Law School Case Brief
Nader v. Schaffer - 417 F. Supp. 837 (D. Conn. 1976)
A political party is a voluntary association, instituted for political purposes, with the goal of effectuating the will of its members. Because the political party is formed for the purpose of engaging in political activities, constitutionally protected associational rights of its members are vitally essential to the candidate selection process. An attempt to interfere with a party's ability so to maintain itself is simultaneously an interference with the associational rights of its members. Party members are entitled to affirmative protection of their associational rights.
Conn. Gen. Stat. § 9-431 stated that the voters, led by Nathra Nader, were not eligible to vote in a primary unless they were on the last completed enrollment list of the party in the municipality or the voting district. Nader filed a case and alleged the deprivation of voting and associational rights and sought an order to restrain the enforcement of Conn. Gen. Stat. § 9-431 on the grounds of its unconstitutionality. Nader filed a motion for summary judgment on their constitutional claims. Defendants, Connecticut Secretary of State and political parties (election officials), led by Gloria Schaffer, filed a motion to dismiss Nader’s motion.
Did Conn. Gen. Stat. § 9-431 violate the voters’ voting and associational rights?
The Court granted the election officials' motion to dismiss and denied the voters' motion for summary judgment because the state had a legitimate interest in protecting party members' associational rights by legislating to protect the party from intrusion by those with adverse political principles, and in protecting the overall integrity of the electoral process so that the results of primary elections reflected the voting of party members. Section 9-431 legitimately conditioned participation in a party's nominating process on a showing of loyalty to the party. The voters' equal protection rights were not violated because the voters were not "interested" in nominating the candidate who presented the best chance of winning the general election while remaining most faithful to party policies and philosophies. Section 9-431 was reasonably related to the accomplishment of state goals and the state had broad discretion in formulating election policies.
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