In Eu v. San Francisco County Democratic Central Committee (1989) 489 U.S. 214. the Supreme Court concluded that certain provisions of the Elections Code are unconstitutional because they "burden the First Amendment rights of political parties and their members without serving a compelling state interest." (Id., at p. 233.) The provisions "prescribe the composition of state central committees, limit the committee chairs' term of office, and designate that the chair rotate between residents of northern and southern California . . . ." (Id., at p. 220.) The court reasoned that these provisions "directly implicate the First Amendment associational rights of political parties and their members" because they limit "a political party's discretion in how to organize itself, conduct its affairs, and select its leaders." (Id., at pp. 229-230.) Although the provisions in question concerned the state central committee, the Eu court made clear that its reasoning also applied to county central committees: "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." (Id., at p. 230.) The Eu court observed: "A State indisputably has a compelling interest in preserving the integrity of its election process. Toward that end, a State may enact laws that interfere with a party's internal affairs when necessary to ensure that elections are fair and honest." (Eu, supra, 489 U.S. at p. 231.) The court determined that the State had failed to establish the requisite compelling state interest because it had "not shown that its regulation of internal party governance is necessary to the integrity of the electoral process." (Id., 489 U.S. at p. 232.) In sum, the court declared, "a State cannot justify regulating a party's internal affairs without showing that such regulation is necessary to ensure an election that is orderly and fair. Because California has made no such showing here, the challenged laws cannot be upheld." (Id., at p. 233.) In Eu the Supreme Court struck down Elections Code provisions prescribing the composition of state central committees. The court observed that, "by specifying who shall be the members of the parties' official governing bodies, California interferes with the parties' choice of leaders." (Eu, supra, 489 U.S. at p. 230.) The Supreme Court concluded that this interference did not serve a compelling state interest because the state had failed to show that it was "necessary to ensure an election that is orderly and fair." (Id., at p. 233.)