On May 8, former U.S. Supreme Court Justice David Souter died. He had written Norman v Reed, the last U.S. Supreme Court opinion that helped ballot access. The 1992 decision interpreted several Illinois ballot access laws in a favorable manner, and was a victory for the Harold Washington Party in its battle to appear on the Cook County ballot for county office. On the other hand, a few months later, Souter voted to uphold Hawaii’s ban on write-in votes.