Legal Principle at Issue
Whether a state, through its election laws, may constitutionally (1) prohibit a political party in one district from using the same name that a different political party uses in another district; (2) require more signatures to get on the ballot in a multidistrict political subdivision than are required to get on a state-wide ballot; and (3) require a political party seeking to be on ballots in both suburban Cook County and in Chicago to obtain 25,000 signatures from both areas.
Affirmed and reversed (or vacated) in part and remanded. Petitioning party received a favorable disposition.
The Petitioners in this case sought to expand the Harold Washington Party, an established party within the City of Chicago, to the surrounding suburbs within Cook County. Under Illinois law, the organizers of a new political party must collect 25,000 signatures of eligible voters in order to field a candidate for state office. If the organizers wish to run candidates solely for offices within a large political subdivision, such as Cook County, they must obtain 25,000 signatures from that subdivision. If the subdivision is comprised of separate "districts," the organizers must obtain 25,000 signatures from each district. Cook County contains two districts city and suburban. Illinois law also provides that a new political party may not use the name of an established political party.
The Petitioners gathered 44,000 signatures from the city district, but only 7,800 signatures from the suburban district. When the Petitioners' slate of candidates was challenged on several grounds, the Cook County Officers Electoral Board ruled that the Petitioners could use the Harold Washington Party name in the suburban district elections and that the failure to gather 25,000 signatures from the suburban district disqualified the candidates who were running only for suburban district offices, but did not disqualify the party's candidates running for city and county-side seats. On appeal, the trial court affirmed the Board's ruling on the use of the party name but held that the failure to obtain 25,000 signatures from the suburban district doomed the entire slate of candidates. The Illinois Supreme Court ruled that Illinois law prohibited use of the party name and that the inability to obtain 25,000 signatures in the suburban district required disqualification of the entire slate of candidates.
A court considering a challenge to an election law must balance the magnitude of the injury to the challenger's First Amendment rights against the offered justifications for the law, taking into account the extent to which the justifications make it necessary to burden the challenger's rights. Anderson v. Celebrezze, 460 U.S. 780 (1983). When the challenger's rights are subjected to severe restrictions, the regulation must be narrowly drawn to advance a compelling state interest. Illinois Elections Bd. v. Socialist Workers Party, 440 U.S. 173 (1979). When the restrictions are only reasonable and nondiscriminatory, however, the state's important regulatory interests are generally sufficient to justify the restrictions. Anderson v. Celebrezze, 460 U.S. 780 (1983).
Importance of Case
The Court paid little deference to the Illinois Supreme Court's holdings on these issues and held that the Illinois Supreme Court's interpretation of the name prohibition was unnecessarily broad and therefore unconstitutional. The Court also held that 25,000-signature-per- district requirement was unconstitutional as applied to a county-wide race because a state cannot require organizers to gather twice as many signatures to field candidates in a county as would be needed to field a candidate statewide. The Court, however, agreed that the failure to obtain the 25,000 signatures in a district race could constitutionally disqualify the party's candidate for that office.