TENNESSEE BALLOT ACCESS LAW STRUCK DOWN

On February 3, U.S. District Court Judge William J. Haynes declared the Tennessee laws for ballot access for new and minor parties unconstitutional. Green Party of Tennessee v Hargett, middle district, 3:11-0692. The decision also puts the plaintiff political parties, the Green Party and the Constitution Party, on the ballot. The decision is 90 pages.

The decision strikes down the April petition deadline for parties to submit their petitions, and also strikes down the number of signatures, 2.5% of the last gubernatorial vote. Also, it says that given that Tennessee has no party registration (so that any voter can choose any party’s primary ballot), the state cannot force minor parties to nominate by primary if they would rather nominate by convention.

The decision also strikes down the law that gives the two largest parties the top lines on the November ballot.

The basis for striking down the number of signatures for a new party is partly the historical record, because no group has successfully completed that petition requirement since 1968, although ironically, it is likely that Americans Elect is about to meet the requirement. Another basis for the decision is that Tennessee only requires 25 signatures for an independent candidate (or 275 for an independent presidential candidate), and it seems silly for the state to require so many more signatures for a minor party than for an independent candidate.

The decision also strikes down a new law that says no party can have the word "Independent" in its name.

This decision will help somewhat with other similar pending ballot access lawsuits in Oklahoma and Alabama, and some that are planned in other states.

On January 19, the 9^th circuit upheld Washington’s top-two system, in a case filed in 2005 by the Democratic, Republican, and Libertarian Parties. The decision is only 25 pages, and came down only 51 days after the hearing, an unusually quick decision for an unexpedited case. The ballot access portion of the decision is only three pages long. The judges didn’t work very hard on that part of the decision. Washington State Republican Party v Washington State Grange, 11-35122. The decision is by Judge Raymond Fisher and was also signed by Judges Dorothy Nelson and Milan D. Smith.

Evidence showed that fifty-six minor party members have run for federal or state office in top-two systems (in elections in which there were at least two major party members running), and out of those fifty-six, none of them placed first or second.

This evidence was not contradicted by the state, and it shows that in reality, top-two systems keep minor party members out of the general election campaign season. Furthermore, the evidence before the judges showed that in 715 instances when minor party members ran in blanket primaries for federal and state office (with at least two major party members running), there are only two instances when a minor party candidate placed first or second.

The opinion says, "We recognize the possibility that I-872 makes it more difficult for minor-party candidates to qualify for the general election ballot than laws permitting a minor-party candidate to qualify for a general election ballot by filing a required number of signatures."

"This additional burden, however, is an inherent feature of any top two primary system, and the Supreme Court
has expressly approved of top two primary systems. See Cal. Democratic Party v Jones, 530 U.S. 567, 585-86 (2000)."

It is easy to show that the 9^th circuit is mistaken. When this same case was in the U.S. Supreme Court in 2008, the Supreme Court said in footnote eleven that the ballot access issue has not yet been settled, and sent the case back to resolve it. Obviously, the U.S. Supreme Court did not believe that the California blanket primary decision issued in 2000 settled that top two systems are constitutional (relative to ballot access), because otherwise footnote eleven makes no sense.

Furthermore, it is obvious that the 2000 California decision invalidating blanket primaries did not say that top two primaries are constitutional. Justice Scalia wrote the 2000 California decision, and in this Washington case, he wrote separately to say that the Washington top-two system so clearly violates the U.S. Constitution that there is no need to send the case back to the lower courts. And even if that weren’t true, what Justice Scalia said in the 2000 California case about a hypothetical system (probably one in which no party labels appear on the ballot) was just dicta.

Furthermore, if the 9^th circuit really meant what it said, that exclusionary ballot access is "inherent" in a top-two system, then under U.S. Supreme Court precedents, top-two is unconstitutional.

In Williams v Rhodes, the Supreme Court said the Constitution protects the right of voters to vote in November for minor party candidates.

George Wallace brought that case, because Ohio had made it so difficult for him to get on the November ballot. He had run in Democratic presidential primaries in 1964. He could have done so in 1968; he was a Democrat. He could have run in the Ohio Democratic presidential primary with 1,000 signatures. But he didn’t want to run in the primary; he wanted to be on the general election ballot, and the Court said he could do that. The basis for the decision was the voting rights of people who wished to vote for Wallace in November.

The most useful U.S. Supreme Court precedent to help determine the ballot access issue relative to top-two systems is Munro v Socialist Workers Party, 479 U.S. 189 (1986), in which the Court upheld Washington state’s old ballot access law for minor parties and independent candidates. That past law required minor party or independent candidates to receive 1% of the vote in a blanket primary, as a condition of advancing to the November ballot.

The Socialist Workers Party had won the case in the 9^th circuit in 1985. The 9^th circuit acknowledged in its Munro opinion that petition requirements to get on the November ballot are constitutional as long as they are at or below 5% of the number of registered voters. But it said a 1% test in a primary is more difficult than a 5% petition.

The U.S. Supreme Court reversed in 1986, and said prior vote tests and petitions are equally difficult, and both should be judged by the same standard. It said, "We are unpersuaded that the differences between the two mechanisms are of constitutional dimension."

This was the holding in the case, and yet the recent 9^th circuit opinion didn’t even mention it. Obviously, because petition requirements higher than 5% are unconstitutional, so are prior vote tests. Yet a top-two system requires a candidate to poll, on the average, 30% in order to qualify for the November ballot.

The recent 9^th circuit opinion says, "I-872 gives minor-party candidates the same opportunity as major-party candidates to advance to the general election." It also says, "Because I-872 gives major- and minor-party candidates equal access to the primary and general election ballots, it does not give the ‘established parties a decided advantage over any new parties struggling for existence.’"

That sentence is rebutted by the U.S. Supreme Court opinion in Jenness v Fortson, 403 U.S. 431 (1971), which says, "The fact is that there are obvious differences in kind between the needs and potentials of a political party with historically established broad support, on the one hand, and a new or small political organization on the other…Sometimes the grossest discrimination can lie in treating things that are different as though they were exactly alike."

The 9^th circuit did not mention that part of Jenness v Fortson. One is reminded of the famous quote "The law in its majesty forbids both the rich and the poor from sleeping under bridges." The evidence showed that minor parties are always kept off the November ballot (if they are at least two major party members running), and the U.S. Constitution forbids the states from having an election law with such a result.

Some defenders of top-two think that the November election is analogous to a run-off, and it is common that only two candidates are in a run-off. But federal law since 1872 has told the states that they must hold congressional elections in November, and if a state wants a run-off, it must be afterwards.

Louisiana understands this and holds its congressional run-offs in December. But no state is free to hold its congressional election in June or August. The California primary in June, and the Washington state primary in August, is not "the election." Instead, these events have no function except as ballot access barriers to the election itself.

Freedom of Association

The 9^th circuit spent more pages on the part of its decision concerning freedom of association, than on the part about ballot access. The political parties had presented experimental evidence that approximately half of all voters, when given a copy of the Washington primary and general election ballots, mistakenly believe that the party labels on those ballots mean the party either nominated the candidate, or that the party approves of the candidate, or that the candidate is a party member.

Political Science Professor Mathew Manweller did the experiment. The 9^th circuit wrote, "Manweller’s results suggest voter confusion, but he did not give the subjects in his experiments the ballot inserts and voter pamphlets the state provides to the actual electorate. The sample ballots Manweller used also did not conform to the ballots used in actual elections; whereas state law requires that the disclaimer regarding the lack of party association appear ‘immediately above the first partisan congressional, state or county office.’"

Professor Manweller says the court is wrong. He writes, "We went down to the Auditors’ Office and got an exact copy of the ballot used in 2008. We reprinted it to the letter, including words that were bolded, underlined, spacing, capitalization. Secondly, we did include the disclaimer language, word for word in the exact place that it
appeared on the state ballot. The Court is correct in that we placed the disclaimer on the bottom left instead of the top left, but that is because that is what the Auditor did."

Also, the 9^th circuit court ignored the fact that there is no Voters Pamphlet in primaries.

The Washington Libertarian Party long ago trademarked its name, and that was an issue in the case, but the decision belittles that argument.

This Libertarian Party will ask for U.S. Supreme Court. It is not known if the major parties will do likewise.

On January 13, U.S. District Court Judge John A. Gibney ruled in Perry v Judd, 3:11-cv-856, that Virginia’s ban on out-of-state petition circulators "is highly unlikely to withstand the First Amendment challenge", and that "The Court agrees with the rationale in Nader v Brewer." Nader v Brewer is a 9^th circuit opinion that struck down Arizona’s ban on out-of-state circulators for presidential candidates. The case had been filed by Republican presidential candidates who had failed to get on the primary ballot.

Judge Gibney said he would not put any candidates on the ballot, because the case had been filed too late. The candidates appealed, but on January 17, the Fourth Circuit agreed that the case had been filed too late. The Fourth Circuit did not express any opinion about the the ban on out-of-state circulators, but will consider that question later this year.

On January 27, a Virginia House Committee passed HB 1133, which says that any adult Virginian may circulate any petition anywhere in the state. This is a liberalization, because the existing law says no one can circulate outside of his or her home U.S. House district, when working on district petitions. However, there is no bill to let out-of-state petitioners work in Virginia.

San Francisco is the most populous jurisdiction in the U.S. that uses Instant Runoff Voting. A bill to ask voters if they wish to repeal the system is under consideration by the Board of Supervisors. Another bill is pending that would retain IRV and expand it so that voters would have more than just three rankings for each office. If the Supervisors pass either bill, whatever passes will probably be on the November 2012 ballot.

The Supervisors will discuss the bills on September 7.

On January 10, the Constitution, Green and Libertarian Parties of Alabama filed a lawsuit in U.S. District Court against the March 2012 petition deadline. Stein v Chapman, m.d., 2:12-cv-42. It was assigned to U.S. District Court Judge William K. Watkins, a Bush Jr. appointee.

On January 31, the Green and Libertarian Parties of Oklahoma filed a lawsuit in U.S. District Court against the March 2012 deadline for party petitions. Libertarian Party of Oklahoma v Zeriax, cv12-119.

In both states, the deadlines were made worse by bills that passed in 2011. The old Oklahoma deadline was in May, and the old Alabama deadline was in June. Sixteen precedents hold that petition deadlines for new parties earlier than May are uncontitutional, and there are no reported decisions to the contrary. The case against early petition deadlines for new parties is especially strong in connection with presidential elections.

On January 27, the Virginia House Privileges and Elections Committee passed HB 1132, to allow write-ins in primaries, if the party wants write-ins for its primaries.

On January 30, the California legislature passed AB 1413, to remove write-in space from the November ballot for Congress and state office.

Alabama: SB 15 reduces petitions for a new party from 3% of the last gubernatorial vote to exactly 5,000 signatures. Independent candidates would need a petition of 1.5% of the last gubernatorial vote. SB 55 would eliminate mandatory petitions for minor party and independent candidates who pay a filing fee of 2% of the office annual salary.

Missouri: four Missouri representatives have introduced HB 1236, to delete the requirement that a petition to qualify a party must include the names of presidential elector candidates if the party believes it will enter the presidential race.

Nebraska: on February 1, a Senate Committee heard LB 757, the bill to make it easier for a party to remain ballot-qualified. The bill says when a party meets the 5% vote test, it then remains on the ballot for the next two elections, not just the next election.

Utah: HB 233 has been introduced, to make the same change that the Nebraska bill mentioned above does. On February 2 the bill passed the House Government Operations Committee.

West Virginia: Delegate Mike Manypenny has introduced HB 3248, which changes the definition of "party" from a group that got 1% for Governor, to 1% for any statewide office. Senator Clark Barnes has introduced SB 63, which changes the definition of "party" the way HB 3248 does, but in addition says a party is also a group with voter registration membership of at least one-twentieth of 1%.

On January 23, the California Secretary of State ruled that if Americans Elect doesn’t wish to participate in the June 2012 primary, that the state will honor its request. Americans Elect is a ballot-qualified party but it doesn’t want to use its presidential primaries in California or any other state.

California parties already have the ability to decline elections for party officers, and California no longer has party primaries for any office besides President. Therefore, California will not
print up any June 2012 primary ballots for voters who are registered "Americans Elect." Those voters will use the ballot printed up for independent voters.

The chart below shows the number of registered voters in each party. Significant parties in the "Other" column are: Alaska: Veterans 1,437, Alaskan Independence 14,948; California: Peace & Freedom 59,012, Justice 183; Connecticut: Working Families 162, Independent Party 9,183, Independence Party 803; Ct. for Lieberman 82; Delaware: Working Families 486; Socialist Workers 215; Independent Party 2,401; Florida: Independent Party 257,258, Independence Party 58,273, Socialist Workers 293, Socialist 555, Tea Party 30; Party for Socialism & Liberation 30; Kentucky: Socialist Workers 59; Louisiana: Conservative 423; Massachusetts: Socialist 162, Working Families 26; New Jersey: Conservative 368; New Mexico: Independent Party 22,772, Socialist 13, Socialist Workers 14; New York: Independence 398,830, Conservative 140,137, Working Families 38,290, Rent is 2 Damn High 37; Oregon: Independent Party 68,516, Progressive 1,904, Working Families 3,335; Rhode Island: Moderate 584.

The California figure for the Justice Party is official, but not accurate, because Los Angeles County reported "zero" members, which is incorrect.

~	Dem.	Rep.	Indp, misc	AIP/Const	Lib’t.	Green	Reform	Am. Elect	other
Alaska	72,792	130,742	264,499	33	8,051	2,133	?	?	16,385
Arizona	957,786	1,118,938	1,033,584	?	22,912	4,996	?	111	– –
Calif.	7,429,684	5,170,592	3,603,612	428,681	93,300	111,319	20,722	3,165	61,074
Colorado	673,701	782,805	627,210	3,161	9,351	4,024	?	?	– –
Conn.	734,554	412,421	829,224	202	1,273	1,721	87	?	9,345
Delaware	288,168	176,247	138,282	454	819	530	106	0	3,243
Dt. Col.	340,607	29,794	79,930	?	?	4,121	?	?	– –
Florida	4,553,563	4,063,853	2,270,719	976	17,222	5,635	2,213	4	326,837
Iowa	644,223	614,913	719,405	– –	1,506	709	– –	– –	– –
Kansas	442,092	752,311	494,368	– –	10,167	– –	1,054	5	– –
Kentucky	1,642,043	1,106,947	203,529	189	2,007	526	79	?	59
Louis’na	1,407,917	773,183	671,674	?	4,885	1,369	1,383	?	– –
Maine	298,888	258,089	326,598	?	?	31,492	?	?	– –
Maryland	1,946,125	919,818	586,839	223	9,753	8,445	?	?	– –
Mass.	1,315,977	407,718	1,865,589	68	15,140	4,542	228	?	1,996
Nebraska	369,880	542,651	216,185	?	1,554	?	?	?	– –
Nevada	446,679	395,845	175,284	48,784	6,585	2,840	?	?	– –
N. Hamp.	223,151	231,611	312,621	?	?	?	?	?	– –
N. Jersey	1,728,364	1,058,426	2,418,172	143	1,482	1,040	63	?	399
N. Mex.	573,117	375,620	198,294	124	2,319	5,103	75	?	26,205
N. York	5,232,392	2,667,228	2,135,863	?	2,883	18,331	?	?	577,591
No. Car.	2,725,296	1,951,973	1,519,964	?	12,573	?	?	?	– –
Okla.	943,283	828,257	229,070	?	?	?	?	?	– –
Oregon	840,495	645,294	448,085	3,208	13,243	8,886	?	?	73,755
Pennsyl.	4,140,374	3,027,321	944,819	1,996	38,220	15,524	?	?	– –
Rhode Is.	283,511	71,858	340,081	?	?	?	?	?	584
So. Dak.	186,601	232,508	86,447	317	997	?	?	?	– –
Utah	110,210	538,181	586,488	2,930	3,903	?	?	?	– –
W. Va.	642,624	350,783	220,118	156	1,379	1,241	63	?	– –
Wyo.	46,552	142,564	21,830	?	833	?	?	?	– –
TOTAL	41,240,649	29,778,491	23,568,383	491,645	282,357	234,527	26,073	3,285	1,097,473
Percent	42.64%	30.79%	24.37%	.51%	.29%	.24%	.03%	.00+%	1.13%

The AIP/Const column above includes the Constitution Party and the American Independent Party of California.
"Libt" = Libertarian.
"Am. Elect." = Americans Elect.

Totals October 2010 were: Dem. 43,140,758 (42.98%), Rep. 30,700,138 (30.58%), Indp. & misc. 24,359,097 (24.27%), AIP/Constitution 476,669 (.47%), Libertarian 278,446 (.28%), Green 246,145 (.25%), Working Families 44,867 (.04%), Reform 30,237 (.03%), other parties 1,107,843 (1.10%).

Totals October 2008 were: Dem. 43,933,901 (43.62%), Rep. 30,944,590 (30.72%), Indp. & misc. 24,157,259 (23.98%), AIP/Constitution 438,222 (.44%), Green 255,019 (.25%), Libertarian 240,328 (.24%), Reform 32,961 (.03%), other parties 675,980 (.67%).

Totals October 2004 were: Dem. 37,301,951 (42.19%), Rep. 28,988,593 (32.79%), Indp. & misc. 20,471,250 (23.15%), Constitution 320,019 (.36%), Green 298,701 (.34%), Libertarian 235,521 (.27%), Reform 63,729 (.07%), Natural Law 39,670 (.04%), other parties 695,639 (.79%).

Totals October 2000 were: Dem. 38,529,264 (43.84%), Rep. 28,813,511 (32.78%), Indp. & misc. 18,999,126 (21.62%), Constitution 348,977 (.40%)
, Libertarian 224,713 (.26%), Green 193,332 (.22%), Reform 99,408 (.11%), Natural Law 61,405 (.07%), other parties 620,668 (.71%).

Totals October 1992 were: Dem. 35,616,630 (47.76%), Rep. 24,590,383 (32.97%), Indp. & misc. 13,617,167 (18.26%), Green 102,557 (.14%), Libertarian 100,394 (.13%), other parties 554,668 (.74%).

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be organized

STATE	REQUIREMENTS		SIGNATURES COLLECTED				DEADLINES
	FULL PARTY	CAND	LIB’T	GREEN	CONSTI	AM. ELE	Party	Indp.
Ala.	44,829	5,000	in court	in court	in court	*finished	Mar. 13	Sep. 6
Alaska	(reg) 7,406	#3,271	already on	*2,133	*29	already on	June 1	Aug. 8
Ariz.	23,041	(est) #27,000	already on	already on	0	already on	Mar. 1	Sep. 7
Ark.	10,000	#1,000	already on	*already on	0	already on	April 7	Aug. 1
Calif.	(reg) 103,004	172,859	already on	already on	negotiation	already on	Jan. 2	Aug. 10
Colo.	(reg) 1,000	#pay $500	already on	already on	already on	already on	Jan. 8	June 4
Conn.	no procedure	#7,500	0	0	0	0	– – –	Aug. 8
Del.	(est.) (reg) 650	(est.) 6,500	already on	*530	*454	0	Aug. 21	July 15
D.C.	no procedure	(est.) #3,900	can’t start	already on	can’t start	can’t start	– – –	*Aug. 8
Florida	0	112,174	already on	already on	already on	already on	Sep. 1	July 15
Georgia	50,334	#51,845	already on	0	0	*94,100	Aug. 6	Aug. 6
Hawaii	691	#4,536	already on	500	0	*finished	Feb. 22	Sep. 7
Idaho	13,102	1,000	already on	0	already on	*800	Aug. 30	Aug. 24
Illinois	no procedure	#25,000	can’t start	can’t start	can’t start	can’t start	– – –	June 25
Indiana	no procedure	#34,195	already on	0	0	0	– – –	June 30
Iowa	no procedure	#1,500	0	0	0	*300	– – –	Aug. 17
Kansas	16,776	5,000	already on	0	0	already on	June 1	Aug. 6
Ky.	no procedure	#5,000	0	0	0	0	– – –	Sep. 7
La.	(reg) 1,000	#pay $500	already on	already on	0	0	May 17	Sep. 4
Maine	28,639	#4,000	0	already on	0	*already on	Dec 8, 11	Aug. 8
Md.	10,000	(est.) 35,000	already on	already on	*1,300	*finished	Aug. 6	Aug. 6
Mass.	(est) (reg) 40,000	#10,000	*15	already on	*68	0	Nov. 1, 11	July 31
Mich.	32,261	30,000	already on	already on	already on	already on	July 19	July 19
Minn.	105,352	#2,000	0	0	0	0	May 1	Aug. 21
Miss.	be organized	1,000	already on	already on	already on	already on	Jan. 6	Sep. 7
Mo.	10,000	10,000	already on	0	already on	finished	July 30	July 30
Mont.	5,000	#5,000	already on	0	200	*finished	Mar. 15	Aug. 15
Nebr.	4,880	2,500	already on	0	0	finished	Aug. 1	Sep. 1
Nev.	7,013	7,013	already on	0	already on	already on	April 13	July 6
N. Hamp.	13,698	#3,000	16,000	0	0	*10,300	Aug. 8	Aug. 8
N.J.	no procedure	#800	0	0	0	0	– – –	July 30
N. M.	3,009	18,053	already on	700	0	*already on	Apr. 2	June 27
N.Y.	no procedure	#15,000	can’t start	already on	can’t start	can’t start	– – –	Aug. 21
No. Car.	85,379	85,379	already on	500	3,000	*finished	May 16	June 14
No. Dak.	7,000	#4,000	*4,400	0	*4,000	*finished	Apr. 13	Sep. 7
Ohio	show support	5,000	already on	already on	already on	already on	unsettled	Aug. 8
Okla.	51,739	43,890	*40,500	*in court	0	*65,000	March 1	July 15
Oregon	21,804	18,279	already on	9,025	already on	*finished	Aug. 28	Aug. 28
Penn.	no procedure	20,601	can’t start	can’t start	can’t start	can’t start	– – –	Aug. 1
R.I.	17,115	#1,000	0	0	0	already on	June 1	Sep. 7
So. Car.	10,000	10,000	already on	already on	already on	*finished	May 6	July 15
So. Dak.	7,928	3,171	finished	0	0	*finished	Mar. 27	Aug. 7
Tenn.	40,042	275	0	*already on	*already on	*finished	April 5	Aug. 16
Texas	49,729	80,778	already on	already on	can’t start	can’t start	*unsettled	*unsettled
Utah	2,000	#1,000	already on	0	already on	already on	Feb. 15	Aug. 15
Vermont	#1,000	already on	0	0	already on	Jan. 1	Jun 14
Virginia	no procedure	#10,000	0	0	0	0	– – –	Aug. 24
Wash.	no procedure	#1,000	can’t start	can’t start	can’t start	can’t start	– – –	Aug. 28
West Va.	no procedure	#7,135	0	already on	0	0	– – –	Aug. 1
Wisc.	10,000	#2,000	0	0	already on	*2,450	May 1	Aug. 7
Wyo.	3,740	3,740	already on	0	*5,900	*finished	June 1	Aug. 28
TOTAL STATES ON			29	18*	13*	16*	“	`

#partisan label permitted (other than "independent").
"AMER ELE" = Americans Elect Party.
*change since Jan. 1 issue.

The Justice Party is now ballot-qualified in Mississippi, has 500 signatures in Utah, and 200 in Hawaii.

The Reform party is qualified in Florida, Kansas, Louisiana and Mississippi. It has 50 signatures in Hawaii, 500 in Utah, and 100 in Nevada. Also, it hopes to persuade the ballot-qualified Independent Party of New Mexico to become that state’s Reform Party affiliate.

On January 4, the Justice Party nominated Rocky Anderson for President. The party does not yet h
ave a vice-presidential nominee.

On January 31, Oregon held a special election to fill the U.S. House seat. The unofficial results: Democratic 53.96%; Republican 39.65%; Progressive 3.23%; Libertarian 3.16%.

When this same seat was up in November 2010, the vote was: Democratic 54.82%; Republican 42.00%; Constitution 1.32%; Green/Progressive 1.01%; Libertarian .85%.

For some months, Roseanne Barr is suggested that she might run for President in 2012, but only recently has she settled on how she might run. She will seek the Green Party presidential nomination. She is too late for most of the party’s presidential primaries, but she could run in New York. That primary is April 24.

So far, Buddy Roemer is the only presidential candidate who has applied for primary season matching funds. The Federal Election Commission will shortly announce whether he has qualified. Jill Stein, who is seeking the Green nomination, is actively attempting to qualify.

On January 26, the Freedom Socialist Party announced that it is running its first-ever national ticket. Stephen Durham of New York is the presidential nominee, and Christina Lopez of Washington is the vice-presidential nominee. The Freedom Socialist Party has run candidates for U.S. House, state legislature, and local office during the last twenty years but has never before had a presidential nominee, or even a nominee for any statewide office. Like several other socialist parties in the U.S., its origins are a split from the Socialist Workers Party.

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