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Law School Case Brief

Anderson v. Celebrezze - 460 U.S. 780, 103 S. Ct. 1564 (1983)

Rule:

The impact of candidate eligibility requirements on voters implicates basic constitutional rights. Freedom to engage in association for the advancement of beliefs and ideas is an inseparable aspect of the "liberty" assured by the Due Process Clause of U.S. Const. amend. XIV, which embraces freedom of speech.

Facts:

An Ohio statute requires an independent candidate for President to file a statement of candidacy and nominating petition in March in order to appear on the general election ballot in November. On April 24, 1980, petitioner Anderson announced that he was an independent candidate for President. Thereafter, on May 16, 1980, his supporters tendered a nominating petition and statement of candidacy, satisfying the substantive requirements for ballot eligibility, to respondent Ohio Secretary of State. Respondent refused to accept the documents because they had not been filed within the time required by the Ohio statute. Anderson and petitioner voters then filed an action in Federal District Court, challenging the constitutionality of the statute. The District Court granted summary judgment for petitioners and ordered respondent to place Anderson's name on the general election ballot, holding that the statutory deadline was unconstitutional under the First and Fourteenth Amendments. The Court of Appeals reversed, holding that the early deadline served the State's interest in voter education by giving voters a longer opportunity to see how Presidential candidates withstand the close scrutiny of a political campaign.

Issue:

Did the Ohio statute requiring independent candidate for President to file statement of candidacy in March in order to appear on general election ballot in November place unconstitutional burden on voting and associational rights of candidate's supporters?

Answer:

Yes

Conclusion:

Applying a balancing test, the United States Supreme Court ruled that Ohio's statutory deadline placed an unconstitutional burden on Anderson’s voters' right of association, under U.S. Const. amend. I. The early deadline burdened independent voters by restricting their candidates to those that declare by March, while voters of the major parties could select a candidate placed on the ballot at a later date. The state's interest in voter education could not justify the burden because it was possible to educate the voters in a short period of time. The state's "equal treatment" interest also failed because independent candidates were treated differently. Finally, protecting against fractionating of the major parties could not justify the restriction where the result was that independent candidates were excluded.

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