Timmons v. Twin Cities Area New Party
Annotate this Case
520 U.S. 351 (1997)
OCTOBER TERM, 1996
TIMMONS, ACTING DIRECTOR, RAMSEY COUNTY DEPARTMENT OF PROPERTY RECORDS AND REVENUE, ET AL. v. TWIN CITIES AREA NEW PARTY
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT
No. 95-1608. Argued December 4, 1996-Decided April 28, 1997
Most States ban multiple-party, or "fusion," candidacies for elected office.
Minnesota's laws prohibit an individual from appearing on the ballot as the candidate of more than one party. When respondent, a chapter of the national New Party, chose as its candidate for state representative an individual who was already the candidate of another political party, local election officials refused to accept the New Party's nominating petition. The party filed suit against petitioners, Minnesota election officials, contending that the State's antifusion laws violated its associational rights under the First and Fourteenth Amendments. The District Court granted petitioners summary judgment, but the Court of Appeals reversed, finding that the fusion ban was unconstitutional because it severely burdened the party's associational rights and was not narrowly tailored to advance Minnesota's valid interests in avoiding intraparty discord and party splintering, maintaining a stable political system, and avoiding voter confusion.
Held: Minnesota's fusion ban does not violate the First and Fourteenth Amendments. Pp. 356-370.
(a) While the First Amendment protects the right of citizens to associate and to form political parties for the advancement of common political goals and ideas, Colorado Republican Federal Campaign Comm. v. Federal Election Comm'n, 518 U. S. 604, 616, States may enact reasonable regulations of parties, elections, and ballots to reduce election- and campaign-related disorder, Burdick v. Takushi, 504 U. S. 428, 433. When deciding whether a state election law violates First and Fourteenth Amendment associational rights, this Court must weigh the character and magnitude of the burden the State's rule imposes on those rights against the interests the State contends justify that burden, and consider the extent to which the State's concerns make the burden necessary. Id., at 434. Regulations imposing severe burdens must be narrowly tailored and advance a compelling state interest. Lesser burdens, however, trigger less exacting review, and a State's important regulatory interests will usually be enough to justify reasonable, nondiscriminatory restrictions. Ibid. No bright line separates permis-
sible election-related regulation from unconstitutional infringements on First Amendment freedoms. Storer v. Brown, 415 U. S. 724, 730. Pp.356-359.
(b) Minnesota's fusion ban does not severely burden the New Party's associational rights. The State's laws do not restrict the ability of the party and its members to endorse, support, or vote for anyone they like or directly limit the party's access to the ballot. The party's preferred candidate will still appear on the ballot, although as another party's candidate. The laws are also silent on parties' internal structure, governance, and policymaking. Eu v. San Francisco County Democratic Central Comm., 489 U. S. 214, and Tashjian v. Republican Party of Conn., 479 U. S. 208, distinguished. Instead, these provisions reduce the universe of potential candidates who may appear on the ballot as the party's nominee and limit, slightly, the party's ability to send a particularized message, to its candidate and to the voters, about the nature of its support for the candidate. However, ballots are designed primarily to elect candidates, not to serve as forums for political expression. See Burdick, supra, at 438. pp. 359-363.
(c) Because Minnesota's fusion ban does not impose a severe burden on the New Party's rights, the State is required to show, not that the ban was narrowly tailored to serve compelling state interests, but that the State's asserted regulatory interests are "sufficiently weighty to justify the limitation" on the party's rights. Norman v. Reed, 502 U. S. 279, 288-289. Elaborate, empirical verification of weightiness is not required. See Munro v. Socialist Workers Party, 479 U. S. 189, 195-196. Here, the burden is justified by "correspondingly weighty" valid state interests in ballot integrity and political stability. States certainly have an interest in protecting the integrity, fairness, and efficiency of their ballots and election processes as means for electing public officials. E. g., Bullock v. Carter, 405 U. S. 134, 145. Minnesota fears that a candidate or party could easily exploit fusion as a way of associating his or its name with popular slogans and catchphrases, transforming the ballot from a means of choosing candidates to a billboard for political advertising. It is also concerned that fusion might enable minor parties, by nominating a major party's candidate, to bootstrap their way to major-party status in the next election and circumvent the State's nominating-petition requirement for minor parties, which is designed to ensure that only bona fide minor and third parties are granted access to the ballot. The State's strong interest in the stability of its political systems, see, e. g., Eu, supra, at 226, does not permit it to completely insulate the two-party system from minor parties' or independent candidates' competition and influence, e. g., Anderson v. Celebrezze, 460 U. S. 780, 802, and is not a paternalistic license for States to protect political