3rd Circ. Orders Clarification of Signature Requirement for Minor Political Parties in Pa.
A federal appeals court has ordered a federal judge to explain why he decided that minor political parties in Pennsylvania should be required to gather a certain number of signatures from a specific number of counties in order to get their candidates on the ballot.
December 14, 2017 at 10:36 AM
7 minute read
A federal appeals court has ordered a federal judge to explain why he decided that minor political parties in Pennsylvania should be required to gather a certain number of signatures from a specific number of counties in order to get their candidates on the ballot.
The U.S. Court of Appeals for the Third Circuit on Wednesday vacated the ruling of U.S. District Chief Judge Lawrence F. Stengel of the Eastern District of Pennsylvania in a challenge to the constitutionality of the state's election laws filed jointly by the Constitution, Green and Libertarian parties of Pennsylvania.
In 2012, the minor parties were successful in their initial challenge to the constitutionality of the state's election law, which says political groups not classified as “major parties” attempting to appear on a ballot need to gather a considerable number of signatures—and the validity of those signatures can be challenged, which can lead to oppressive financial costs for the smaller parties, according to Third Circuit Judge Jane Richards Roth's opinion. The threat of high costs resulting from challenges has deterred some candidates from running.
After their victory, the parties and the state were asked to provide prospective orders as to what the law should require going forward. Stengel adopted the state's version, which was based on a bill pending before the state legislature. It required minor party candidates to gather two and one-half times as many signatures as major party candidates have to in order to be placed on the ballot.
It also provided a county requirement, which mandated that for the Office of Governor, a minor party candidate had to gather at least 5,000 signatures, including a minimum of 250 from at least 10 counties. For other statewide offices, the bill required between 1,250 and 2,500 signatures with at least 250 from at least five counties, according to Roth. Stengel provided no explanation for choosing the state's version.
Roth said that the importance of the subject merited an explanation from the court. She also explored the facets of the arguments for and against county-based requirements.
She explained that county requirements are typically implemented to keep “frivolous candidates” off the ballot by demonstrated significant geographical support.
“However, signature gathering requirements based on geographical units other than counties may serve that interest just as well,” Roth said. “For example, congressional districts must have populations that are 'as nearly as practicable' equal in population; thus, requiring a minimum number of signatures to be gathered from different congressional districts serves the interest of requiring candidates to show support across different geographical areas but does not dilute anyone's voting power. Hence, it is rarely, if ever, necessary to impose county-based signature gathering requirements that significantly burden voting rights.”
She added, “the district court can impose the county-based signature-gathering requirements if it concludes that the requirements would have no appreciable impact on voting rights. The court did not so conclude here, and we have no basis in the record to reach such a conclusion independently.”
Oliver B. Hall of the Center for Competitive Democracy in Washington, D.C., represented the parties.
“We prevailed on appeal and the court has vacated the requirement that we were challenging, so we're happy with that,” Hall said. “Now the case has to go back to the district court to fashion a remedy that doesn't raise the constitutional concerns that the prior order did.”
The state Attorney General's Office, which handled the case for defendant and former Commonwealth Secretary Pedro Cortes, did not respond to a request for comment.
A federal appeals court has ordered a federal judge to explain why he decided that minor political parties in Pennsylvania should be required to gather a certain number of signatures from a specific number of counties in order to get their candidates on the ballot.
The U.S. Court of Appeals for the Third Circuit on Wednesday vacated the ruling of U.S. District Chief Judge
In 2012, the minor parties were successful in their initial challenge to the constitutionality of the state's election law, which says political groups not classified as “major parties” attempting to appear on a ballot need to gather a considerable number of signatures—and the validity of those signatures can be challenged, which can lead to oppressive financial costs for the smaller parties, according to Third Circuit Judge
After their victory, the parties and the state were asked to provide prospective orders as to what the law should require going forward. Stengel adopted the state's version, which was based on a bill pending before the state legislature. It required minor party candidates to gather two and one-half times as many signatures as major party candidates have to in order to be placed on the ballot.
It also provided a county requirement, which mandated that for the Office of Governor, a minor party candidate had to gather at least 5,000 signatures, including a minimum of 250 from at least 10 counties. For other statewide offices, the bill required between 1,250 and 2,500 signatures with at least 250 from at least five counties, according to Roth. Stengel provided no explanation for choosing the state's version.
Roth said that the importance of the subject merited an explanation from the court. She also explored the facets of the arguments for and against county-based requirements.
She explained that county requirements are typically implemented to keep “frivolous candidates” off the ballot by demonstrated significant geographical support.
“However, signature gathering requirements based on geographical units other than counties may serve that interest just as well,” Roth said. “For example, congressional districts must have populations that are 'as nearly as practicable' equal in population; thus, requiring a minimum number of signatures to be gathered from different congressional districts serves the interest of requiring candidates to show support across different geographical areas but does not dilute anyone's voting power. Hence, it is rarely, if ever, necessary to impose county-based signature gathering requirements that significantly burden voting rights.”
She added, “the district court can impose the county-based signature-gathering requirements if it concludes that the requirements would have no appreciable impact on voting rights. The court did not so conclude here, and we have no basis in the record to reach such a conclusion independently.”
Oliver B. Hall of the Center for Competitive Democracy in Washington, D.C., represented the parties.
“We prevailed on appeal and the court has vacated the requirement that we were challenging, so we're happy with that,” Hall said. “Now the case has to go back to the district court to fashion a remedy that doesn't raise the constitutional concerns that the prior order did.”
The state Attorney General's Office, which handled the case for defendant and former Commonwealth Secretary Pedro Cortes, did not respond to a request for comment.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllPa. High Court to Weigh Parent Company's Liability for Dissolved Subsidiary's Conduct
3 minute readDon’t Settle for the Minimum: Finding Constitutional Claims Closer to Home
7 minute readMatt's Corner: RPC 8.4(d)—Conduct Prejudicial to the Administration of Justice
2 minute readTrending Stories
- 1Judicial Ethics Opinion 24-68
- 2Friday Newspaper
- 3Judge Denies Sean Combs Third Bail Bid, Citing Community Safety
- 4Republican FTC Commissioner: 'The Time for Rulemaking by the Biden-Harris FTC Is Over'
- 5NY Appellate Panel Cites Student's Disciplinary History While Sending Negligence Claim Against School District to Trial
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250