Anderson v. Celebrezze

In Anderson v. Celebrezze, 460 U.S. 780 (1983), Anderson, a Republican not nominated by his party, announced on April 24, 1980 that he would run as an independent candidate for president. On May 16, his supporters tendered a nominating petition and statement of candidacy to the Ohio Secretary of State, who refused to accept the documents because they were submitted after the March 20 deadline then required by the Ohio statute. Id. at 782-83. The Supreme Court found the Ohio deadline unconstitutional because it burdened the association rights of independent voters and candidates and placed significant restrictions on the nationwide presidential electoral process. Id. at 795. The Court found that the deadline discriminated against political party candidates and voters with preferences outside the two dominant political parties. Id. at 794. The Court also stated that the propriety of state election deadlines cannot be resolved by any "litmus-paper test." Instead, a balancing test is involved: (A) court must resolve such a challenge by an analytical process that parallels its work in ordinary litigation. It must first consider the character and magnitude of the asserted injury to the rights protected by the First and Fourteenth Amendments that the plaintiff seeks to vindicate. It then must identify and evaluate the precise interests put forward by the State as justifications for the burden imposed by its rule. In passing judgment, the Court must not only determine the legitimacy and strength of each of those interests, it also must consider the extent to which those interests make it necessary to burden the plaintiff's rights. Only after weighing all these factors is the reviewing court in a position to decide whether the challenged provision is unconstitutional. Id. at 789. The Court declared that an Ohio statute requiring an independent candidate for President to file a statement of candidacy eight months before the general election in November unconstitutionally burdened the voting and associational rights of voters, including the candidate's supporters. The Court recognized that each state has important regulatory interests concerning the election process, notably to assure honesty and fairness throughout the process. The regulation, however, must be reasonable and nondiscriminatory. Id. at 788, 103 S.Ct. at 1570, 75 L.Ed.2d at 557. The Court further observed that each challenge must be resolved on a case-by-case basis, utilizing an established analytical process. Id. at 789, 103 S.Ct. at 1570, 75 L.Ed.2d at 558. Justice Stevens described that process as follows: A court must first consider the character and magnitude of the asserted injury to the rights protected by the First and Fourteenth Amendments that the plaintiff seeks to vindicate. It then must identify and evaluate the precise interests put forward by the State as justifications for the burden imposed by its rule. In passing judgment, the Court must not only determine the legitimacy and strength of each of those interests; it also must consider the extent to which those interests make it necessary to burden the plaintiff's rights. Only after weighing all these factors is the reviewing court in a position to decide whether the challenged provision is unconstitutional. Ibid. The U.S. Supreme Court set forth the following "balancing of interests" test to be used in analyzing constitutional challenges to state election laws: "A court must resolve such a challenge by an analytical process that parallels its work in ordinary litigation. It must first consider that character and magnitude of the asserted injury to the rights protected by the First and Fourteenth Amendments that the plaintiff seeks to vindicate. It then must identify and evaluate the precise interests put forward by the State as justifications for the burden imposed by its rule. In passing judgment, the Court must not only determine the legitimacy and strength of each of those interests; it also must consider the extent to which these interests make it necessary to burden the plaintiff's rights. Only after weighing all these factors is the reviewing court in a position to decide whether the challenged provision is unconstitutional." Id. at 789, 103 S. Ct. at 1570.