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Person v. New York State Board of Elections
The District Court denied Person's application for an injunction, and he subsequently appealed, ultimately unsuccessfully, to the Second Circuit.
Person challenged a provision of the law that prohibits payment to petition circulators based on the number of signatures they collect. Person argued that the prohibition of per-signature payment violated U.S. Supreme Court precedent in Meyer v. Grant. However, the Second Circuit joined the Eighth and Ninth Circuits in holding that "that a state law prohibiting the payment of electoral petition signature gatherers on a per-signature basis does not per se violate the First or Fourteenth Amendments."
Precedents mentioned in the case
- People ex rel Beckerman v. Doe