline places an unconstitutional burden on the voting and associational rights of supporters of independent candidates. The court must weigh the character and magnitude of the injury to First and Fourteenth Amendment rights against the state's justifications for the burden. The early deadline places a substantial burden on independent candidates and their supporters by preventing late-emerging candidacies and making it harder to gather signatures and build campaign momentum. The State's asserted interests in voter education, equal treatment of candidates, and political stability are not sufficient to justify this burden. The voter education argument is unrealistic in the modern era of mass communication and is undermined by the state's later deadline for major party nominees. The equal treatment argument fails because the deadline impacts independents far more severely than party candidates. Finally, the political stability interest, which amounts to protecting major parties from competition, is not a legitimate state goal that can justify excluding candidates from the political process.
Dissenting - Justice Rehnquist
No, Ohio's filing deadline does not place an unconstitutional burden on voters' rights and is a valid exercise of the State's broad power under Article II to regulate the appointment of presidential electors. The burden imposed by the deadline is minimal, as evidenced by the fact that five other independent candidates successfully qualified for the Ohio ballot in 1980. The law did not exclude Anderson from running for president; it only prevented him from having two chances in the same election year—first as a party candidate and then as an independent. The deadline serves the state's compelling interest in political stability, as recognized in Storer v. Brown, by discouraging party splintering and intraparty feuds. The state also has a legitimate interest in voter education, and providing a longer campaign period allows the electorate to better scrutinize candidates. The law is rational, allows reasonable ballot access, and should not be overturned by the Court.
Analysis:
This decision established a flexible balancing test, often called the Anderson-Burdick test, for evaluating the constitutionality of state election laws. This test requires a court to weigh the character and magnitude of the burden on voting and associational rights against the precise interests the state proffers as justification. The ruling moved away from a rigid, tiered scrutiny framework in election law, providing a more nuanced approach. It also underscores that a state's regulatory interest is weaker in the context of a national presidential election, where the impact of its rules extends beyond its borders, than in purely state or local elections.
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