On March 20, the Seventh Circuit issued a four-page opinion in Marshall v Wisconsin Election Commission, 24-2746. This was the last pending lawsuit filed by independent presidential candidate Shiva Ayyadurai last year, over whether states can keep presidential candidates off the ballot if they don’t meet the constitutional requirements. The decision is unsigned and will not be published. It says the whole issue is “frivolous” and that states may keep such presidential candidates off the ballot. This is a more complicated issue than the opinion acknowledges. It occupied hundreds of pages of briefs and amicus briefs in 2024 in Trump v Anderson, the case over whether Donald Trump should be on various ballots in 2024.

The judges are Frank Easterbrook, a Reagan appointee; Thomas K. Kirsch II, a Trump appointee; and Candace Jackson-Akiwumi, a Biden appointee. This case arose from Wisconsin.