Eu v. S.F. Cty. Democratic Cent. Comm.Annotate this Case
489 U.S. 214 (1989)
U.S. Supreme Court
Eu v. S.F. Cty. Democratic Cent. Comm., 489 U.S. 214 (1989)
Eu v. San Francisco Democratic Central Committee
Argued December 5, 1988
Decided February 22, 1989
489 U.S. 214
APPEAL FROM THE UNITED STATES COURT OF APPEALS FOR
THE NINTH CIRCUIT
Section 11702 of the California Elections Code (Code) forbids the official governing bodies of political parties to endorse or oppose candidates in primary elections, while § 29430 makes it a misdemeanor for any candidate in a primary to claim official party endorsement. Other Code sections dictate the organization and composition of parties' governing bodies, limit the term of office for a party's state central committee chair, and require that the chair rotate between residents of northern and southern California. Various party governing bodies, members of such bodies, and other politically active groups and individuals brought suit in the District Court, claiming, inter alia, that these Code provisions deprived parties and their members of the rights of free speech and free association guaranteed by the First and Fourteenth Amendments. The District Court granted summary judgment for the plaintiffs as to the provisions in question, and the Court of Appeals affirmed.
Held: The challenged California election laws are invalid, since they burden the First Amendment rights of political parties and their members without serving a compelling state interest. Pp. 489 U. S. 222-233.
(a) The ban on primary endorsements in §§ 11702 and 29430 violates the First and Fourteenth Amendments. By preventing a party's governing body from stating whether a candidate adheres to the party's tenets or whether party officials believe that the candidate is qualified for the position sought, the ban directly hampers the party's ability to spread its message and hamstrings voters seeking to inform themselves about the candidates and issues, and thereby burdens the core right to free political speech of the party and its members. The ban also infringes a party's protected freedom of association rights to identify the people who constitute the association and to select a standard-bearer who best represents the party's ideology and preferences, by preventing the party from promoting candidates at the crucial primary election juncture. Moreover, the ban does not serve a compelling governmental interest. The State has not adequately explained how the ban advances its claimed interest in a stable political system or what makes California so peculiar that it is virtually the only State to determine that such a ban
is necessary. The explanation that the State's compelling interest in stable government embraces a similar interest in party stability is untenable, since a State may enact laws to prevent disruption of political parties from without, but not from within. The claim that a party that issues primary endorsements risks intraparty friction which may endanger its general election prospects is insufficient, since the goal of protecting the party against itself would not justify a State's substituting its judgment for that of the party. The State's claim that the ban is necessary to protect primary voters from confusion and undue influence must be viewed with skepticism, since the ban restricts the flow of information to the citizenry without any evidence of the existence of fraud or corruption that would justify such a restriction. Pp. 489 U. S. 222-229.
(b) The restrictions on the organization and composition of the official governing bodies of political parties, the limits on the term of office for state central committee chairs, and the requirement that such chairs rotate between residents of northern and southern California cannot be upheld. These laws directly burden the associational rights of a party and its members by limiting the party's discretion in how to organize itself, conduct its affairs, and select its leaders. Moreover, the laws do not serve a compelling state interest. A State cannot justify regulating a party's internal affairs without showing that such regulation is necessary to ensure that elections are orderly, fair, and honest, and California has made no such showing. The State's claim that it has a compelling interest in the democratic management of internal party affairs is without merit, since this is not a case where intervention is necessary to prevent the derogation of party adherents' civil rights, and since the State has no interest in protecting the party's integrity against the party itself. Nor are the restrictions justified by the State's claim that limiting the term of the state central committee chair and requiring that the chair rotate between northern and southern California help to prevent regional friction from reaching a critical mass, since a State cannot substitute its judgment for that of the party as to the desirability of a particular party structure. Pp. 489 U. S. 229-233.
826 F.2d 814, affirmed.
MARSHALL, J., delivered the opinion of the Court, in which all other Members joined, except REHNQUIST, C.J., who took no part in the consideration or decision of the case. STEVENS, J., filed a concurring opinion, post, p. 489 U. S. 233.
JUSTICE MARSHALL delivered the opinion of the Court.
The California Elections Code forbids the official governing bodies of political parties from endorsing candidates in party primaries. It also dictates the organization and composition of those bodies, limits the term of office of a party chair, and requires that the chair rotate between residents of northern and southern California. The Court of Appeals for the Ninth Circuit held that these provisions violate the free speech and associational rights of political parties and their members guaranteed by the First and Fourteenth Amendments. 826 F.2d 814 (1987). We noted probable jurisdiction, 485 U.S. 1004 (1988), and now affirm.
The State of California heavily regulates its political parties. Although the laws vary in extent and detail from party to party, certain requirements apply to all "ballot-qualified" parties. [Footnote 1] The California Elections Code (Code) provides that the "official governing bodies" for such a party are its "state convention," "state central committee," and "county central committees," Cal.Elec.Code Ann. § 11702 (West
1977), and that these bodies are responsible for conducting the party's campaigns. [Footnote 2] At the same time, the Code provides that the official governing bodies "shall not endorse, support, or oppose, any candidate for nomination by that party for partisan office in the direct primary election." Ibid. It is a misdemeanor for any primary candidate, or a person on her behalf, to claim that she is the officially endorsed candidate of the party. § 29430.
Although the official governing bodies of political parties are barred from issuing endorsements, other groups are not. Political clubs affiliated with a party, labor organizations, political action committees, other politically active associations, and newspapers frequently endorse primary candidates. [Footnote 3] With the official party organizations silenced by the ban, it has been possible for a candidate with views antithetical to those of her party nevertheless to win its primary. [Footnote 4]
In addition to restricting the primary activities of the official governing bodies of political parties, California also regulates their internal affairs. Separate statutory provisions dictate the size and composition of the state central committees; [Footnote 5] set forth rules governing the selection and removal of committee members; [Footnote 6] fix the maximum term of office for the chair of the state central committee; [Footnote 7] require that the chair rotate between residents of northern and southern California; [Footnote 8] specify the time and place of committee meetings; [Footnote 9] and
limit the dues parties may impose on members. [Footnote 10] Violations of these provisions are criminal offenses punishable by fine and imprisonment.
Various county central committees of the Democratic and Republican Parties, the state central committee of the Libertarian Party, members of various state and county central committees, and other groups and individuals active in partisan politics in California brought this action in federal court against state officials responsible for enforcing the Code (State or California). [Footnote 11] They contended that the ban on primary endorsements and the restrictions on internal party governance deprive political parties and their members of the rights of free speech and free association guaranteed by the First and Fourteenth Amendments of the United States Constitution. [Footnote 12] The first count of the complaint challenged the ban on endorsements in partisan primary elections; the second count challenged the ban on endorsements in nonpartisan school, county, and municipal elections; and the third count challenged the provisions that prescribe the composition of state central committees, the term of office and eligibility criteria for state central committee chairs, the time and place of state and county central committee meetings, and the dues county committee members must pay.
The plaintiffs moved for summary judgment, in support of which they filed 28 declarations from the chairs of each plaintiff central committee, prominent political scientists, and elected officials from California and other States. The State moved to dismiss, and filed a cross-motion for summary judgment supported by one declaration from a former state senator.
The District Court granted summary judgment for the plaintiffs on the first count, ruling that the ban on primary endorsements in §§ 11702 and 29430 violated the First Amendment as applied to the States through the Fourteenth Amendment. The court stayed all proceedings on the second count under the abstention doctrine of Railroad Comm'n of Texas v. Pullman Co.,312 U. S. 496 (1941). [Footnote 13] On the third count, the court ruled that the laws prescribing the composition of state central committees, limiting the committee chairs' terms of office, and designating that the chair rotate between residents of northern and southern California violate the First Amendment. [Footnote 14] The court denied summary judgment with respect to the statutory provisions establishing
the time and place of committee meetings and the amount of dues. Civ. No. C-83-5599 MHP (ND Cal., May 3, 1984).
The Court of Appeals for the Ninth Circuit affirmed. 792 F.2d 802 (1986). This Court vacated that decision, 479 U.S. 1024 (1987), and remanded for further consideration in light of Tashijian v. Republican Party of Connecticut,479 U. S. 208 (1986).
After supplemental briefing, the Court of Appeals again affirmed. 826 F.2d 814 (1987). The court first rejected the State's arguments based on nonjusticiability, lack of standing, Eleventh Amendment immunity, and Pullman abstention. 826 F.2d at 821-825. Turning to the merits, the court characterized the prohibition on primary endorsements as an "outright ban" on political speech. Id. at 833.
Prohibiting the governing body of a political party from supporting some candidates and opposing others patently infringes both the right of the party to express itself freely and the right of party members to an unrestricted flow of political information.
Id. at 835. The court rejected the State's argument that the ban served a compelling state interest in preventing internal party dissension and factionalism: "The government simply has no legitimate interest in protecting political parties from disruptions of their own making." Id. at 834. The court noted, moreover, that the State had not shown that banning primary endorsements protects parties from factionalism. Ibid. The court concluded that the ban was not necessary to protect voters from confusion, stating, "California's ban on preprimary endorsements is a form of paternalism that is inconsistent with the First Amendment." Id. at 836.
The Court of Appeals also found that California's regulation of internal party affairs "burdens the parties' right to govern themselves as they think best." Id. at 827. This interference with the parties' and their members' First Amendment rights was not justified by a compelling state interest, for a State has a legitimate interest "in orderly elections,
not orderly parties." Id. at 831. In any event, the court noted, the State had failed to submit "a shred of evidence,'" id. at 833 (quoting Civ. No. C-83-5599 (ND Cal. May 3, 1984)), that the regulations of party internal affairs helped minimize party factionalism. Accordingly, the court held that the challenged provisions were unconstitutional under the First and Fourteenth Amendments.
A State's broad power to regulate the time, place, and manner of elections
"does not extinguish the State's responsibility to observe the limits established by the First Amendment rights of the State's citizens."
Tashijian v. Republican Party of Connecticut, 479 U.S. at 479 U. S. 217. To assess the constitutionality of a state election law, we first examine whether it burdens rights protected by the First and Fourteenth Amendments. Id. at 479 U. S. 214; Anderson v. Celebrezze,460 U. S. 780, 460 U. S. 789 (1983). If the challenged law burdens the rights of political parties and their members, it can survive constitutional scrutiny only if the State shows that it advances a compelling state interest, Tashijian, supra, at 479 U. S. 217, 479 U. S. 222; Illinois Bd. of Elections v. Socialist Workers Party,440 U. S. 173, 440 U. S. 184 (1979); American Party of Texas v. White,415 U. S. 767, 415 U. S. 780, and n. 11 (1974); Williams v. Rhodes,393 U. S. 23, 393 U. S. 31 (1968), and is narrowly tailored to serve that interest, Illinois Bd. of Elections, supra, at 440 U. S. 185; Kusper v. Pontikiss,414 U. S. 51, 414 U. S. 58-59 (1973); Dunn v. Blumstein,405 U. S. 330, 405 U. S. 343 (1972).
We first consider California's prohibition on primary endorsements by the official governing bodies of political parties. California concedes that its ban implicates the First Amendment, Tr. of Oral Arg. 17, but contends that the burden is "miniscule." Id. at 7. We disagree. The ban directly affects speech, which "is at the core of our electoral
process and of the First Amendment freedoms." Williams v. Rhodes, supra, at 393 U. S. 32. We have recognized repeatedly that "debate on the qualifications of candidates [is] integral to the operation of the system of government established by our Constitution." Buckley v. Valeo,424 U. S. 1, 424 U. S. 14 (1976) (per curiam); see also NAACP v. Claiborne Hardware Co.,458 U. S. 886, 458 U. S. 913 (1982); Carey v. Brown,447 U. S. 455, 447 U. S. 467 (1980); Garrison v. Louisiana,379 U. S. 64, 379 U. S. 74-75 (1964). Indeed, the First Amendment "has its fullest and most urgent application" to speech uttered during a campaign for political office. Monitor Patriot Co. v. Roy,401 U. S. 265, 401 U. S. 272 (1971); see also Mills v. Alabama,384 U. S. 214, 384 U. S. 218 (1966). Free discussion about candidates for public office is no less critical before a primary than before a general election. Cf. Storer v. Brown,415 U. S. 724, 415 U. S. 735 (1974); Smith v. Allwright,321 U. S. 649, 321 U. S. 666 (1944); United States v. Classic,313 U. S. 299, 313 U. S. 314 (1941). In both instances, the "election campaign is a means of disseminating ideas as well as attaining political office." Illinois Bd. of Elections, supra, at 440 U. S. 186.
California's ban on primary endorsements, however, prevents party governing bodies from stating whether a candidate adheres to the tenets of the party or whether party officials believe that the candidate is qualified for the position sought. This prohibition directly hampers the ability of a party to spread its message, and hamstrings voters seeking to inform themselves about the candidates and the campaign issues. See Tashijian, supra, at 479 U. S. 220-222; Pacific Gas & Electric Co. v. Public Utilities Comm'n of California,475 U. S. 1, 475 U. S. 8 (1986); Brown v. Hartlage,456 U. S. 45, 456 U. S. 60 (1982); First National Bank of Boston v. Bellotti,435 U. S. 765, 435 U. S. 791-792 (1978). A "highly paternalistic approach" limiting what people may hear is generally suspect, Virginia State Bd. of Pharmacy v. Virginia Citizens Consumer Council, Inc., 425
U.S. 748, 425 U. S. 770 (1976); see also First National Bank of Boston, supra, at 435 U. S. 790-792, but it is particularly egregious where the State censors the political speech a political party shares with its members. See Roberts v. United States Jaycees,468 U. S. 609, 468 U. S. 634 (1984) (O'CONNOR, J., concurring).
Barring political parties from endorsing and opposing candidates not only burdens their freedom of speech, but also infringes upon their freedom of association. It is well settled that partisan political organizations enjoy freedom of association protected by the First and Fourteenth Amendments. Tashijian, supra, at 479 U. S. 214; see also Elrod v. Burns,427 U. S. 347, 427 U. S. 357 (1976) (plurality opinion). Freedom of association means not only that an individual voter has the right to associate with the political party of her choice, Tashijian, supra, at 479 U. S. 214 (quoting Kusper, supra, at 414 U. S. 57), but also that a political party has a right to "identify the people who constitute the association,'" Tashijian, supra, at 479 U. S. 214 (quoting Democratic Party of United States v. Wisconsin ex rel. La Follette,450 U. S. 107, 450 U. S. 122 (1981)); cf. NAACP v. Alabama ex rel. Patterson,357 U. S. 449, 357 U. S. 460-462 (1958), and to select a "standardbearer who best represents the party's ideologies and preferences." Ripon Society, Inc. v. National Republican Party, 173 U.S.App.D.C. 350, 384, 525 F.2d 567, 601 (1975) (Tamm, J., concurring in result), cert. denied, 424 U.S. 933 (1976).
Depriving a political party of the power to endorse suffocates this right. The endorsement ban prevents parties from promoting candidates
"at the crucial juncture at which the appeal to common principles may be translated into concerted action, and hence to political power in the community."
Tashijian, supra, at 479 U. S. 216. Even though individual members of the state central committees and county central committees are free to issue endorsements, imposing limitation
"on individuals wishing to band together to advance their views on a ballot measure, while placing none on individuals acting alone, is clearly a restraint on the right of association."
Because the ban burdens appellees' rights to free speech and free association, it can only survive constitutional scrutiny if it serves a compelling governmental interest. [Footnote 15] The
State offers two: stable government and protecting voters from confusion and undue influence. [Footnote 16] Maintaining a stable political system is, unquestionably, a compelling state interest. See Storer v. Brown, 415 U.S. at 415 U. S. 736. California, however, never adequately explains how banning parties from endorsing or opposing primary candidates advances that interest. There is no showing, for example, that California's political system is any more stable now than it was in 1963, when the legislature enacted the ban. Nor does the State explain what makes the California system so peculiar that it is virtually the only State that has determined that such a ban is necessary. [Footnote 17]
The only explanation the State offers is that its compelling interest in stable government embraces a similar interest in party stability. Brief for Appellants 47. The State relies heavily on Storer v. Brown, supra, where we stated that, because "splintered parties and unrestrained factionalism may do significant damage to the fabric of government," 415 U.S. at 415 U. S. 736, States may regulate elections to ensure that "some sort of order, rather than chaos . . . accompan[ies] the democratic processes," id. at 415 U. S. 730. Our decision in Storer, however, does not stand for the proposition that a State may enact election laws to mitigate intraparty factionalism during a primary campaign. To the contrary, Storer recognized that "contending forces within the party employ the primary campaign and the primary election to finally settle their differences." Id. at 415 U. S. 735. A primary is not hostile to intraparty feuds; rather, it is an ideal forum in which to resolve them. Ibid.;American Party of Texas v. White, 415 U.S. at 415 U. S. 781. Tashijian recognizes precisely this distinction. In that case, we noted that a State may enact laws to "prevent the disruption of the political parties from without" but not, as in this case, laws "to prevent the parties from taking internal steps affecting their own process for the selection of candidates." 479 U.S. at 479 U. S. 224.
It is no answer to argue, as does the State, that a party that issues primary endorsements risks intraparty friction which may endanger the party's general election prospects. Presumably a party will be motivated by self-interest, and not engage in acts or speech that run counter to its political success. However, even if a ban on endorsements saves a political party from pursuing self-destructive acts, that would
not justify a State substituting its judgment for that of the party. See ibid.; Democratic Party of United States, 450 U.S. at 450 U. S. 124. Because preserving party unity during a primary is not a compelling state interest, we must look elsewhere to justify the challenged law.
The State's second justification for the ban on party endorsements and statements of opposition is that it is necessary to protect primary voters from confusion and undue influence. Certainly the State has a legitimate interest in fostering an informed electorate. Tashijian, supra, at 479 U. S. 220; Anderson v. Celebrezze, 460 U.S. at 460 U. S. 796; American Party of Texas v. White, supra, at 415 U. S. 782, n. 14; Bullock v. Carter,405 U. S. 134, 405 U. S. 145 (1972); Jenness v. Fortson,403 U. S. 431, 403 U. S. 442 (1971). However,
"'[a] State's claim that it is enhancing the ability of its citizenry to make wise decisions by restricting the flow of information to them must be viewed with some skepticism.'"
flow of information between political associations and their members when necessary to prevent fraud and corruption, see Buckley v. Valeo, 424 U.S. at 424 U. S. 26-27; Jenness v. Fortson, supra, at 403 U. S. 442, there is no evidence that California's ban on party primary endorsements serves that purpose. [Footnote 19]
Because the ban on primary endorsements by political parties burdens political speech while serving no compelling governmental interest, we hold that §§ 11702 and 29430 violate the First and Fourteenth Amendment.
We turn next to California's restrictions on the organization and composition of official governing bodies, the limits on the term of office for state central committee chair, and the requirement that the chair rotate between residents of northern and southern California. These laws directly implicate the associational rights of political parties and their members. As we noted in Tashijian, a political party's "determination . . . of the structure which best allows it to pursue its political goals is protected by the Constitution." 479 U.S. at 479 U. S. 224. Freedom of association also encompasses a political party's decisions about the identity of, and the process for electing, its leaders. See Democratic Party of United States, supra, (State cannot dictate process of selecting state delegates to Democratic National Convention);
Cousins v. Wigoda,419 U. S. 477 (1975) (State cannot dictate who may sit as state delegates to Democratic National Convention); cf. Tashijian, supra, at 479 U. S. 235-236 (SCALIA, J., dissenting) ("The ability of the members of [a political p]arty to select their own candidate . . . unquestionably implicates an associational freedom").
The laws at issue burden these rights. 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. [Footnote 20] And by specifying who shall be the members of the parties' official governing bodies, California interferes with the parties' choice of leaders. A party might decide, for example, that it will be more effective if a greater number of its official leaders are local activists, rather than Washington-based elected officials. The Code prevents such a change. A party might also decide that the state central committee chair needs more than two years to successfully formulate and implement policy. The Code prevents such an extension of the chair's term of office. A party might find that a resident of northern California would be particularly effective in promoting the party's message and in unifying the party. The Code prevents her from chairing the state central committee unless the preceding chair was from the southern part of the State.
Each restriction thus limits a political party's discretion in how to organize itself, conduct its affairs, and select its leaders. Indeed, the associational rights at stake are much stronger than those we credited in Tashijian. There, we found that a party's right to free association embraces a right to allow registered voters who are not party members to vote in the party's primary. Here, party members do not seek to
associate with nonparty members, but only with one another in freely choosing their party leaders. [Footnote 21]
Because the challenged laws burden the associational rights of political parties and their members, the question is whether they serve a compelling state interest. A State indisputably has a compelling interest in preserving the integrity of its election process. Rosario v. Rockefeller,410 U. S. 752, 410 U. S. 761 (1973). 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. Storer v. Brown, 415 U.S. at 415 U. S. 730. For example, a State may impose certain eligibility requirements for voters in the general election even though they limit parties' ability to garner support and members. See, e.g., Dunn v. Blumstein, 405 U.S. at 405 U. S. 343-344 (residence requirement); Oregon v. Mitchell,400 U. S. 112, 400 U. S. 118 (1970) (age minimum); Kramer v. Union Free School Dist. No. 15,395 U. S. 621, 395 U. S. 625 (1969) (citizenship requirement). We have also recognized that a State may impose restrictions that promote the integrity of primary elections. See, e.g., American Party of Texas v. White, 415 U.S. at 415 U. S. 779-780 (requirement that major political parties nominate candidates through a primary and that minor parties nominate candidates through conventions); id. at 415 U. S. 785-786 (limitation on voters' participation to one primary and bar on voters both voting in a party primary and signing a petition supporting an independent candidate); Rosario v. Rockefeller, supra, (waiting periods before voters may change party registration and participate in another party's primary); Bullock v. Carter, 405 U.S. at 405 U. S. 145 (reasonable filing fees as a condition of placement on the ballot). None of these restrictions, however, involved direct regulation of
a party's leaders. [Footnote 22] Rather, the infringement on the associational rights of the parties and their members was the indirect consequence of laws necessary to the successful completion of a party's external responsibilities in ensuring the order and fairness of elections.
In the instant case, the State has not shown that its regulation of internal party governance is necessary to the integrity of the electoral process. Instead, it contends that the challenged laws serve a compelling "interest in the democratic management of the political party's internal affairs.'" Brief for Appellants 43 (quoting 415 U.S. at 415 U. S. 781, n. 15). This, however, is not a case where intervention is necessary to prevent the derogation of the civil rights of party adherents. Cf. Smith v. Allwright,321 U. S. 649 (1944). Moreover, as we have observed, the State has no interest in "protect[ing] the integrity of the Party against the Party itself." Tashijian, 479 U.S. at 479 U. S. 224. The State further claims that limiting the term of the state central committee chair and requiring that the chair rotate between residents of northern and southern California helps "prevent regional friction from reaching a `critical mass.'" Brief for Appellants 48. However,
a State cannot substitute its judgment for that of the party as to the desirability of a particular internal party structure any more than it can tell a party that its proposed communication to party members is unwise. Tashijian, supra, at 479 U. S. 224.
In sum, 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. [Footnote 23]
For the reasons stated above, we hold that the challenged California election laws burden the First Amendment rights of political parties and their members without serving a compelling state interest. Accordingly, the judgment of the Court of Appeals is
CHIEF JUSTICE REHNQUIST took no part in the consideration or decision of this case.
A "ballot-qualified" party is eligible to participate in any primary election because: (a) during the last gubernatorial election, one of its candidates for state-wide office received two percent of the vote; (b) one percent of the State's voters are registered with the party; or (c) a petition establishing the party has been filed by ten percent of the State's voters. Cal.Elec.Code Ann. § 6430 (West 1977).
In the interest of simplicity, we use the terms "ballot-qualified party" and "political party" interchangeably.
The Code requires the state central committee of each party to conduct campaigns for the party, employ campaign directors, and develop whatever campaign organizations serve the best interests of the party. Cal.Elec.Code Ann. § 8776 (West Supp.1989) (Democratic Party); § 9276 (Republican Party); § 9688 (American Independent Party); § 9819 (Peace and Freedom Party). The county central committees, in turn, "have charge of the party campaign under general direction of the state central committee." § 8940 (Democratic Party); § 9440 (Republican Party); § 9740 (American Independent Party); § 9850 (Peace and Freedom Party). In addition, they "perform such other duties and services for th[e] political party as seem to be for the benefit of the party." § 8942 (Democratic Party); § 9443 (Republican Party); § 9742 (American Independent Party); § 9852 (Peace and Freedom Party).
For example, while voters cannot learn what the Democratic state and county central committees think of candidates, they may be flooded with endorsements from disparate groups across the State such as the Berkeley Democratic Club, the Muleskinners Democratic Club, and the District 8 Democratic Club. Addendum to Motion to Affirm or to Dismiss 39a
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