The September 3 Arizona court ruling, saying an independent presidential candidate must not be registered into a ballot-qualified party, is unprecedented. Never before in history has any presidential candidate been kept off any ballot (general election ballot, or presidential primary ballot) on the basis of his or her voter registration partisan choice.

In general elections, even major party presidential nominees have sometimes qualified as independent candidates. Harry Truman qualified as an independent presidential candidate in 1948 in Louisiana and Mississippi, because the Democratic Parties of those states refused to list him on the general election ballot. If the Arizona 2020 Kanye West decision had been applied to Truman, Truman could not have been on the ballot in those states. Truman would have also qualified as an independent in Alabama, but he missed the May 1948 deadline. South Carolina at the time did not have government-printed ballots, but if it had, Truman would have tried to qualify in South Carolina as well.

In 1952, Dwight Eisenhower qualified as an independent presidential candidate in Mississippi. He was listed twice, both as an independent and as a Republican. Mississippi permits fusion. Eisenhower got far more votes as an independent than as a Republican.

In 1968, Hubert Humphrey qualified as the nominee of two minor parties in Alabama, because the Alabama Democratic Party wouldn’t put him on the ballot.