FLORIDA, OKLAHOMA AND TENNESSEE PASS UNCONSTITUTIONAL BALLOT ACCESS LAWS

During May, Florida, Oklahoma and Tennessee ballot access bills were signed into law, even though the new laws will very likely be held unconstitutional.

Florida

On May 19, Governor Rick Scott signed HB 1355. It says that if a party is ballot-qualified in Florida, but that it is not recognized by the Federal Election Commission as a "national committee", it can’t put a presidential candidate on the ballot without a petition, signed by 4% of the last vote cast for President. The petition must list the candidates for President and Vice-President, and is due July 15. In 2012, the requirement will be 335,630 valid signatures. The petition must also contain 4% of the last presidential vote in each of 14 U.S. House districts. Since the Florida U.S. House district boundaries probably won’t be determined until 2012, this is a wildly impractical law.

The Florida Constitution says in Article VI, sec. 1, "The requirements for a candidate with no party affiliation or for a candidate of a minor party for placement of the candidate’s name on the ballot shall be no greater than the requirements for a candidate of the party having the largest number of registered voters." Currently the Democratic Party has the most registered members in Florida. Of course, the Democratic Party need not petition to place its presidential nominee on the ballot. Therefore, the presidential ballot access provision of HB 1355 seems to violate the Florida Constitution.

The FEC will not give "national committee" status to a new party. The FEC makes it wait until after it has run a presidential campaign and also run congressional campaigns.

The bill also makes it illegal for anyone to run in a primary for any office if that person switched parties during the year before filing.

If this law had been in effect in Pennsylvania in 2010, U.S. Senator Arlen Specter could not have run for re-election in the Democratic primary, because he had switched from the Republican Party in 2009. This part of HB 1355 seems to violate the U.S. Constitution, because the U.S. Supreme Court said in Tashjian v Republican Party of Connecticut that states are not permitted to tell parties that they can’t nominate a non-member.

Oklahoma

On May 10, Governor Mary Fallin signed HB 1615, which moves the petition deadline for a new party from May 1 to March 1. The bill also moves the primary (for office other than President) from July to June. The legislature did not pass any bill lowering the number of signatures, which is 5% of the last vote cast. In 2012 that will be 51,739 valid signatures.

The U.S. Supreme Court has a very good record on early petition deadlines. The Court has ruled, or at least strongly suggested, that petition deadlines as early as March, for independent candidates, and new or minor parties, violate the U.S. Constitution.

Early petition deadlines, not requirements for too many signatures, have done the most harm to ballot access for the minor party and independent presidential candidates who had the greatest popular support, for the last 100 years. In 1912, Oklahoma’s early petition deadline for new parties kept Theodore Roosevelt off the Oklahoma ballot.

Roosevelt had not formed the Progressive Party until August 1912, but he got on the ballot in all states except Oklahoma. At the time Oklahoma didn’t require any signatures for a new party to get on the ballot, but the new party had to apply no later than early June. Roosevelt asked for relief from the State Supreme Court in Persons v Penn, but the Court ruled against him.

In 1924, Louisiana’s early deadline for voters to switch their registration to independent status kept Robert La Follette off i
ts ballot. The state only required 1,000 signatures, but the signers had to be registered outside of the qualified parties, and voters couldn’t switch their registration later than March of the election year. La Follette didn’t decide to run until July 4, 1924. He got on the ballot in all states except Louisiana.

In 1948, Oklahoma’s early deadline kept Strom Thurmond off the ballot in that state. He had not launched the States Rights Democratic Party in Oklahoma until August 4. He asked the Oklahoma Supreme Court for relief, but the Court ruled against him in Lillard v Cordell.. Thurmond appeared on the ballot in all the other southern states.

In 1968, George Wallace failed to qualify for the Ohio ballot because of its early petition deadline for new parties, and its failure to have any procedure for independent presidential candidates. He had qualified in all the other states. In October, the U.S. Supreme Court put him on the ballot, and struck down the Ohio ballot access laws. Three years later, the U.S. Supreme Court commented on its own 1968 Ohio decision, and said that Ohio’s February petition deadline had been "unreasonably early."

In 1977, the U.S. Supreme Court said in Mandel v Bradley that petition deadlines as early as March are probably unconstitutional, if the historical record shows that few petitioning candidates are able to comply. The plaintiff in this case was running for U.S. Senate in Maryland. This matches the fact situation in Oklahoma, where no party has qualified since 2000.

In 1983, the U.S. Supreme Court said in Anderson v Celebrezze that early petition deadlines for independent presidential candidates are always unconstitutional, even when the number of signatures is low. The case was from Ohio, which required only 5,000 signatures, only one-tenth of 1% of the electorate. The decision’s language makes it clear that it applies to new and minor parties as well as independent candidates.

As a result of these U.S. Supreme Court decisions, lower courts have been unanimous in striking down petition deadlines for new or minor parties, if those deadlines were earlier than May. Such decisions have been from Alabama, Alaska, Arkansas, Idaho, Indiana, Kentucky, Maine, Massachusetts, Nebraska, Nevada, New Jersey, Ohio, Pennsylvania, South Dakota, and Tennessee. The only reported case which upheld a party petition deadline earlier than May is a 1988 decision from North Dakota which upheld an April deadline. However, at the time, North Dakota permitted use of a partisan label for candidates who used the independent procedure, and independent petitions were not due in September, so one can say that North Dakota had an alternate procedure for minor parties that did not have an early deadline.

In addition to those cases, the 10^th circuit said in Populist Party v Herschler in 1984 that a deadline as early as June 1 "appears to run counter to the views expressed in Anderson v Celebrezze." Oklahoma is in the 10^th circuit. However, in 1988, the 10^th circuit said the old Oklahoma petition deadline of May 31 is constitutional, but just barely.

As a consequence of all this case law, it will be difficult for Oklahoma to justify a March 1 petition deadline, especially given the large number of signatures required.

Oklahoma will argue that it must have an early petition deadline, because this year it moved its primary to June and requires newly-qualifying parties to nominate by primary. But that argument did not work in similar cases in Idaho, Nebraska, Nevada, Ohio, South Dakota, and Tennessee. All those states also had said newly-qualifying parties must nominate by primary. As a result of the decisions against the early deadlines in those states, Idaho, Nebraska, Nevada and Wyoming changed their policies and now let newly-qualifying parties nominate by convention. South Dakota kept its requirement that new parties nominate by primary, but moved the petition deadline for new parties to only two months before its primary. Ohio still hasn’t passed a new law to replace the law that was declared unconstitutional in 2006.

The Libertarian Party wrote a letter to Oklahoma’s Governor and asked her to veto HB 1615, but she disregarded the letter’s advice and did not even respond to that letter.

Tennessee

On May 23, Tennessee Governor Bill Haslam signed HB 794, a bill that is intended to replace the state’s old ballot access law for new and minor parties. The old law was declared unconstitutional in 2010.

The new law does not reduce the number of signatures (2.5% of the last gubernatorial vote), which in 2012 is 40,042 signatures. The new law does improve the filing deadline slightly. The old law was vague, but seemed to require the petitions to be submitted in March. The new deadline is the first Tuesday in April. Tennessee holds its primary (for office other than President) in early August, and there are approximately 120 days between early April and early August.

The decision striking down the old law says that an April deadline is too early to pass muster. The decision relies on the 6^th Circuit opinion Libertarian Party of Ohio v Blackwell (Tennessee is in the 6^th circuit). The Tennessee decision says, "In Blackwell, Ohio’s political party requirement amounted to only one percent of the total vote cast in the previous election. Yet, this fact did not preclude the Court’s conclusion that Ohio’s 120 days deadline rendered Ohio’s scheme unconstitutional…As stated in Blackwell, the 6^th Circuit cited and relied upon decisions in other circuits and district courts holding State deadlines of 60 days and 90 days prior to a primary as creating burdens for minor political parties and voters."

So, the new Tennessee law sets a deadline that has already been found to be too early. The same three parties that won the 2010 Tennessee lawsuit will probably file a new lawsuit.

The bill also eliminates procedures for a party to become ballot-qualified in just a single county.

Oklahoma, and Tennessee aren’t the only states passing bills for early petition deadlines:

Colorado: on May 5, the legislature passed SB 189. It moves the independent presidential deadline from 140 days before the election (late June) to 155 days before (early June). This gives Colorado the second earliest independent presidential deadline in the nation, after Texas.

States in which petition deadlines for independent candidates in June have been held unconstitutional are Alaska, Arizona, Kansas, Massachusetts, Nevada, and South Dakota. There are no precedents (since 1983, when th
e U.S. Supreme Court released Anderson v Celebrezze) upholding an independent presidential petition deadline in June.

SB 189 also moves the primary from August to June. It also moves the petition deadline for a new party to qualify itself from March 1, to the second Friday in January. The petition process to qualify a new party has only existed since 1998, and the original 1998 law set the deadline of May 1. In 2003 the legislature had provided that in the rare cases when a qualified minor party holds a nominating convention, and at least two candidates for the same office receive at least 30% of the vote, that qualified minor party must then nominate by primary for that particular office. And, the 2003 law also moved the petition deadline for a new party to March 1, just in case the minor party might need a primary. Actually, no qualified minor party ever actually then had a primary, except in 2010 the Libertarian Party had one.

The rationale for moving the party petition deadline to January is that the primary is now in June. Fortunately, however, it is still possible for an unqualified party in Colorado to use the independent petition procedures, because Colorado lets candidates who use the independent procedure choose a partisan label that is printed on the ballot. Those petitions are due in June. Thus, in a sense, a new party can still enjoy a June petition deadline in Colorado. This is not true in Ohio, Oklahoma, or Tennessee.

Ohio: on May 18, the Ohio House passed HB 194, moving the petition deadline for newly qualifying parties from four months before the primary, to three months before the primary. The bill attempts to fix the ballot access law, which was declared unconstitutional in 2006.

On May 24, SB 148 passed the Senate. It lowers the number of signatures to one-half of the old requirement (to one-half of 1% of the last vote cast, i.e., 19,263 signatures in 2012). It changes the petition deadline from 120 days before the primary to 100 days before the primary, which would be near Thanksgiving of the year before the election.

California: on April 25, the Senate passed SB 205 by 24-15. It makes it illegal to pay people to register new voters, if payment is based on how many voter registrations the worker submits. Because the only way that new parties in California have qualified for the ballot since 1970 has been by paying workers to persuade voters to register into that new party, this bill makes it much more difficult for a new party to become qualified. Persuading 103,004 voters to change their registration to list them as members of a new party is a sales job, and if salespeople can’t be paid on a per-registration basis, the job becomes much more expensive. The bill will be heard in the Assembly Elections Committee on June 7.

Delaware: on May 10, the legislature passed HB 11, which tells parties that they can’t nominate a non-member. The bill has the indirect effect of making fusion illegal ("fusion" is the practice of letting two parties jointly nominate the same candidate). The Working Families Party, which uses fusion and which is ballot-qualified in Delaware, will probably sue.

Georgia: in March, two House members, Rusty Kidd and Alan Powell, introduced HB 494. It abolishes mandatory petitions for all independent and minor party candidates. Georgia has high filing fees, so ballot crowding would be controlled by fees alone. It is too late in 2011 for this bill to advance, but Georgia has two-year legislative sessions, so it could pass in 2012.

Illinois: HB 2009, which makes ballot access for independent candidates more restrictive, seems unlikely to pass. It says that anyone who ran for any office in the primary cannot then run under a different label in November. Although the House passed it, the Senate has sent it to a committee which is typically considered a graveyard committee for bills.

Maine: on May 24, the legislature passed LD 142, which eases the organizational requirements for a ballot-qualified party. The old law says a party must hold a caucus in at least one town in each of Maine’s 16 counties. The bill says such caucuses only are needed in any 14 counties.

Missouri: on May 10, a conference committee deleted the parts of SB 282 that help minor parties. Committee members were heard to say that they didn’t want to make it easier for a Tea Party that might conceivably emerge. The ballot access part of the bill would have deleted a typographical error in the law that describes what must be listed on a petition to qualify a new party. The law says the petition need not carry the names of any candidates (they get nominated later by convention if the group qualifies), except that if the group wants to have a presidential nominee, the petition must list the presidential nominee. Fortunately the Secretary of State permits a stand-in presidential candidate on the petition.

Texas: on May 24, the House passed SB 100. It eases the petition deadline for independent candidates (other than for President) by moving it from May to June. Oddly, however, it does not improve the petition deadline for independent presidential candidates, whose deadline would continue to be May. The bill also moves the runoff primary from April to May.

Alaska: on May 24, Governor Sean Parnell signed SB 31, which explicitly says that a write-in vote is not necessarily invalid just because the voter did not spell the candidate’s name correctly.

California: on May 5, the Assembly passed AB 461, which says that write-ins may be counted even if the voter forgot, or didn’t know, to "X" the box next to the name written in.

California: on May 19, the Assembly passed AB 459, the National Popular Vote Plan bill, by 47-21. Four Republicans voted for it, and no Democrat voted against it.

Hawaii: on April 28, a legislative conference committee killed HB 638, even though it had passed both houses. The bill would have provided that Instant Runoff Voting be used in special elections.

Indiana: on May 13, Governor Mitch Daniels signed HB 1242. It says, among other things, that a party keeps its qualified status even if its nominee for Secretary of State should not have been on the ballot. Indiana defines "party" as a group that polled at least 2% for Secretary of State in the last election. It is possible that the
Republican incumbent, Charlie White, will be determined ineligible to have run for that office, because it appears he registered to vote at an address where he didn’t live; plus he voted using that address.

Kansas: on May 20, the legislature sent HB 2080 to the Governor. It cancels the 2012 presidential primary in order to save money.

Louisiana: on May 18, the House Committee on Governmental Affairs passed HB 533. It says that independent candidates for all office may have "independent" printed on the ballot next to their names. Currently, only presidential candidates can have that label. Independent candidates for office other than President now have the label "No party" on the ballot. The bill also removes the names of candidates for presidential elector from the ballot. Currently Louisiana is one of only six states that still lists them on the ballot. Their names take up a lot of room and are not especially helpful to voters.

Oklahoma: SB 91, a bill that originally required birth certificates to be submitted for presidential candidates, has been amended to no longer require such certificates.

This means that no state will have passed any bill, requiring presidential candidates to submit copies of their birth certificates. President Obama’s release of his birth certificate on April 27 seems to have ended interest in bills of this type. The actual consequences of such proposed laws would probably have been to put ballot access for certain presidential candidates in jeopardy, because some paperwork snafu would have occurred.

Washington: on May 12, Governor Christine Gregoire signed HB 5119, which eliminates the presidential primary, in order to save money.

California: U.S. District Court Judge Otis Wright will hear oral arguments in Chamness v Bowen on June 13, at 1:30 pm, in Los Angeles. This is the case that argues that two aspects of the top-two system are unconstitutional: the provision saying write-in votes can’t be counted in November (even though the law requires write-in space to be printed on ballots); and the provision saying members of qualified parties can list their party on the ballot, but members of unqualified parties can’t.

California (2): on May 20, the 9^th circuit upheld the type of Instant Runoff Voting used in San Francisco city elections. Dudum v Arntz, 10-17198. San Francisco only lets voters indicate a First, Second, and Third Choice. Most places in the world that use Instant Runoff Voting let voters vote for as many candidates as they wish. The plaintiffs argued that San Francisco discriminates against voters whose choices all fail to do well, but the Court said all voters’ votes count, even if they are merely counted as votes for losing candidates.

Massachusetts: on May 27, the Libertarian Party asked the U.S. Supreme Court to hear its lawsuit on using stand-in presidential candidates on petitions. Barr v Galvin. This is the first time this issue has ever been presented to the Court.

Until 2009, all lower courts that had considered the question had ruled in favor of using a stand-in presidential candidate on petitions. This practice helps a party that must circulate petitions before it has chosen its actual presidential candidate. Unfortunately, in 2009, the First Circuit ruled against the practice, in cases from both Massachusetts and New Hampshire.

Nevada: on May 19, a lower state court construed the law concerning special congressional elections to mean that parties may nominate candidates in the upcoming special election for U.S. House, 2^nd district. The court overturned a Secretary of State ruling that left parties out of the procedure. Nevada Republican Party v State of Nevada, 11oc-00147, Carson City.

New Hampshire: the Libertarian Party has received an extension until July 24, to file a cert petition in its lawsuit on stand-in presidential candidates on petitions.

New York: on May 10, a U.S. District Court denied the state’s motion to dismiss the lawsuit Conservative Party v Walsh The issue is the state’s policy on how to count votes when a voter mistakenly votes twice for the same candidate, once on each party’s line. The state counts that vote for the party closest to the top of the ballot, which is almost always one of the two major parties. The ruling seems to say that this is not constitutional, and now a trial will be held to arrive at a better solution.

Pennsylvania: on May 19, the 3^rd circuit ruled that the Constitution, Green, and Libertarian Parties lack standing to challenge the state’s unique system of charging fees of up to $110,000, if they submit a petition that turns out not to have enough valid signatures. The decision also says they also don’t have standing to sue over the requirement for ongoing ballot status, that they have registration of 15% of the state total; and that they don’t have standing to challenge the policy in some counties to discard all write-in votes.

STATE	REQUIREMENTS		SIGNATURES COLLECTED				DEADLINES
	FULL PARTY	CAND	LIB’T	GREEN	CONSTI	AM. ELE	Party	Indp.
Ala.	44,829	5,000	0	0	0	*0	June 1	Sep. 6
Alaska	(reg) 7,406	#3,271	already on	*2,143	*4	finished	June 1	Aug. 8
Ariz.	23,041	(est) #27,000	already on	already on	0	finished	Mar. 1	Sep. 7
Ark.	10,000	#1,000	finished	0	0	0	June 30	Aug. 1
Calif.	1,030,040	172,859	already on	already on	in court	*600,000	*unsettled	Aug. 10
Colo.	(reg) 1,000	#pay $500	already on	already on	already on	0	*Jan. 8	*June 4
Conn.	no procedure	#7,500	can’t start	can’t start	can’t start	can’t start	– – –	July 13
Del.	(est.) (reg) 650	(est.) 6,500	already on	563	283	0	Aug. 21	July 15
D.C.	no procedure	(est.) #3,900	can’t start	already on	can’t start	can’t start	– – –	Aug. 21
Florida	*335,630	112,174	already on	already on	already on	already on	Sep. 3	July 15
Georgia	57,956	#57,558	already on	*0	*0	*0	Aug. 6	Aug. 6
Hawaii	691	#4,536	already on	0	0	0	Feb. 22	Sep. 7
Idaho	13,102	1,000	already on	can’t start	already on	can’t start	Aug. 30	Aug. 31
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	0	– – –	Aug. 17
Kansas	16,776	5,000	already on	0	0	finished	June 1	Aug. 6
Ky.	no procedure	#5,000	can’t start	can’t start	can’t start	can’t start	– – –	Sep. 4
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	0	Dec 8, 11	Aug. 8
Md.	10,000	(est.) 35,000	in court	in court	0	0	Aug. 6	Aug. 6
Mass.	(est) (reg) 40,000	#10,000	15,857	already on	0	0	Nov. 1, 11	July 31
Mich.	32,261	30,000	already on	already on	already on	finished	July 19	July 19
Minn.	105,352	#2,000	0	0	0	0	May 1	Aug. 14
Miss.	be organized	1,000	already on	already on	already on	0	Jan. 6	Sep. 7
Mo.	10,000	10,000	already on	0	already on	0	July 30	July 30
Mont.	5,000	#5,000	already on	0	0	0	Mar. 15	Aug. 1
Nebr.	4,880	2,500	already on	0	0	0	Aug. 1	Aug. 28
Nev.	7,013	7,013	already on	0	already on	already on	July 2	July 6
N. Hamp.	13,698	#3,000	0	0	0	0	Aug. 8	Aug. 8
N.J.	no procedure	#800	0	0	0	0	– – –	July 30
N. M.	3,009	18,053	already on	0	0	0	Apr. 2	June 6
N.Y.	no procedure	#15,000	in court	already on	can’t start	can’t start	– – –	Aug. 21
No. Car.	85,379	85,379	already on	0	3,000	0	May 16	June 14
No. Dak.	7,000	#4,000	0	0	0	0	Apr. 13	Sep. 7
Ohio	no law exists	5,000	already on	already on	already on	0	unsettled	Aug. 8
Okla.	51,739	43,890	0	0	0	0	*March 1	July 15
Oregon	21,804	18,279	already on	8,710	already on	0	Aug. 28	Aug. 28
Penn.	no procedure	(es) #25,000	can’t start	can’t start	can’t start	can’t start	– – –	Aug. 1
R.I.	17,115	#1,000	0	0	0	0	June 1	Sep. 7
So. Car.	10,000	10,000	already on	already on	already on	0	May 6	July 15
So. Dak.	7,928	3,171	0	0	0	0	Mar. 27	Aug. 7
Tenn.	*40,042	275	0	0	0	0	*April 5	Aug. 16
Texas	49,729	80,778	already on	already on	can’t start	can’t start	May 20	May 14
Utah	2,000	#1,000	already on	0	already on	0	Feb. 15	Aug. 15
Vermont	be organized	#1,000	already on	0	0	0	Jan. 1	Jun 14
Virginia	no procedure	#10,000	can’t start	can’t start	can’t start	can’t start	– – –	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	can’t start	can’t start	already on	can’t start	June 1	Sep. 7
Wyo.	3,740	3,740	already on	0	*600	0	June 1	Aug. 28
TOTAL STATES ON			27	15	12	2	“	`

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

The May 1 B.A.N. listed minor party members who were elected to local non-partisan office in various April elections, but failed to include Dr. Edward Shadid, a member of the Green Party who was elected to the Oklahoma City city council on April 5. He is a spinal surgeon and in 2010 had run for the legislature, polling 10.5% against both a Democrat and a Republican. Because the Green Party has never been on the Oklahoma ballot, no one has ever been permitted to be a registered Green. Therefore, Shadid is a registered independent, and his ballot label in 2010 had been "independent."

On May 10, Alabama filled the vacant State House seat, 105^th district, in Mobile County. Only two candidates appeared on the ballot, Constitution Party nominee Bill Atkinson, and a Republican. Atkinson received 46.0% of the vote. This is the best showing the Constitution Party has ever made in a state legislative race, other than in Montana in 2006 when Rick Jore polled 55.5% and was elected.

On May 14, the Montana Constitution Party rejoined the national Constitution Party. The state party had been upset with the national party and had refused to list the party’s presidential candidate on the Montana ballot in 2008, but the breach is healed.

On May 14, the Libertarian Party of Indianapolis nominated Ed Coleman for city council, 24^th district. He is an incumbent and was elected as a Republican in 2007, but in 2008 he had left the Republican Party and joined the Libertarian Party. Indianapolis has partisan city elections.

On May 2, Canada held a parliamentary election. The Green Party elected its first member of the Canadian Parliament. Elizabeth May represents a district near Victoria, British Columbia. Nationally, Greens ran in every district and polled 4% of the vote. Conservatives received 40% of the popular vote; New Democrats 31%; Liberals 19%; Bloc Quebecois 6%. The New Democratic Party had never before placed second in a national Canadian election. Alhough it has won control of some provincial governments in the past, and always elects some members of the national Parliament, it has still been considered a "third" party. Labor unions provide most of the New Democratic Party’s strength.

On May 5, Great Britain held a referendum on whether to use Instant Runoff Voting. This was the first referendum held nationally since 1975. The idea was defeated, 32% to 68%. The Conservative Party carried on a full-scale campaign against IRV, and the Labour Party did not back it, even though individual leaders of the Labour Party did. The Liberal Democratic Party was the chief force behind the ida, but that party is unpopular just now, and that hurt the IRV campaign.

On May 10, Gallup Polls released the results of a survey which asks whether the United States would be better off with a new major party. 52% said "Yes"; 40% said "No"; 8% were undecided. The poll asked respondents for their own partisan loyalties. 68% of the independents and minor party members favored a new major party; 52% of the Republicans did; but only 33% of the Democrats did.

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