MISSISSIPPI DEMOCRATS WIN AGAINST OPEN PRIMARY
DECISION IS EVEN STRONGER THAN SIMILAR 2006 VIRGINIA DECISION

On June 8, U.S. District Court Judge Allen Pepper, a Clinton appointee, ruled that the Mississippi Democratic Party has a right to prevent outsiders from voting in its primary. Mississippi State Democratic Party v Barbour, 4:06cv29. Mississippi has never had registration by party, so any registered voter in Mississippi has been free to vote in any party’s primary. The state Democratic Party feels that Republicans have been voting in its primaries, and it wants to stop it, so it filed its lawsuit in February 2006, and has now won it, at least at the first level.

The decision is based almost entirely on the U.S. Supreme Court decision of 2000 called California Democratic Party v Jones. In that case, the Supreme Court had said that if a party doesn’t like blanket primaries, it cannot be forced to use them (a blanket primary puts all candidates on the same ballot, and a voter can vote for a Democrat for one office and a Republican for another office). This is the second time that a U.S. District Court somewhere in the U.S. has ruled that open primaries are also unconstitutional, if a party objects. The first was in Virginia, where the Republican Party partially won a similar case last year. That decision is being appealed, and the Mississippi decision will also be appealed.

The judge did not say that the state must create a system in which voters register by party, but it is difficult to imagine how the state can comply with the decision, without it.

The decision also said that future primaries must require voters to show photo ID at the polls. The judge said this is because the party wants a list of people who choose to vote in its primary. However, the Democratic Party objects to this, and on June 15, it asked for a rehearing in the case, on the photo ID issue.

The Democratic Party also asked for a rehearing on the question of when the decision should go into effect. The decision said that it would not go into effect until April 2008, but the party wants it to go into effect for the state office primary of August 2007.

Why These Decisions are Good for Minor Political Parties

Americans who think about political parties are of two schools of thought. Some believe in "responsible" political parties. This means that political ideas represent either ideologies, or particular interest groups, or both. Parties have an attitude about what government policy should be. This viewpoint holds that political parties are carriers of ideas and philosophies. This is the dominant idea of political parties throughout most of the world.

The other school of thought was expressed by Political Scientist Bruce Cain. He wrote, "A system that channels its choices into two pluralistic catch-all parties is just as democratic as one with multiple minor parties, and it is no less respectful of free choice." See "An Ethical Path to Reform", Election Law Journal, p. 137, vol. 4, no. 2 (2005).

The U.S. Supreme Court once seemed to believe in the Cain model of what a party ought to be. In Jenness v Fortson, the 1971 decision that injured ballot access for minor parties, the Court said that Socialist Workers Party members ought to run for office in the Democratic and Republican primaries. Page 440 of the decision says, "Alternative routes are available to getting a name printed on the ballot. The candidate may enter the primary of a political party (at the time, "party" in Georgia was defined as a group that had polled 20% for president in the U.S., or 20% for Governor, so obviously only the Democratic and Republican Parties were "parties").

"The argument that this alternative route is not realistically open to a candidate with unorthodox or ‘radical’ views is hardly valid in light of American political history. Time after time established political parties, at local, state and national levels, have, while retaining their old labels, changed their ideological direction because of the influence and leadership of those with unorthodox or ‘radical’ views."

Thus, the U.S. Supreme Court in 1971 thought it was OK to keep new and minor parties off the ballot, because anyone could run in the major party primaries. But the Court has shifted sharply away from the idea that political parties are "catch-all" organizations open to anyone, regardless of that person’s political ideas. The shift started in 1972, when the Court first upheld the right of the Democratic National Convention to decide for itself which delegates to seat, regardless that the unseated delegates had been elected in a state party primary. Similar decisions followed in 1975 and 1981, giving national party conventions similar rights.

Then, in 1986, the Court first applied similar principles to a state political party, in a Connecticut case. A somewhat similar California case in 1989 upheld the right of state party officers to make endorsements in their own party’s primaries, and to organize themselves as they wished, regardless of state law. In 2000, the Court said that forcing a party to let members of other parties vote in its primary was a severe burden on any party, and that the First Amendment protects parties from such systems.

Thus, any court decision that uses the "responsible" model for what a political party is, is another step away from the type of thinking expressed in Jenness v Fortson.

On June 3, a lower Alaska state court upheld the new definition of "political party." Green Party v State, 3AN-05-10787. The same judge had granted an injunction on February 8, 2006, leaving the Green Party on the ballot through 2006. But now she has said that she must uphold the new definition of party, because in November 2006, the State Supreme Court had upheld the old definition.

The old definition was a group that either polled 3% for Governor, or which had registration of 3% of the last gubernatorial vote. In 2002 the Green Party didn’t meet either test. But since it had polled over 3% for U.S. Senate and U.S. House in 2002, it sued in 2003, arguing that the vote test should apply to any statewide race. While that suit was pending, the legislature changed the definition.

The new definition was passed in 2004. As with the old definition, it has a registration alternative and a vote alternative. The new registration alternative is worse than the old registration alternative. The new registration test is 3% of the last vote cast. Since presidential year turnout is about 35% higher than gubernatorial year turnout, that means the registration test is 35% higher in the two years after a presidential election, than in the two years before a presidential election. For example, 7,124 registrants are required now, but about 9,500 will be needed in 2009.

The new definition’s vote test alternative requires a party to poll 3% every election, not just every gubernatorial election. In presidential years the party must poll 3% for U.S. Senator. If U.S. Senator isn’t on the ballot, then and only then does the U.S. House seat count. In 2004 the Green Party had polled more than 3% for U.S. House, but less than 3% for U.S. Senate, so it filed a new lawsuit against the new definition.

The judge said the new vote test is easier than the old vote test. She said that a new party doesn’t need to wait for a gubernatorial election year, in order to meet the vote test.

However, the new vote test is worse for a party that is formed in a gubernatorial year, and does poll 3% for Governor. Under the old law, that party could relax for 4 years. Under the new law, if it doesn’t meet the registration test, it must worry about passing the vote test every two years.

The decision doesn’t discuss the registration alternative. If, in the future, a party wants to challenge the fact that the registration test alternative irrationally see-saws between 7,000 and 9,500 every two years, that case might win. The Libertarian Party, which never meets the vote test, but which remains on the ballot by always keeping its registration above 7,000, may file such a lawsuit in 2009, when its ballot status will be threatened by the need to suddenly have 9,500 registrants.

On June 21, the Maryland State Court of Appeals ruled that a signature on a statewide petition is valid, even if the signature appears on a petition sheet that was intended for voters in some other county. Nader for President 2004 v Maryland State Board of Elections, no. 76-Sep 2004.

The same court had issued an order in this case in 2004, putting Nader on the ballot, but the court then took 3 years to explain its reasoning. The decision will be helpful in the future, since the state has a Baltimore County that is separate from Baltimore City. In the past, if someone from Baltimore County signed a Baltimore City petition, or vice versa, the signature was invalid. In the future, Maryland statewide petitions will have a higher validity rate.

In 2005, the ACLU filed a lawsuit on behalf of the Iowa Green and Libertarian Parties, so that voters could register as members of those parties. The case is about to be settled. Any unqualified party that submits 850 signatures, and a copy of its Bylaws, and has appeared on the ballot in the last ten years, will be able to have voters register as members, and to obtain a list of those voters.

On June 15, a U.S. District Court Magistrate upheld the Oregon law passed in 2005 that makes it illegal for a primary voter to sign a petition for an independent candidate. Wasson v Bradbury, 06-6205-TC. Some federal cases are assigned to Magistrates, because the Judges have too much work to handle. Since plaintiff Greg Wasson consented to having his case heard by a Magistrate, the decision has the same force as if it had been issued by a Judge.

The Magistrate said that the purpose of the restriction is to keep "spoiler" candidates off the ballot. This is absurd. First, there are no objective standards in advance of any election to know which independent candidate might be a "spoiler." The U.S. Supreme Court had already ruled in 1974 that a candidate’s political views cannot be used to keep him or her off the ballot, and had struck down an Indiana law barring Communists from the ballot. Whether someone is a "spoiler" depends on the political views of the "spoiler", considered in combination with the views of each of the major party nominees. No serious person today would support an election law that evaluates an independent candidate’s political views, to determine whether he or she should be on the ballot.

Also, an independent is more likely to "spoil" the chances of a major party nominee, if the independent has the capacity to poll a large vote. Independents who have virtually no voter appeal are extremely unlikely to "spoil" an election for a major party nominee. But if the state has an interest in keeping "spoilers" off the ballot, this means that the more support the independent has, the greater the state interest in keeping him or her off the ballot. This is just the opposite of U.S. Supreme Court ballot access precedents, which say that states have an interest in keeping candidates with no voter support off the ballot, but that candidates with a modicum of support should be on the ballot.

Wasson will either ask for a rehearing, or appeal to the 9^th circuit.

On June 25, the U.S. Supreme Court ruled that part of the McCain-Feingold Campaign Finance law is unconstitutional, as applied in certain situations. Federal Election Commission v Wisconsin Right to Life, no. 06-969.

In 1974 Congress made it illegal for individuals to give large donations to candidates for federal office, but it remained legal for individuals to give large donations to political parties. However, in 2002, the McCain-Feingold law made it illegal for individuals to give large donations to political parties as well. The U.S. Supreme Court upheld that limit on large donations to parties in 2003, in McConnell v FEC. The rationale was that wealthy individuals could bribe the President, and members of Congress, by saying, "If you do what I want, I’ll give $200,000 to your political party."

The Libertarian Party was a co-plaintiff in the 2003 lawsuit, and argued that this rationale made no sense for new and small parties. In response, the 2003 U.S. Supreme Court decision said, "A nascent or struggling minor party can bring an as-applied challenge if sec. 323(a) prevents it from amassing the resources necessary for effective advocacy."

The McCain-Feingold law also made it illegal for corporations and unions to pay for broadcast ads that mention a candidate for federal office, within two months of an election. The 2003 decision also upheld that law. Furthermore, the 2003 decision didn’t even invite corporations or unions to bring an "as-applied" challenge later.

Nevertheless, Wisconsin Right to Life sued in 2004, saying that even though the McCain-Feingold limits on broadcast ads had been upheld in 2003, it still believed that the law couldn’t possibly be constitutional if the ad merely said, "Contact Senators Feingold and Kohl and tell them to oppose the filibuster." At the time, Senator Feingold was running for re-election, so he could not be named.

On June 25, the U.S. Supreme Court ruled in favor of Wisconsin Right to Life. It said that the law can’t be applied to ads that may reasonably be interpreted as something other than an appeal to vote for or against a specific candidate.

Only Justices Roberts and Alito ruled that way. Justices Scalia, Thomas and Kennedy said the line drawn between ads that clearly ask the voter to vote for or against a certain candidate, and ads that might reasonably be interpreted not to do this, is hopelessly vague and arbitrary, and that ban on broadcast ads should be held unconstitutional, no matter what they say. Justices Souter, Breyer, Ginsburg and Stevens, who were in the minority, wanted to ban the ad.

The fact that five Justices have now ruled against the McCain-Feingold law on an "as-applied" challenge to the ad ban, suggests that a future challenge to the McCain-Feingold ban on large individual donations to minor parties may also succeed.

Colorado: on June 3, SB 83 was signed into law. It lets minor parties nominate anyone they wish, regardless of prior party membership.

Maine: the legislature adjourned for the year without passing LD1799, which eases the definition of "political party." However, the legislative session extends over two years, and the bill is likely to advance next year, since it is sponsored by the Majority Leader of the House.

Missouri: HB894, the bill to require independent candidates to file a declaration of candidacy in March, failed to pass, and the legislature has now adjourned. Unfortunately, SB138 also failed to pass. It would have removed the error in the law that seems to require new parties to list their presidential elector candidates on the party petition. The Constitution Party is circulating its party petition without such electors, and hopes that the Secretary of State will rule that the law has a drafting error and that no such list of electors is really required.

During the last 30 days, bills to move presidential primaries from March to February were signed into law in Alabama, Connecticut and Illinois. Similar bills failed in Rhode Island and Texas, and are unlikely to pass in Pennsylvania.

In the last 30 days, bills to pass the National Popular Vote Plan passed the California Senate, the Illinois Senate, and a New Jersey Senate Committee.

Alabama: HB332, which would have set up procedures for a write-in candidate to file a declaration of write-in candidacy, failed to advance in the Senate, and the legislature has now adjourned.

California: on June 6, the Assembly passed both bills that expand the use of ranked-choice voting, or Instant-Runoff voting. They both have a hearing in the Senate Elections Committee on July 10.

California (2): on June 7, the Assembly passed AB 583. It sets up public funding for a few offices in 2010. It is somewhat discriminatory against minor parties and very discriminatory against independents.

Delaware: HB 177, which bans fusion, has not advanced during the last thirty days.

Illinois: HB 426 was signed on June 20. It eases the deadline for a party to certify its presidential nominee to early September.

Oregon: HB 3040, which would have legalized fusion, failed to pass.

South Carolina: on June 20, S99 was enacted into law. It says that the government will pay for presidential primaries. Under the old system, each party paid for its own primary. The new law only covers parties that polled 5% for president in the last election.

2004	Nader (indp.)	Badnarik (Libt.)	Peroutka (Consti)	Cobb (Green)
2000	Nader (Green)	Buchanan (Reform)	Browne (Libt)	Phillips (Consti)	Hagelin (Nat Law)
1996	Perot (Reform)	Browne (Libt)	Phillips (Consti)	Hagelin (Nat Law)
1992	Perot (indp.)	Marrou (Libt)	Fulani (New Aliance)
1988	Paul (Libt)	Fulani (New Alliance)
1984	Bergland (Libt)	Serrette (New Alliance)
1980	Anderson (indp.)	Clark (Libt)	Commoner (Citizens)	Hall (Communist)
1976	McCarthy (indp.)	MacBride (Libt)	Camejo (Soc Wkrs)	Hall (Communist)	LaRouche (Labor)
1972	Schmitz (American)
1968	Wallace (American)
1964
1960
1956
1952	Hallinan (Prog)	Hass (Soc Labor)
1948	Wallace (Prog)	Thomas (Socialist)	Teichert (Soc Labor)
1944	Thomas (Socialist)	Watson (Prohibition)
1940	Thomas (Socialist)	Babson (Prohibition)
1936	Lemke (Union)	Thomas (Socialist)	Browder (Comm)	Colvin (Prohi)
1932	Thomas (Socialist)	Foster (Communist)	Upshaw (Prohi)	Reynolds (SocLab)
1928	Thomas (Socialist)	Foster (Communist)	Reynolds (Soc Lab)
1924	La Follette (Prog)	Johns (Soc Lab)
1920	Debs (Socialist)	Watkins (Prohibition)
1916	Benson (Socialist)	Hanly (Prohibition)	Reimer (Soc Labor)
1912	Roosevelt (Prog)	Debs (Socialist)	Chafin (Prohibition)	Reimer (SocLabor)
1908	Debs (Socialist)	Chafin (Prohibition)	Hisgen (Indpndence)	Gillhaus (Soc Lab)
1904	Debs (Socialist)	Swallow (Prohibition)	Watson (Peoples)	Corregan (SocLab)
1900	Woolley (Prohibition)	Debs (Socialist)	Barker (Peoples)	Malloney (SocLab)
1896	Palmer (Nat Dem)	Levering (Prohibition)	Matchett (Soc Labor)
1892	Weaver (Peoples)	Bidwell (Prohibition)
1888	Fisk (Prohibition)	Streeter (Union Labor)
1884	Butler (Greenback)	St. John (Prohibition)
1880	Weaver (Greenback)	Dow (Prohibition)
1876	Cooper (Greenback)	Smith (Prohibition)
1872	O’Conor (Labor Ref)
1868
1864
1860	Breckinridge (Sou D)	Bell (Consti Union)
1856	Fillmore (American)

Abbreviations: Comm = Communist; Soc Lab = Socialist Labor; Sou D = Southern Democratic; Nat Dem = National Democratic; Libt = Libertarian; Consti = Constitution; Prog = Progressive; Nat Law = Natural Law. Candidates are listed (from left to right) in order of how many popular votes they received in that particular election.

RocktheDebates.org is a group working for more inclusive general election presidential debates. The strategy is to ask leading Democratic and Republican candidates for president to agree that if they are nominated, they will debate all their general election opponents who are on the ballot in enough states to theoretically win a majority in the Electoral College.

Larry Reinsch, of Iowa, has already been able to ask Hillary Clinton, Barack Obama, and Sam Brownback about this idea. On June 10, in Ames, Clinton said, "Well, I would certainly be open to doing it. I…you know, I might…there might be a couple of people that I would be a little bit reluctant about, but, you know, I am generally open to that. You know in New York we have a lot of parties; we don’t just have the Democratic and Republican Party, we have a lot of other parties. And, you, I believe in…in free and open debate. So, I will certainly consider it. I’m not going to make a 100% commitment, because it’s a hypothetical, and I try to stay away from hypotheticals. But I take your point and I think that it’s a very important one that we need to get as many people involved as possible, and that means having a lot of opinions out there that people can respond to."

On June 19, Reinsch got a response from Barack Obama. At first he thought the question was about primary season debates, which are already very inclusive. Then, when he understood the question is about general election debates, he said, "We don’t have a Parliamentary System; you’re basically not going to get a Libertarian elected president." Reinsch then said, "You know why that is?" Obama said, "Well, because we’ve got a winner-take-all system." Reinsch then said, "No, the biggest problem is because we don’t get to hear about them. If we could hear about them they’d get in the polls." Obama then said, "I taught voting rights, and I’ll tell you what the problem is, part of it is the structure of our democracy."

"When you have a winner-take-all system, then what happens, it’s very hard for third parties to get a foothold. Which is why we never really, even when guys like George Wallace did have a hearing, the worse thing when Ross Perot did have a hearing and had millions of dollars, its still very hard for them to get leverage. But the general point, my general attitude is as many people get a hearing as possible. But what we’ll hear from the networks is…look, its nice, we’re not just setting up a platform for a theoretical debate, we’re choosing the next President…I get your point and I’m sympathetic to it."

On June 24, Reinsch got a response from Sam Brownback while in Roland, Iowa. Brownback said, "I’ve got to think about that, because you’d also have the Prohibitionist candidate. You’ve got…you’d have Ross Perot’s party, you’d have 5 or 6 at least…Let me think about it."

The chart above shows that ever since the major parties have been the Democratic and Republican Parties, there has never been a presidential election in which more than seven candidates were on the ballot in states containing a majority of electoral votes. The average number of such candidates has been 4.3 (that includes the two major party nominees). So, the idea is not impractical. It is hoped that many activists (especially in states in which the Democratic and Republican presidential candidates make themselves available for question-and-answer sessions) will imitate Larry Reinsch. For the record, Reinsch is an independent voter.

"Rock the Debates" favors general election debates that include any candidate who is on the ballot in states containing a majority of electoral votes. If presidential debates had existed ever since 1856, and if the "Rock the Debates" rule had been in effect, the candidates above would have been the only candidates (other than the Democratic and Republican nominees) to be invited. There would never have been more than 7 candidates in such debates.

There were no government-printed ballots before 1889. Therefore, "on the ballot" before 1889 means that the candidate and his party successfully circulated private ballots in states containing a majority of electoral votes, so that votes could be tallied for that party and its candidate in states containing a majority of electoral votes.

In actual history, there were no presidential debates in any elections except 1960, and all elections 1976 through the present.

STATE	REQUIREMENTS		SIGNATURES COLLECTED				DEADLINES
	FULL PARTY	CAND	LIB'T	GREEN	CONSTI	WK FAM.	Party Due	Indp. Due
Alabama	37,513	5,000	0	0	0	0	June 3	Sep. 8
Alaska	(reg) 7,124	#3,128	already on	*3,489	0	0	Aug. 6	Aug. 6
Ariz.	20,449	est. #21,500	already on	*5,100	0	0	Mar. 6	June 4
Arkansas	10,000	#1,000	0	0	0	0	June 30	Aug. 4
Calif.	(reg) 88,991	158,372	already on	already on	already on	0	Dec. 31, 07	Aug. 8
Colorado	(reg) 1,000	Pay $500	already on	already on	already on	0	May 1	June 17
Conn.	no procedure	#7,500	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	Aug. 12	July 15
D.C.	no procedure	est. #3,900	can’t start	already on	can’t start	can’t start	- - -	Aug. 19
Florida	be organized	104,334	already on	already on	already on	0	Sep. 2	July 15
Georgia	44,089	#42,489	already on	*3,500	0	0	July 8	July 8
Hawaii	663	4,291	already on	0	60	0	Apr. 3	Sep. 5
Idaho	11,968	5,984	already on	can’t start	already on	can’t start	Aug. 29	Aug. 25
Illinois	no procedure	#25,000	can’t start	already on	can’t start	can’t start	- - -	June 26
Indiana	no procedure	#32,742	already on	0	0	0	- - -	June 23
Iowa	no procedure	#1,500	0	0	0	0	- - -	Aug. 15
Kansas	16,994	5,000	already on	0	0	0	June 2	Aug. 4
Kentucky	no procedure	#5,000	can’t start	can’t start	can’t start	can’t start	- - -	Sep. 2
La.	(reg) 1,000	pay $500	already on	already on	47	0	May 22	Sep. 2
Maine	27,544	#4,000	0	already on	0	0	Dec 14, 07	Ag 15
Maryland	10,000	est. 32,500	already on	already on	0	0	Aug. 4	Aug. 4
Mass.	est. (reg) 40,500	#10,000	19,253	already on	65	already on	Feb. 1	July 29
Michigan	38,024	38,024	already on	already on	already on	0	July 17	July 17
Minnesota	110,150	#2,000	0	0	0	0	July 15	Sep. 9
Mississippi	be organized	1,000	already on	already on	already on	0	Jan. 10	Sep. 5
Missouri	10,000	10,000	already on	0	*2,000	0	July 29	July 29
Montana	5,000	#5,000	already on	*500	already on	0	Mar. 13	July 30
Nebraska	5,921	2,500	7,100	already on	already on	0	Aug. 1	Aug. 26
Nevada	5,746	5,746	already on	already on	already on	0	July 3	July 3
N. Hamp.	12,524	#3,000	0	0	0	0	Aug. 6	Aug. 6
New Jersey	no procedure	#800	0	0	0	0	- - -	July 28
New Mex.	2,794	16,764	already on	already on	unclear	0	Apr. 1	June 4
New York	no procedure	#15,000	can't start	can't start	can't start	already on	- - -	Aug. 19
No. Car.	69,734	69,734	*62,500	*14,000	100	0	May 16	June 12
No. Dakota	7,000	#4,000	already on	0	already on	0	Apr. 11	Sep. 5
Ohio	*20,114	5,000	*2,000	0	0	0	*Nov 26 07	Aug. 21
Oklahoma	46,324	43,913	*400	0	0	0	May 1	July 15
Oregon	20,640	18,356	already on	already on	already on	already on	Aug. 26	Aug. 26
Penn.	no procedure	est. #27,000	can’t start	can’t start	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	May 30	Sep. 5
So. Caro.	10,000	10,000	already on	already on	already on	already on	May 4	July 15
So. Dakota	8,389	3,356	*200	0	*300	0	Mar. 25	Aug. 5
Tennessee	45,254	25	0	0	0	0	unsettled	Aug. 21
Texas	43,991	74,108	already on	can’t start	can’t start	can’t start	May 27	May 12
Utah	2,000	#1,000	*1,650	300	already on	0	Feb. 15	Sep. 2
Vermont	be organized	#1,000	already on	already on	0	0	Jan. 1	Sep. 12
Virginia	no procedure	#10,000	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	- - -	July 26
West Va.	no procedure	#15,118	0	0	*900	0	- - -	Aug. 1
Wisconsin	10,000	#2,000	already on	already on	can’t start	can’t start	June 2	Sep. 2
Wyoming	3,868	3,868	already on	*0	*0	*0	June 2	Aug. 25
TOTAL STATES ON			26	19	14	5	-	-

#partisan label is permitted (other than "independent").
* means entry changed since June 1, 2007 B.A.N.
"Wk Fam" means Working Families Party.
"Consti" means Constitution Party.

On June 13, New York city Mayor Michael Bloomberg changed his registration from "Republican" to "independent". The press didn’t learn of this until a week later, while Bloomberg was in California. Although Bloomberg has subsequently denied that he has any intent to run for president, the press has run many articles speculating on how he would do if he ran for president as an independent.

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