Eu v. San Francisco County Democratic Central Comm

In Eu v. San Francisco County Democratic Central Comm., 489 U.S. 214, 229-30, 109 S. Ct. 1013, 1023-24, 103 L. Ed. 2d 271 (1989), the plaintiff political party challenged sections of the California Election Code that dictated the size and composition of the state central committees, set forth rules governing the selection and removal of committee members, fixed the maximum term of office for the chair of the state central committee, required that the chair rotate between the residents of northern and southern California, specified the time and place of committee meetings, and limited the dues the parties could impose on members. 489 U.S. at 218-19, 109 S. Ct. at 1017-18. The official governing bodies required by statute were responsible for conducting the party's campaigns. Id. at 216-17, 109 S. Ct. at 1016-17. In Eu, the Court noted that freedom of association "encompasses a political party's decisions about the identity of, and the process for electing, its leaders" as well as the determination of the best structure for the party. Id. at 229, 109 S. Ct. at 1023. The Court concluded that the laws at issue unduly burdened the rights of political parties because "by requiring parties to establish official governing bodies at the county level, California prevents the political parties from governing themselves with the structure they think best. And by specifying who shall be the members of the parties' official governing bodies, California interferes with the parties' choice of leaders." Id. at 230, 109 S. Ct. at 1024. The Court did not find persuasive the state's contention that the challenged laws served a compelling "interest in the 'democratic management of the political party's internal affairs.'" Id. at 232, 109 S. Ct. at 1025. Therefore, the Court held the challenged California election laws unconstitutional. Id. at 233, 109 S. Ct. at 1025.