| This issue was originally printed on green paper. |
Table of Contents
LIBERTARIANS LOSE OKLAHOMA PARTY RIGHTS CASE
BUT COURT MAJORITY CRITICIZES OVERLY-STRICT BALLOT ACCESS LAWS
On May 23, the U.S. Supreme Court issued Clingman v Beaver. Six justices voted to uphold an Oklahoma law that makes it illegal for parties to invite all voters to vote in their primaries. Three justices dissented, saying there is no important state interest in forbidding this practice.
However, two of the justices in the majority, as well as the three justices in the minority, wrote that election laws that make it difficult for new and minor parties to operate are unwise and sometimes unconstitutional.
Justice Clarence Thomas wrote the majority opinion, which was co-signed by Chief Justice William Rehnquist (who didn’t attend the oral argument), and Justices Antonin Scalia and Anthony Kennedy. Justices Sandra O’Connor and Stephen Breyer agreed that the law is constitutional, but refused to co-sign parts of the Thomas opinion. Therefore, much of the majority opinion is really a minority opinion, leaving the law on political party freedom of association in a confused state.
Ballot Access
Three justices wrote opinions. The Thomas opinion says nothing about ballot access, nor does it say anything about the role that minor parties play, nor about the two-party system.
O’Connor wrote very good language about how courts should respond when hearing an election law case brought by minor parties. Part of the O’Connor opinion was co-signed by Breyer, and part wasn’t. The parts of the O’Connor that Breyer co-signed say: "Although the State has a role to play in regulating elections, it is not a wholly independent or neutral arbiter. Rather, the State is itself controlled by the political party or parties in power, which presumably have an incentive to shape the rules of the electoral game to their own benefit…
"As such restrictions become more severe, and particularly where they have discriminatory effects, there is increasing cause for concern that those in power may be using electoral rules to erect barriers to electoral competition. In such cases, applying heightened scrutiny helps to ensure that such limitations are truly justified and that the State’s asserted interests are not merely a pretext for exclusionary or anticompetitive restrictions (emphasis added)."
All of Stevens’ dissent was co-signed by Justice Ruth Ginsburg, and three-fourths of it was also co-signed by Justice David Souter. The part of Stevens’ dissent that represents three justices says, "Even if participation in the Libertarian primary causes a voter to be a less committed ‘Democrat’ or ‘Republican’, the dilution of that commitment does not justify abridgment of the fundamental rights at issue. While party identity is important to our system, it should not be immunized from the risk of change. If states were able to protect the incumbent parties in the name of protecting the stability of the two-party system in general, we might still have the Federalists, the Anti-federalists, or the Whigs. In any event, we would not have the evolution of thought or policies that are occasioned through the change of political parties. While no such change has occurred in recent memory, that is no reason to ossify the status quo."
Both O’Connor and Stevens wrote even more supportive statements in the parts of their opinions that did not get as many co-signatures as the parts quoted above. But the statements above are majority sentiment in the U.S. Supreme Court, and they are especially strong given that no justice took issue with them. As noted above, Thomas said nothing about these matters in his opinion.
Law Professor Rick Hasen of Loyola Law School in Los Angeles, who is co-founder of the Election Law Journal and one of the pioneer election law specialists in the nation, wrote on May 23, "The Supreme Court’s decision today in Clingman v Beaver is less significant for its holding (the state may prevent political parties from inviting voters from other political parties to participate in its primary) than for the nuanced differences of opinions among the Justices: reading the opinions together, my first impression is that the case could make it somewhat easier for minor parties to challenge burdensome election laws. The bottom line is that the opinions are an invitation for lower courts to consider challenges by minor parties that state election laws as a whole discriminate against minor parties."
The part of O’Connor’s opinion that has less clout (since Breyer didn’t sign that part) criticizes Oklahoma for its requirement that a party be removed from the ballot if it fails to poll 10% for the office at the top of the ballot (president and governor). This is the first time any Justice of the Court has ever criticized any state’s law on how a party remains on the ballot.
The part of Stevens’ opinion that also had less clout, since it only had Ginsburg’s co-signature, says, "There is over a century of experience demonstrating that the two major parties are fully capable of maintaining their own positions of dominance in the political marketplace without any special assistance from the state governments that they dominate."
Freedom of Association
Ironically, the decision in some ways strengthens the right of political parties to run their own affairs. This is because Stevens and Ginsburg changed their position.
In 2000, Stevens and Ginsburg had been the only justices who had not agreed that political parties have a right to decide for themselves who should vote in their primaries. In California Democratic Party v Jones, seven of the justices said parties cannot be required to let non-members vote in their primaries. Only Stevens and Ginsburg dissented.
But now, those two justices say, "It is no business of the State to tell a political party what its message should be, how it should select its candidates, or how it should form coalitions to ensure electoral success."
Nor does the Thomas opinion make any attacks on the general idea that parties should run their own affairs. The only point of the Thomas decision is that this particular burden on parties and voters is slight.
The Thomas opinion says that states have an interest in closed primaries. This is a sharp deviation from all the political party association cases of the past, which emphasize that the First Amendment association clause protects political party autonomy to decide for themselves what kind of primary to have. And, clearly, the text of the Constitution doesn’t favor any kind of primary; the text just protects freedom of parties to decide. Thomas wrote that there is a state interest in avoiding "primary election outcomes which would tend to confuse or mislead the general voting population to the extent it relies on party labels as representative of certain ideologies."
Thomas also wrote that the law preserves parties as viable and identifiable interest groups; that it is useful for a state to classify voters or candidates according to political affiliations; and that the law helps party-building efforts. He said that the law helps guard against party raiding.
Restrictions on Changing Parties
The Oklahoma Libertarian Party had argued that other state laws make it difficult for voters to register "Libertarian." The party had said this is one reason it wanted to invite all voters to vote in its primary.
When a party goes off the ballot in Oklahoma, all its members are switched to "independent" status against their will. These voters can re-register back into a party that has just gone off the ballot, but this takes a special effort. Furthermore, if the party doesn’t re-qualify for the ballot in the next three years, the state against switches these voters back to "independent" status.
Thomas acknowledged this problem, but said the constitutionality of this law is not properly part of the case. O’Connor also wrote about this point, and suggested that the Oklahoma laws on voter registration are unreasonable, but she agreed that only a new lawsuit can reach this issue.
The Oklahoma Libertarian Party is pursing a state lawsuit against the ballot access laws, and chances for that lawsuit appear good, partly because of the Clingman decision, and also because Oklahoma was the only state in which it was impossible for anyone to vote for anyone for president last year except Bush and Kerry.
To read the whole Clingman decision, visit Ballot-Access.org and use the link in the May 23 story.
Since the May 1 B.A.N., bills in six states to improve ballot access have made headway:
Alaska: HB 94 passed the legislature’s special session on May 15. However, the only ballot access improvement it makes is to provide for independent presidential candidates. In the past, independent presidential candidates were forced to create new parties to get on the Alaska ballot. Now Arkansas is the only state with no procedures for independent presidential candidates.
Unfortunately, the part of the bill that made it easier for a party to remain on the ballot was deleted.
Connecticut: SB 1233, which sets up a procedure for a group to transform itself into a qualified party in advance of any election, passed another committee on April 28, and is now set for a floor vote in the Senate.
Florida: HB 1567, which defines "national political party" to be a party on the ballot in at least one state besides Florida, passed on May 6. Such parties can get on the ballot for president with no petition and no fee, if they hold a national convention. Although the bill maintains the same easy requirement as before, the old law was so vague that the Reform Party’s position on the ballot had been attacked in court.
Georgia: HB 244, which was signed into law on April 22, says that party labels are permitted in special partisan elections. In the past, all special elections just listed candidates, with no labels. As before, in special elections, anyone can get on the ballot just by paying a filing fee; no petition is needed.
Missouri: HB 525, which gives new parties more flexibility to decide whether to run a presidential candidate, passed on May 12.
West Virginia: SB 669 was signed into law on April 16. It removes obsolete language saying petition circulators must tell potential signers that if they sign, they won’t be able to vote in the primary.
On May 23, HF 1481 passed the Minnsota legislature. It makes it somewhat easier for a group to attain "qualified party" status. Currently, a party is a group that polled 5% for any statewide race at either of the last two elections, or which submits a petition of 5% of the last vote cast.
The bill adds a third method: any group that runs at least 45 candidates for Representative, and 23 for State Senate, and 4 for U.S. House, and one statewide candidate, in a gubernatorial year, is then a qualified party for the next four years.
Running that many candidates under the independent procedures would take 40,000 signatures.
Another part of the bill requires presidential electors to vote for their own party’s presidential nominee, and if they don’t, they are deemed disqualified.
Many lawsuits involving the interests of minor parties and/or independent candidates are pending. Here is a list of most of them.
Alabama: Swanson v Bennett, 02-644, the oldest pending ballot access case, is still awaiting a decision from U.S. District Court in Montgomery on the constitutionality of the June petition deadline (for minor parties and non-presidential independent candidates). The legislature had changed it in 2002 from July to June.
Alaska: Green Party of Alaska v State, 3AN-03-9936, a case concerning the definition of "party," is being appealed to the State Supreme Court by the Green Party.
Alaska (2): Green Party of Alaska v State, S11272, over whether two or more political parties can jointly demand a blanket primary for themselves, is pending in the Alaska Supreme Court.
Arizona: Arizona Libertarian Party v Brewer, 02-144-TUC, is in U.S. District Court. The issue is whether a party may demand a closed primary for itself, for public office. State law tells parties that they must let independents vote in each party’s primary.
Arizona (2): Nader v Brewer, 04-1699-PHX, is in U.S. District Court. It challenges the early June petition deadline for independent presidential candidates, and the law making it illegal for out-of-staters to circulate.
Hawaii: Nader v Yoshina, 04-611, is in U.S. District Court and concerns the way the state checks petition signatures.
Illinois: Lee v Keith, 04-3042, is in U.S. District Court in Springfield. It challenges the 10% petition for independent candidates for the legislature. Also it challenges the December (of the year before the election) petition deadline.
Massachusetts: White v Galvin, 04-427, Plymouth, is in state court. It challenges the law that incumbents are always first on the ballot. No other state has such a law.
New Hampshire: Akins v Secretary of State, 04-E-360, Merrimack Co., has just had a trial. It challenges the law that the party with the most registrations always gets the best spot on the ballot. This has been the Republican Party for over 40 years. It also challenges using alphabetical order to list candidates in multi-member districts, within the party column.
New Hampshire (2): Libertarian Party of N.H. v Gardner, 05-E-0004, Merrimack, challenges the state’s ballot access laws for minor party and independent candidates, and the definition of "political party."
Ohio: Libertarian Party of Ohio v Blackwell, 04-4215, will be heard in the 6th circuit in July. It challenges the November (of the year before the election) deadline to place a new party on the ballot. It also challenges the validity of disqualifying the party’s 2004 petition because of slight differences in the format of the petition that was used, compared to a new one promulgated in the middle of the petition drive.
Ohio (2): Lawrence v Blackwell, 04-4022, will also receive a hearing in the 6th circuit in July. The issue is the March deadline for independent non-presidential petitions.
Ohio (3): Blankenship v Blackwell, 04-4259, is the third ballot access case that will have oral arguments in the 6th circuit this summer. The issue is whether out-of-staters may circulate an independent presidential candidate petition. This is a Nader case.
Oklahoma: Libertarian Political Organization v Clingman, 2004-2949, the ballot access case, will have a hearing this fall in state court.
Oregon: Prete v Bradbury, 04-35285, will have a hearing in the 9th circuit in July. The issue is whether a state can ban paying circulators per signature.
Pennsylvania: the State Supreme Court will hear a case over whether or not Ralph Nader must pay attorney’s fees for the people who successfully challenged his petition last year. Serody v Nader, 17 MAP 2005. The lower court said he must pay $81,000.
Washington: Washington State Republican Party v Logan, 05-927-Z, U.S. District Court in Seattle, attacks the "top-two" primary.
West Virginia: McClure v Manchin, 04-2197, is pending in lower state court. It attacks the petition deadline for minor party and independent candidates (for office other than president) of May.
national: Initiative & Referendum Institute v US Postal Service, 04-5045, will have a decision out soon from the US Court of Appeals, D.C. circuit.
national (2): Hagelin v FEC, 04-5312, had a hearing in the U.S. Court of Appeals, D.C. circuit, on May 9, before Judges Harry Edwards (Clinton appointee), Karen Henderson (Bush Sr.), and David Tatel (Clinton). The issue is whether the FEC must investigate the Commission on Presidential Debates. All three judges were very active questioners and obviously interested in the case.
national (3): FEC v Reform Party, 1:04cv79, is pending in U.S. District Court in the Northern District of Florida, Tallahassee. The FEC is attempting to recover several hundred thousand dollars that it says the Reform Party owes the government.
On May 17, the Oregon House passed HB2614, which makes it illegal for voters who are registered members of a party to sign a petition for an independent candidate. A similar Arizona law was held unconstitutional in 1999, and it required only 7,000 signatures; Oregon requires over 18,000. The Senate Rules Committee hasn’t set a hearing date yet, but in the meantime activists are working hard to rally opposition.
Florida’s HB 1471 failed to pass the Senate, and the legislature has now gone home. It would have required signers to include their birthday, or their voter registration number, on the petition. Also it would have outlawed paying circulators per signature, either "directly" or "indirectly."
The March 1 B.A.N. compared the states on how easy it is for minor party and independent presidential candidates to get on the ballot. The April 1 B.A.N. compared the states on how easy it is for a group to be a qualified party. The May 1 chart compares them on how easy it is for a new party to get a full slate of U.S. House candidates on the November ballot. This chart compares the states for access in U.S. Senate and gubernatorial elections, for independent and minor party candidates.
The chart in the middle column tells the average number of candidates on the November ballot for Governor and U.S. Senator in each state (including the Democratic and Republican nominees), for the period 1980-2004. The states are ordered with the most lenient at the top, and the most restrictive at the bottom. Arkansas, New Mexico and Maryland have offered voters the fewest choices for Governor and U.S. Senator. However, Maryland drastically improved ballot access in 1998 and again in 2003, so its future ranking will surely improve.
The nationwide average for U.S. Senate and gubernatorial elections is 3.73 candidates on the ballot. This contrasts to 2.60 candidates on the ballot in the average U.S. House race, and 4.10 candidates on the ballot in the average presidential race.
The chart in the right column shows the percentage of signatures (or, in Delaware, the number of registrants) for a new party or independent candidate for U.S. Senator or Governor to get on the November ballot. The easiest method in each state is used. "Easiest" means the procedure used most often. "Percentage" shows the number of signatures (or registrants, or votes in a primary) needed, divided by the number of registered voters. Washington is the worst, since candidates need approximately 30% support from the voters (measured by primary votes) in order to get on the November ballot. This is because the voters passed the "top-two" initiative last year.
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|||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
| STATE |
|
|
|
|||||
|
|
|
|
|
|
|
|
||
|
Alabama |
41,012 |
41,012 |
1,200 |
0 |
0 |
0 |
0 |
in court |
|
Alaska |
(reg) 9,258 |
#3,128 |
already on |
in court |
0 |
0 |
0 |
Aug. 22 |
|
Ariz. |
26,835 |
est. #20,000 |
already on |
0 |
0 |
0 |
0 |
June 14 |
|
Arkansas |
10,000 |
10,000 |
*200 |
0 |
0 |
0 |
0 |
May 1 |
|
Calif. |
(reg) 77,389 |
165,573 |
already on |
already on |
already on |
already on |
39,328 |
Aug. 11 |
|
Colorado |
(reg) 1,000 |
#1,000 |
already on |
already on |
already on |
534 |
337 |
July 10 |
|
Connecticut |
no procedure |
#7,500 |
already on |
0 |
already on |
0 |
0 |
Aug. 11 |
|
Delaware |
est. (reg) 280 |
est. 5,600 |
already on |
already on |
already on |
257 |
211 |
July 15 |
|
D.C. |
no procedure |
est. #3,800 |
can't start |
already on |
can't start |
can't start |
can't start |
Aug. 30 |
|
Florida |
be organized |
pay fee |
already on |
already on |
already on |
already on |
already on |
July 18 |
|
Georgia |
42,676 |
#42,676 |
already on |
0 |
0 |
0 |
0 |
July 11 |
|
Hawaii |
648 |
25 |
already on |
already on |
0 |
already on |
0 |
July 25 |
|
Idaho |
11,968 |
5,984 |
already on |
0 |
already on |
already on |
0 |
Aug. 31 |
|
Illinois |
no procedure |
#25,000 |
can't start |
can't start |
can't start |
can't start |
can't start |
June 26 |
|
Indiana |
no procedure |
#29,553 |
already on |
*3,000 |
0 |
0 |
0 |
June 30 |
|
Iowa |
no procedure |
#1,500 |
0 |
0 |
0 |
0 |
0 |
Aug. 18 |
|
Kansas |
16,477 |
5,000 |
already on |
0 |
0 |
0 |
already on |
July 31 |
|
Kentucky |
no procedure |
#2,400 |
0 |
0 |
0 |
0 |
0 |
Aug. 8 |
|
La. |
(reg) 1,000 |
pay fee |
already on |
*virtual on |
*47 |
*20 |
virtually on |
Sep. 7 |
|
Maine |
24,798 |
#4,000 |
0 |
already on |
0 |
0 |
0 |
May 25 |
|
Maryland |
10,000 |
est. 29,400 |
already on |
already on |
already on |
0 |
0 |
Aug. 7 |
|
Mass. |
est. (reg) 41,000 |
#10,000 |
23,900 |
9,509 |
56 |
44 |
1,168 |
Aug. 1 |
|
Michigan |
31,731 |
31,731 |
already on |
already on |
already on |
already on |
0 |
July 20 |
|
Minnesota |
141,420 |
#2,000 |
0 |
0 |
0 |
0 |
0 |
July 18 |
|
Mississippi |
be organized |
1,000 |
already on |
already on |
already on |
already on |
already on |
April 7 |
|
Missouri |
10,000 |
10,000 |
already on |
0 |
0 |
0 |
0 |
July 31 |
|
Montana |
5,000 |
#5,000 |
already on |
0 |
*500 |
0 |
0 |
May 30 |
|
Nebraska |
4,735 |
2,500 |
300 |
*3,300 |
0 |
0 |
0 |
Aug. 29 |
|
Nevada |
7,915 |
7,915 |
already on |
0 |
already on |
0 |
0 |
July 7 |
|
New Hamp. |
20,299 |
#3,000 |
0 |
0 |
0 |
0 |
0 |
Aug. 9 |
|
New Jersey |
no procedure |
#800 |
0 |
0 |
0 |
0 |
0 |
June 6 |
|
New Mex. |
3,782 |
14,079 |
already on |
already on |
already on |
0 |
0 |
July 11 |
|
New York |
no procedure |
#15,000 |
can't start |
can't start |
can't start |
can't start |
can't start |
Aug. 22 |
|
No. Car. |
69,734 |
law is void |
*25,200 |
8,900 |
0 |
0 |
0 |
June 30 |
|
No. Dakota |
7,000 |
1,000 |
0 |
0 |
0 |
0 |
0 |
Sep. 8 |
|
Ohio |
56,280 |
5,000 |
in court |
0 |
0 |
0 |
0 |
May 1 |
|
Oklahoma |
73,188 |
pay fee |
in court |
0 |
0 |
0 |
0 |
June 21 |
|
Oregon |
18,381 |
18,356 |
already on |
already on |
already on |
0 |
0 |
Aug. 29 |
|
Penn. |
no procedure |
*66,827 |
can't start |
can't start |
can't start |
can't start |
can't start |
Aug. 1 |
|
Rhode Isl. |
21,815 |
#1,000 |
can't start |
can’t start |
can't start |
can't start |
can't start |
July 20 |
|
So. Caro. |
10,000 |
10,000 |
already on |
already on |
already on |
0 |
already on |
July 15 |
|
So. Dakota |
8,364 |
#3,346 |
already on |
0 |
already on |
0 |
0 |
June 20 |
|
Tennessee |
41,314 |
25 |
0 |
0 |
0 |
0 |
0 |
April 6 |
|
Texas |
45,253 |
45,253 |
already on |
can't start |
can't start |
can't start |
can't start |
May 11 |
|
Utah |
2,000 |
#1,000 |
already on |
*1,000 |
already on |
0 |
0 |
Mar. 17 |
|
Vermont |
be organized |
#1,000 |
already on |
already on |
0 |
0 |
0 |
Sep. 21 |
|
Virginia |
no procedure |
#10,000 |
can't start |
can't start |
can't start |
can't start |
can't start |
June 13 |
|
Washington |
no procedure |
law is unclear |
can’t start |
can't start |
can't start |
can't start |
can't start |
July 7 |
|
West Va. |
no procedure |
#8,724 |
0 |
0 |
0 |
0 |
0 |
May 8 |
|
Wisconsin |
10,000 |
#2,000 |
already on |
already on |
already on |
0 |
0 |
July 11 |
|
Wyoming |
4,774 |
4,774 |
already on |
0 |
0 |
0 |
0 |
Aug. 28 |
|
TOTAL STATES ON |
28
|
15
|
16
|
6
|
4
|
- | ||
Three states (Ky., La.,
N.C.) have no statewide partisan races up in 2006, so the chart shows the
requirements for a party to run a full slate for U.S. House.
*means a change since the Apr. 1, 2005 chart.
#means partisan label is permitted (other than "indp.").
The chairman of the Texas Libertarian Party, Patrick Dixon, was elected to the city council of Lago Vista on May 7. The election was non-partisan.
David Owens, Libertarian Party candidate for Township Supervisor in London Britain Township, Chester County, Pennsylvania, this coming November, won the Republican nomination for that office as well on May 17, by write-in votes. He will appear on the ballot in November as "Libertarian, Republican." He has one opponent, a Democrat.
Pennsylvania held an election on May 17 for State Senate, 42nd district. The vote was Dem. 55.3%, Rep. 37.4%, Libertarian 7.3%. In November 2002 (the last time this seat was up) the vote had been Dem. 72.3%, Rep. 27.7%.
Missouri held a special election for the 22nd State Senate district on April 5, 2005. The results: Republican 30.15%; Democratic 29.83%; independent 27.52%; another independent 12.50%. The independent who placed 3rd was himself a Democratic member of the House.
Ohio will hold an election to fill the vacancy in the 2nd congressional district on August 2. Only the Democratic and Republican Parties are qualified in Ohio, so any other party must use the independent candidate procedure. It requires 3,168 signatures by June 13. So far, this is only the second congressional special election in the nation this year.
On September 24, 2004, the C.W. Mining Company, which owns a coalmine in Utah, sued The Militant, newspaper of the Socialist Workers Party, for defamation. The company also sued all 22 employees of The Militant, which includes Roger Calero, the party’s presidential nominee last year. The company doesn’t like the newspaper’s reporting of a labor dispute between the company and the United Mine Workers Union. The case is pending in federal court.
A poll in Vermont shows Bernie Sanders with a big lead for the U.S. Senate next year. If Sanders wins, he will be the first non-major party nominee since 1976 to win a U.S. Senate election. The poll, released May 10, showed Sanders defeating Republican Lieutenant Governor Brian Dubie 59% to 23%. With another Republican opponent listed, businessman Richard Tarrant, the results are: Sanders 62%, Tarrant 18%.
No prominent Democrat is expected to run. However, Democratic Party officials want Sanders to ask the Progressive Party not to run for the U.S. House seat, and also not to run for the Lieutenant Governorship, next year. The Progressive Party wants to run David Zimmerman for U.S. House and Anthony Pollina for Lieutenant Governor.
A group of Green Party activists have formed Greens for Democracy. The web page is Greens4Democracy.net. The group is dissatisfied with the formula that the national Green Party has been using to determine how many delegates each state sends to national conventions. The current formula, which is the norm for major parties and many minor parties as well, is essentially based on state population, with bonuses for states in which the party is unusually successful (relative to votes for the party, or the number of office-holders it has). Greens for Democracy would rather use a formula that is based on party membership in each state, however each state party defines "member."
Greens for Democracy also wants the presidential delegate process altered so that the delegation sent by a state is more strictly proportional to the vote within that state for a choice of presidential nominee.
Finally, the group wants the national party to adopt a resolution that no state Green Party will endorse, cross-endorse, or otherwise support any major party nominee.
The group’s goals have received formal support from the California, New York, and Vermont Green Parties so far this year, and partial support from the Florida party.
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