460 U.S. 780 (1983)
On April 24, 1980, petitioner John Anderson announced that he was an independent candidate for President of the United States.1 His supporters subsequently gathered the signatures of registered voters, filed required documents, and submitted filing fees to qualify his name for the November 1980 general election ballot in all fifty states and the District of Columbia.2 On that date, however, it was already too late for Anderson to qualify in Ohio because the statutory deadline for filing a statement of candidacy had passed.3
Anderson had his name entered in the Republican primary in Ohio and twenty-six other states before deciding to run as an independent, and he competed unsuccessfully in nine Republican primaries.4 On May 16, 1980, Anderson's supporters tendered a nominating petition containing approximately 14,500 signatures and a statement of candidacy to respondent Celebrezze, the Ohio Secretary of State.5 These documents would have entitled Anderson to a place on the ballot if filed on or before March 20, 1980, but respondent refused to accept the petition solely because it had not been filed within the time required by section 3513.25.7 of the Ohio Revised Code.6 Three days later, Anderson and three voters, two registered in Ohio and one in New Jersey, commenced this action in the United States District Court for the Southern District of Ohio challenging the constitutionality of Ohio's early filing deadline for independent candidates.7
The District Court granted petitioners' motion for summary judgment and ordered respondent to place Anderson's name on the general election ballot.8 The Secretary of State promptly appealed and unsuccessfully requested expedited review, but the election was held while the appeal was pending.9 In Ohio Anderson received 254,472 votes, or 5.9 percent of the votes cast; nationally, he received 5,720,060 votes or approximately 6.6 percent of the total.10
The Court of Appeals reversed.11 It first inferred that prior summary affirmances had implicitly sustained the validity of early filing deadlines, then independently reached the same conclusion.12 The conflict among the Circuits on an important question of constitutional law led the Supreme Court to grant certiorari.13
Whether Ohio's March 20, 1980 filing deadline for independent presidential candidates placed an unconstitutional burden on the voting and associational rights of Anderson's supporters?14
Ballot access restrictions implicate the First and Fourteenth Amendment rights of voters and candidates to associate for the advancement of political beliefs and to cast votes effectively.15 A court must weigh the character and magnitude of the asserted injury against the precise interests put forward by the State.16 It must consider the extent to which those interests make it necessary to burden the plaintiff's rights.17
Yes. The March 20 deadline imposed a substantial burden on independent-minded voters by preventing Anderson, who announced his candidacy on April 24 after competing in Republican primaries, from appearing on the Ohio ballot despite his supporters' tender of 14,500 signatures on May 16.18 This exclusion limited the field of candidates and denied voters the opportunity to associate around a late-emerging independent whose positions crystallized after major-party developments.19 The deadline forced decisions before the national conventions and compounded signature-gathering obstacles when voter interest was low.20
Ohio's early filing deadline unconstitutionally burdened the voting and associational rights of Anderson's supporters.21
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Justice Rehnquist dissented.22 He argued that Article II grants states plenary power to appoint presidential electors.23 Ohio's scheme rationally provided alternative routes to the ballot.24
The deadline merely required a candidate who had already decided to run to choose between party and nonparty paths by March 20.25 No evidence showed that it impeded signature gathering or prevented newly emergent candidates.26 It served the compelling interest in political stability by preventing a rejected party aspirant from bolting to an independent candidacy after the primary season began.27
Whether the State's interests in voter education justified the early filing deadline for independent presidential candidates?28
A state has a legitimate interest in fostering informed voter choices.29 This interest must be evaluated against the specific restriction imposed and modern communications realities.30 The state cannot justify an early deadline by claiming it is necessary to inform voters when major-party nominees appear on the ballot regardless of when they became candidates.31
No. Although voter education is a legitimate state interest, the March 20 deadline did not serve it because modern instantaneous communications allow voters to learn about candidates in far less than seven months.32 The state placed major-party nominees on the ballot even if they never campaigned in Ohio.33 Enforcing the deadline would have prevented Anderson from participating in debates that could have educated Ohio voters.34
The State's interest in voter education did not justify the early filing deadline.35
Whether the State's interest in equal treatment of partisan and independent candidates justified the early filing deadline?36
Equal treatment of candidates does not justify imposing the same early deadline on independents and party primary participants.37 The burdens and benefits differ materially.38 Party candidates receive organizational support and automatic ballot access for their nominees after conventions.39 Independents receive no comparable benefit and face total exclusion if they miss the deadline.40
No. The deadline did not achieve equal treatment because major-party nominees appeared on the November ballot even if they decided to run after March 20.41 An independent was simply denied a place.42 The administrative justification of 75 days for processing applied only to primaries and did not extend to independents.43 Independents gained no organizational benefit from early filing.44
The State's interest in equal treatment did not justify the early filing deadline.45
Whether the State's interest in political stability justified the early filing deadline for independent presidential candidates?46
A state has a legitimate interest in political stability and avoiding splintered parties.47 This interest cannot justify protecting major parties from external competition or intraparty feuding in a presidential election.48 The restriction must be precisely drawn and cannot discriminate against independents or apply too broadly or narrowly to achieve the goal.49
No. Ohio's asserted interest in protecting parties from damaging intraparty feuding amounted to shielding them from competition by independents who had previously sought a party nomination.50 The deadline was both too broad, applying to unaffiliated independents, and too narrow, allowing former party members to run independently if they decided before March.51 It actually impaired stability by forcing dissident groups to form minor parties early rather than first attempting to influence a major party.52
The State's interest in political stability did not justify the early filing deadline.53
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Justice Rehnquist maintained that the deadline furthered the compelling interest in stability by requiring an early choice of route.54 It prevented a candidate rejected by his party from switching to an independent candidacy.55 This was precisely the behavior California sought to prevent through the disaffiliation statute upheld in Storer v. Brown.56
He viewed the restriction as rationally tied to assuring serious contenders and avoiding factionalism without freezing the status quo.57 Ohio's laws met the criteria of rationality and reasonable access to the ballot.58