MINOR PARTY AND INDEPENDENT VOTE FOR TOP OFFICES IS 2^nd BEST MID-TERM RESULT SINCE 1934

In November 2006, 5.0% of the vote for the top office on the ballot went to minor party and independent candidates. This is the second-best showing in a mid-term election for "other" since 1934. The "other" vote was 5.3% in 2002.

"Top office" is Governor, in the 36 states that elected a Governor. In the others, it is U.S. Senate. In Kentucky, Louisiana, and North Carolina, which had no partisan statewide elections, it is U.S. House. "Other" does not include votes cast for minor party nominees who were also major party nominees. "Other" also does not include "None of the Above" in Nevada, nor does it include write-ins.

Using the same rules for previous mid-term years gives these results:

1998	4.9%
1994	4.5%
1990	4.6%
1986	3.6%
1982	1.8%
1978	2.4%
1974	2.4%
1970	3.4%
1966	3.2%
1962	1.1%
1958	.9%
1954	.6%
1950	1.1%
1946	1.4%
1942	4.8%
1938	3.8%
1934	5.6%
1930	6.1%
1926	4.5%
1922	4.2%
1918	6.8%
1914	16.3%

The "other" vote in 1914 was high because there were three strong minor parties that year. The Progressive Party received 10%, the Socialist Party 4%, and the Prohibition Party 2%. They each elected at least one member to Congress that year.

Many states still haven’t released official vote tallies. Using a combination of official and unofficial tallies from all states, these are the totals so far for each party for the "top" office: Democratic 40,264,560 (49.28%); Republican 37,379,872 (45.75%); independent 1,797,050 (2.20%); Green 949,185 (1.16%); Libertarian 778,395 (.95%); Constitution 193,063 (.24%); Reform 97,677 (.12%), other parties 245,289 (.30%). See the vote by state and the breakdown of the other parties below.

	Dem.	Repub.	Green	Lib’t.	Constit.	Reform	oth(1)	oth(2)	Independent
Alab.	518,750	717,287	`	?	`	`	`	`	`
Alas.	96,824	114,204	586	680	`	`	1,265	`	22,418
Ariz.	959,830	543,528	`	30,268	`	`	`	`	`
Ark.	421,051	309,996	13,068	`	`	`	`	`	15,913
Cal.	3,223,705	4,640,102	192,997	109,293	58,692	`	65,912	`	`
Colo.	779,741	566,303	`	20,527	8,705	`	`	`	9,629
Conn.	398,220	709,849	9,583		5,560
Del	170,567	69,734	`	2,671	`	`	`	`	`
Fla.	2,178,289	2,519,845	`	15,987	`	92,595	`	`	22,407
Ga.	811,049	1,229,724	`	81,412	`	`	`	`	`
Hi.	121,709	215,280	5,433	1,849	`	`	`	`	`
Ida.	198,845	237,437	`	7,241	7,309	`	`	`	`
Ill.	1,677,497	1,332,755	349,128	?	?	`	`	`	`
Ind.	`	1,171,596	`	168,828	`	`	`	`	`
Iowa	565,657	466,757	7,722	5,621	`	`	1,957	`	`
Kan.	480,532	336,583	`	8,652	`	5,082	`	`	`
Ky.	597,572	606,307	`	39,256	774	`	`	`	`
La.	295,762	579,702	`	25,772	1,262	`	`	`	`
Me.	206,753	164,514	52,059	`	`	`	`	`	120,422
Md.	942,374	825,634	15,554	`	`	`	3,481	`	`
Mass.	1,230,065	779,807	43,032	`	`	`	`	`	154,012
Mich.	2,142,589	1,609,182	20,016	23,508	7,084	`	`	`	`
Minn.	1,007,461	1,028,568	10,850	`	`	`	141,735	`	13,425
Miss.	205,786	375,836	`	9,106	`	`	`	`	`
Mo.	1,048,301	1,002,007	18,292	48,133	`	`	`	`	`
Mont.	198,897	196,061	10,367	`	`	`	`	`	`
Nebr.	144,624	434,802	`	`	8,894	`	`	`	3,740
Nev.	255,684	279,003	6,753	`	20,019	`	`	`	`
N.H	298,677	104,223	`	116	`	`	`	`	`
N.J.	1,163,381	974,525	`	14,340	`	`	3,348	2,452	29,943
N.M.	384,516	174,253	`	`	`	`	`	`	`
N.Y.	2,856,027	1,200,226	40,346	14,799	`	`	7,062	`	13,712
No.C.	1,026,915	913,893	`	`	`	`	`	`	`
No.D.	150,146	64,417	`	2,194	`	`	`	`	1,395
Ohio	2,312,735	1,411,678	38,771	68,163	`	`	`	`	`
Okla.	616,135	310,327	`	`	`	`	`	`	`
Ore.	698,561	588,155	19,978	16,751	50,103	`	`	`	`
Pa.	2,345,082	1,652,486	?	?	?	`	`	`	`
R.I.	182,350	188,773	`	`	`	`	`	`	`
So.C.	489,084	601,871	`	`	`	`	`	`	`
So.D.	121,242	207,000	`	3,286	4,006	`	`	`	`
Tenn.	1,241,606	538,508	2,681	`	`	`	`	`	27,345
Tex.	1,309,774	1,714,618	`	26,726	`	`	`	`	1,342,759
Utah	169,421	344,541	2,374	4,210	20,655	`	8,965		`
Vt.	108,090	148,014	1,936				638		3,693
Va.	1,175,606	1,166,277	26,102	`	`	`	`	`	`
Wa.	1,170,988	826,296	20,699	29,006	`	`	`	`	16,237
W.V.	293,848	153,013	`	`	`	`	8,474	`	`
Wis.	1,136,726	976,275	40,858	`	`	`	`	`	`
Wyo.	135,516	58,100	`	`	`	`	`	`	`

Parties in the "Other (1)" column are: Alaskan Independence; Peace & Freedom (Ca.); Socialist Workers (Iowa, N.J, N.Y.); Populist (Md.); Independence (Mn.); Personal Choice (Ut.); Liberty Union (Vt.); Mountain (W.V.). The party in the "Other(2)" column is Socialist.

On October 30, U.S. District Court Judge James Whittemore, a Clinton appointee, issued an order requiring that WFLA-TV (sponsor of the Florida gubernatorial debate set for that night) admit Max Linn, the Reform Party nominee. Linn v Media Group Corp., 8:06-cv-2005. The court convened at 4:30 p.m., and the judge issued his ruling at 5 p.m. The debate started at 7 p.m. Chris Matthews was the debate moderator, and he seemed to take the transformation of the debate from a 2-way to a 3-way event with equanimity.

The basis for the order was that WFLA-TV had said it would admit anyone who was at 7% in polls. Linn had 8.7% in one poll, so this case was about forcing the sponsor to honor a commitment. This case is not a precedent that certain poll thresholds are too high.

This case was in federal court because WFLA-TV lawyers had transferred it there. The original case had been filed in state court. This case should not be confused with a similar Max Linn lawsuit filed to get into the debate of October 24. In that earlier case, Linn won in lower court but the next day a State Appeals Court had reversed his victory.

On November 7, voters passed Instant-Runoff in all four jurisdictions that were voting on it. Oakland, California, passed it with 69%. Minneapolis passed it by 65%.

In Davis, California, voters passed Measure L, which provides for Single Transferable Vote for multi-winner elections such as City Council at-large. This is the system used in Cambridge, Massachusetts and the system used in New York city council elections between 1937 and 1949. It is like Instant-Runoff Voting, but since it applies to multi-winner office, it is possible for a group to elect one candidate even if the group is a minority of the electorate.

In Pierce County, Washington, the voters passed IRV for partisan county elections.

In both California and Minnesota, the voters elected a new Secretary of State. In each case, the new Secretary of State had endorsed IRV, wheras the old one had not done so.

Other election reforms were defeated by the voters. Oregon voters refused to amend their Constitution to make campaign contribution limits possible. California voters defeated public funding. Massachusetts voters defeated fusion. Oregon voters defeated legislative term limits. Florida voters weakened the initiative process, by passing a measure that will require all ballot measures in the future to pass with 60% of the vote (ironically, this measure itself received less than 60% of the vote, but since it hadn’t gone into effect yet, it passed). However, Rhode Island voters passed a measure to let ex-felons vote, even if they are still on probation or parole.

On November 3, the three judges in the 3^rd circuit who had upheld Pennsylvania ballot access law retracted their August 23 opinion. They then re-issued the same opinion, with several paragraphs missing. Rogers v Corbett, 06-2241.

The case attacks a law that says even if a party polls enough votes to meet the definition of "party", that it cannot be on the ballot unless it submits 67,070 signatures. The August decision had upheld that law. It said the reward for a group meeting the 2% vote test is that it may show all its nominees on a single petition. By contrast, it said, an unqualified party needs a separate petition for each nominee.

But, the 3^rd circuit was wrong. Pennsylvania also lets unqualified parties list multiple nominees on a single petition. The Constitution, Green and Libertarian Parties had pointed out the error, after the decision had been issued.

The three judges responded by correcting their error, and now the new decision is awaiting a request to all ten full-time judges of the 3^rd circuit to rehear the big issues in the case.

On November 21, the New Hampshire Supreme Court upheld New Hampshire ballot access laws that effect minor parties. Libertarian Party of New Hampshire v State, 2005-606. The Supreme Court also said it had been proper for the lower court to refuse to permit evidence to be submitted in this case.

New Hampshire requires 3,000 signatures for a statewide minor party or independent candidate to appear on the November ballot, 1,500 for U.S. House, 750 for State Senator, and 150 for State House. By contrast, Democrats and Republicans need no signatures to get on primary ballots if they pay a filing fee ranging from $100 to $2. The New Hampshire Constitution says everyone has "an equal right to be elected into office."

The Court said that the "equal right" provision is not violated, because it is as difficult for a major party member to win a primary as it is for the nominee of an unqualified party to submit a petition. This is logically faulty. It fails to consider that it is also difficult for a minor party member to win a minor party convention nomination. Pat Buchanan spent over $1,000,000 to win the Reform Party’s presidential nomination in 2000. It was a difficult struggle for him, since he faced opposition from Ross Perot, who was backing John Hagelin for that nomination.

Also, in New Hampshire this year, there was a 3-way battle for the Libertarian Party’s gubernatorial nomination, and the bitterness from that fight was partly responsible for the party’s failure to obtain the needed 3,000 signatures for its nominee, Richard Kahn.

Since members of all parties (qualified and unqualified alike) face a struggle to win their own party’s nomination, the state is not giving all nominees an "equal right to be elected", since the nominees of the Democratic and Republican Parties are automatically placed on the ballot, but the nominees of other parties are not. The New Hampshire definition of "political party" is so restrictive, it was not met by any party other than the Democratic and Republican Parties during the entire period 1916 to the present, except it was met by the Libertarian Party in 1990, 1992 and 1994.

The New Hampshire Court cited the unfavorable U.S. Supreme Court decisions, but it didn’t mention the favorable ones. Most of the U.S. Supreme Court’s ballot access decisions have been victories for minor parties and independents.

Similarly, there have been reported ballot access wins during the past four months from the 2^nd circuit, the 6^th circuit, the 7^th circuit, and a U.S. District Court in Arkansas. There has also been one reported loss, the 3^rd circuit decision mentioned above. The New Hampshire Court mentioned the 3^rd circuit decision, but did not mention the other four cases.

Worst of all, the New Hampshire Supreme Court mentioned Clingman v Beaver, the latest U.S. Supreme Court opinion to discuss minor parties, but did not mention the language supported by five justices that "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." The New Hampshire Court refused to apply heightened scrutiny.

The New Hampshire decision did not mention any state interest in the petitions, except to quote one sentence from Jenness v Fortson saying the state interest is "avoiding confusion, deception, and even frustration of the democratic process."

As documented in a 2002 article by Richard Winger in the Election Law Journal, the reference to "deception" was a factual error in Jenness. Chief Justice Burger had asserted during oral argument that opponents of U.S. Senator George Norris of Nebraska had qualified an independent candidate also named George Norris. Actually, that dirty trick had been done in a Republican primary, in 1930.

As for "confusion", this is a reference to having too many names on a ballot. But New Hampshire is one of only four states in 2006 that had no minor party or independent candidates on the statewide ballot. Also, New Hampshire’s Secretary of State has said that voters are not confused by the state’s lengthy presidential primary ballots.

On November 22, Ralph Nader asked the U.S. Supreme Court to hear his appeal, against a Pennsylvania State Supreme Court order that he must pay court costs for the challenge procedure in 2004 that took him off the ballot. In Pennsylvania, when a petition is challenged, only state judges can decide whether the challenge is valid. Nader was billed $82,102 in fees for court reporters and handwriting experts. Nader v Serody, 06-696.

On November 17, the Alaska Supreme Court upheld the old definition of "political party". Green Party of Alaska v State, S-11964. The old definition said a party is either a group with registration equal to 3% of the last gubernatorial vote, or which polled 3% for Governor. Greens had argued that the vote for any statewide office, not just Governor, should count. The only statewide races are President, Governor, U.S. Senate, and U.S. House.

It has been common for Alaska Greens to poll over 3% for Congress. In 1996 the Green candidate for U.S. Senate, Jed Whittaker, outpolled the Democratic nominee, 29,037 votes to 23,977 votes. The party has been less successful in gubernatorial races.

In 2004, the legislature made the "party" definition even harder, and the Green Party has another case pending in lower state court against the new definition. The new definition says a party is either a group with registration equal to 3% of the last vote cast, or which polled 3% for one particular statewide race every two years. The particular race in gubernatorial years is Governor; in presidential years, it is U.S. Senate. If no U.S. Senate seat is up in a presidential year, then it is U.S. House.

The Alaska Supreme Court implicitly accepted the state’s argument that the minor party vote is less meaningful in races that are easy wins for the Republican Party over the Democratic Party. It says, "Because the gubernatorial term (unlike federal offices) is limited, there will be non-incumbents running at regular intervals. Consequently, the governor’s race is the only statewide election in which a competitive race may be predicted with some confidence."

Ironically, though, the new law (still under attack in court) contradicts the state’s theory that only the gubernatorial vote is meaningful. This is because, as noted above, the new law requires a party to poll a certain vote for the so-called "less meaningful" races (but only in presidential years).

The decision also said that 20 other states use only the gubernatorial vote, or else use only the gubernatorial and presidential votes. The decision said that these states include Colorado, Georgia, Kansas, Montana, Nebraska, New Mexico, and North Dakota. The Court was factually wrong for all seven of those states (except that one could argue that they were halfway right about Georgia, and that New Mexico is ambiguous). The Court made these factual errors because it relied in inaccurate evidence submitted by the state. Steps are being taken to correct these errors.

On August 17, 2006, the New Hampshire Supreme Court ruled that the state Constitution requires that all parties, and all candidates, have an equal chance to get the best spot on ballots (see the September 1 B.A.N. for more detail). This decision (Akins v Sec. of State, 904 A.2d 702) has triggered a new interest in this issue, nationwide.

On November 4, the New York Times carried an op-ed, "In the Voting Booth, Bias Starts at the Top." The author, Jon Krosnick, is a professor of communication and political science at Stanford. He argues that candidates and parties listed on the top line get a significant, if small, advantage, and that fairness demands that all candidates and all parties enjoy an equal opportunity to appear first.

Since then, several other major newspapers have written articles on this subject. For example, The Courier-Journal of Louisville, Kentucky, carried a lengthy article on November 18 titled, "Being First on Ballot Has Advantages."

In 1978, the 7^th circuit ruled that the U.S. Constitution requires that all parties have an equal chance for the best spot on the ballot, but in 1979 that circuit said that principle only applies to qualified parties. In 1980 the 8^th circuit also ruled that the Constitution requires that all parties have an equal chance for the top line, and made no exceptions.

This area of the law has long been dormant, but is about to revive. A lawsuit is currently pending in federal court against Maryland’s law mandating alphabetical order of candidates (Schaefer v Lamone). Another lawsuit is pending in state court against Massachusetts’ policy of listing incumbents first (White v Galvin).

Voter turnout in November 2006 was 39.7% of the eligible electorate ("eligible electorate" means registered voters plus people eligible to register). Although low, this was significantly higher than in 2002, when turnout was only 36%. Since ballot access requirements (in many states) for 2008 are calculated as a percentage of the number of votes cast in 2006, the higher turnout means more signatures will be needed in 2008.

Although it is not possible to know exactly how many signatures will be needed in 2008 for a new party or independent presidential candidate, the number will be close to 690,000. This assumes that the candidate is pragmatic, and uses the easier method (either new party or independent candidate) in each state. That compares to 634,727 in 2004. "Easier" means the method used most often, not necessarily the method with the lowest number. Thus, the "easier" method in California is the independent petition of 158,372 signatures, not the new party method of approximately 85,000 registrations.

This month is an ideal time to find a legislator to introduce bills in 2007 sessions of the legislature. Many legislatures restrict the number of bills that any legislator may introduce. If one waits, one is likely to be told, "Sorry, I already have as many bills as I am able to introduce." Even though state legislatures won’t come into session until early January, bills are often filed before the session begins. Hundreds of bills have already been filed in Texas.

STATE	REQUIREMENTS		SIGNATURES COLLECTED					DEADLINE
	FULL PARTY	CAND	LIB'T	GREEN	CONSTI	WK FAM	REFORM
Alabama	est. 38,000	5,000	0	0	0	0	0	Sep. 8
Alaska	(reg) 7,080	#3,128	already on	3,620	0	0	0	Aug. 6
Ariz.	20,449	est. #21,500	already on	500	0	0	0	June 11
Arkansas	10,000	#1,000	0	0	0	0	0	Aug. 4
Calif.	est. (reg) 85,000	158,372	already on	already on	already on	0	31,897	Aug. 8
Colorado	(reg) 1,000	#1,000	already on	already on	already on	0	273	June 17
Conn.	no procedure	#7,500	can’t start	can’t start	can’t start	can’t start	can’t start	Aug. 6
Delaware	est. (reg) 290	est. 5,800	already on	already on	already on	already on	182	July 15
D.C.	no procedure	est. #3,900	can’t start	already on	can’t start	can’t start	can’t start	Aug. 19
Florida	be organized	104,334	already on	already on	already on	0	already on	Sep. 2
Georgia	44,089	#42,489	already on	can’t start	can’t start	can’t start	can’t start	July 8
Hawaii	663	4,291	already on	already on	0	0	0	Sep. 5
Idaho	11,968	5,984	already on	can’t start	already on	can’t start	can’t start	Aug. 29
Illinois	no procedure	#25,000	can’t start	already on	can’t start	can’t start	can’t start	June 26
Indiana	no procedure	est. #32,200	already on	0	0	0	0	June 23
Iowa	no procedure	#1,500	0	0	0	0	0	Aug. 15
Kansas	est. 16,900	5,000	already on	0	0	0	already on	Aug. 4
Kentucky	no procedure	#5,000	can’t start	can’t start	can’t start	can’t start	can’t start	Sep. 2
La.	(reg) 1,000	pay fee	already on	already on	47	0	already on	Sep. 2
Maine	est. 27,300	#4,000	0	already on	0	0	0	Aug 15
Maryland	10,000	est. 32,500	3,000	finished	0	0	0	Aug. 4
Mass.	est. (reg) 40,500	#10,000	19,253	already on	65	already on	745	July 29
Michigan	38,024	38,024	already on	already on	already on	0	0	July 17
Minnesota	110,150	#2,000	0	0	0	0	0	Sep. 9
Mississippi	be organized	1,000	already on	already on	already on	0	already on	Sep. 5
Missouri	10,000	10,000	already on	0	0	0	0	July 29
Montana	5,000	#5,000	already on	0	already on	0	0	July 30
Nebraska	5,921	2,500	6,700	already on	already on	0	0	Aug. 26
Nevada	5,746	5,746	already on	already on	already on	0	0	July 3
New Hamp	12,106	#3,000	0	0	0	0	0	Aug. 6
New Jersey	no procedure	#800	0	0	0	0	0	July 28
New Mex.	2,794	16,764	already on	already on	unclear	0	0	June 4
New York	no procedure	#15,000	can't start	can't start	can't start	already on	can't start	Aug. 19
No. Car.	69,734	69,734	in court	0	0	0	0	June 12
No. Dakota	7,000	#4,000	finished	0	finished	0	0	Sep. 5
Ohio	law is void	5,000	0	0	0	0	0	Aug. 21
Oklahoma	46,324	43,913	in court	0	0	0	0	July 15
Oregon	20,640	18,356	already on	already on	already on	already on	0	Aug. 26
Penn.	no procedure	est. #27,000	in court	in court	in court	can’t start	can’t start	Aug. 1
Rhode Isl.	18,557	#1,000	can’t start	can’t start	can’t start	can’t start	can’t start	Sep. 5
So. Caro.	10,000	10,000	already on	already on	already on	already on	0	July 15
So. Dakota	8,389	#3,356	0	0	0	0	0	Aug. 5
Tennessee	45,254	25	0	0	0	0	0	Aug. 21
Texas	est. 44,000	74,108	already on	can’t start	can’t start	can’t start	can’t start	May 27
Utah	2,000	#1,000	0	0	already on	0	0	Sep. 2
Vermont	be organized	#1,000	already on	already on	0	0	0	Sep. 12
Virginia	no procedure	#10,000	can’t start	can’t start	can’t start	can’t start	can’t start	Aug. 22
Wash.	no procedure	#1,000	can’t start	can’t start	can’t start	can’t start	can’t start	July 26
West Va.	no procedure	#15,118	0	0	0	0	0	Aug. 1
Wisconsin	10,000	#2,000	already on	already on	can’t start	can’t start	can’t start	Sep. 2
Wyoming	3,868	3,868	already on	can’t start	can’t start	can’t start	can’t start	Aug. 25
TOTAL STATES			24	19	13	5	4	`

#Partisan label is permitted (other than "indp.").
"Deadline" is procedure with latest deadline.
"Wk Fam" = "Working Families Party".
"Consti" = Constitution Party.
"Lib’t" = Libertarian Party.

Seven minor party nominees were elected to state legislatures on November 7, 2006: the Vermont Progressive Party elected six, and the Constitution Party elected one in Montana. No Greens or Libertarians were elected, although in Maine, three Greens were within a few hundred votes of winning. John Eder (who had been elected as a Green in 2002 and 2004) was defeated for re-election in a two-person race with 48.5% of the vote. Also in Maine, two Greens outpolled Republican nominees, but lost to Democrats. In Vermont, one Libertarian who also had the Republican nomination polled 43.6% of the vote.

The Indiana Libertarian Party won two partisan elections for Township Supervisors (one in Henry County and one in Wayne County). The Nevada Constitution Party won a two-party race for Eureka County Clerk-Treasurer, as well as a two-party race for Constable in Searchlight.

The New Mexico Libertarian Party had hoped to re-elect its County Commissioner, Paul Trujillo, in Valencia County. However, he placed second in a three-party race, outpolling the Republican nominee but losing to the Democratic nominee. Some observers believe that Trujillo would have won, if it had not been for the straight-ticket device. In New Mexico, 50% of the voters usually use it. No party other than the Democratic or Republican Parties has ever won a partisan election in New Mexico.

In non-partisan elections, Greens elected two members to the Portland, Maine city council. A Green was elected Mayor of Richmond, California.

Two independent candidates were elected to the Senate, Joseph Lieberman and Bernie Sanders. This is the first time since 1970 that two candidates who were not major party nominees were elected to the U.S. Senate. Harry F. Byrd was elected as an independent from Virginia in 1970, and James Buckley was elected as a Conservative from New York that year.

The Vermont Senate race was the first U.S. Senate election in U.S. history at which the major party combined vote was less than one-third of the total vote cast for that office.

Doug Friedline died on November 10, at the age of 49, from a heart attack. He had been perhaps the only campaign manager in the nation who made a living representing independent and minor party nominees. He had been manager for Jesse Ventura in 1998, and for Max Linn in Florida this year. He was a much-loved figure.

On November 7, the voters of Greene County, Alabama, elected Ison Thomas sheriff, by write-in votes. He defeated the only ballot-listed candidate by 100 votes.

On September 26, a New York state court dismissed a libel lawsuit that had been filed against the Workers World Party’s newspaper. The paper had published a story alleging that the WCI Steel had underfunded pensions. Renco Group, Inc. v Workers World Party, 102875-06, Manhatten. Justice Edward Lehrner said the article expressed opinion, and is therefore immune from such lawsuits.

The next B.A.N. will have a chart for voter registration in each party in each state, and more election returns.

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