Anderson v. Celebrezze

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Anderson v. Celebrezze
Seal of the United States Supreme Court.svg
Court:U.S. Supreme Court
Text:Text of decision
Holding:
Ohio's early filing deadline violated the First and Fourteenth Amendments of the U.S. Constitution, placing an unconstitutional burden on the voting and associational rights of supporters of independent presidential candidates.
Case history
Trial court:United States District Court for the Southern District of Ohio
Appellate court:United States Court of Appeals
Appellate court:United States Supreme Court
Author, appellate decision:John Paul Stevens
Appellate court decision:April 19, 1983
Anderson v. Celebrezze, a case decided by the U.S. Supreme Court in 1983, held that Ohio's early filing deadline violated the First and Fourteenth Amendments of the U.S. Constitution, placing an unconstitutional burden on the voting and associational rights of supporters of independent presidential candidates.[1][2]

Background

An Ohio statute required independent presidential candidates to file statements of candidacy and nominating petitions in March in order to qualify to appear on the general election ballot in November. Independent candidate John Anderson announced his candidacy for President in April 1980 and all requisite paperwork was submitted on May 16, 1980. The Ohio Secretary of State, Anthony J. Celebrezze, refused to accept the documents.[1]

Anderson and his supporters filed an action challenging the constitutionality of the aforementioned statute on May 19, 1980 in the United States District Court for the Southern District of Ohio. The District Court ruled in Anderson's favor and ordered Celebrezze to place Anderson's name on the ballot. Celebrezze appealed the decision to the United States Court of Appeals, which ultimately overturned the District Court's ruling (the election took place while this appeal was pending).[1]

Decision

In a 5-4 decision, the Court reversed the ruling of the Court of Appeals, maintaining that Ohio's early filing deadline indeed violated the voting and associational rights of Anderson's supporters. Justice John Paul Stevens, in the Court's majority opinion, wrote the following:

Ohio's filing deadline prevents persons who wish to be independent candidates from entering the significant political arena established in the State by a Presidential election campaign - and creating new political coalitions of Ohio voters - at any time after mid-to-late March. At this point developments in campaigns for the major-party nominations have only begun, and the major parties will not adopt their nominees and platforms for another five months. Candidates and supporters within the major parties thus have the political advantage of continued flexibility; for independents, the inflexibility imposed by the March filing deadline is a correlative disadvantage because of the competitive nature of the electoral process.[1][3]

See also

Portal:Third Party Ballot Access

External links

References