Munro v. Socialist Workers Party

*200Justice Marshall,

with whom Justice Brennan joins, dissenting.

Limitations on ballot access burden two fundamental rights: “the right of individuals to associate for the advancement of political beliefs, and the right of qualified voters, regardless of their political persuasion, to cast their votes effectively.” Williams v. Rhodes, 393 U. S. 23, 30 (1968). These fundamental rights are implicated most clearly where minor-party access to the ballot is restricted. As we noted in Illinois Board of Elections v. Socialist Workers Party, 440 U. S. 173, 185 (1979), “[t]he States’ interest in screening out frivolous candidates must be considered in light of the significant role that third parties have played in the political development of the Nation.”

The minor party’s often unconventional positions broaden political debate, expand the range of issues with which the electorate is concerned, and influence the positions of the majority, in some instances ultimately becoming majority positions. And its very existence provides an outlet for voters to express dissatisfaction with the candidates or platforms of the major parties. Notwithstanding the crucial role minor parties play in the American political arena, the Court holds today that the associational rights of minor parties and their supporters are not unduly burdened by a ballot access statute that, in practice, completely excludes minor parties from participating in statewide general elections.

h — I

The Court fails to articulate the level of scrutiny it applies in holding that the Washington 1% primary vote requirement is not an unconstitutional ballot access restriction. While it recognizes that “[Restrictions upon the access of political parties to the ballot impinge upon the rights of individuals to associate for political purposes, as well as the rights of qualified voters to cast their votes effectively . . . and may not survive scrutiny under the First and Fourteenth Amendments,” *201ante, at 193, the Court'fails to indicate how much impingement would be too much or how great the State’s interest must be to limit ballot access to candidates who have demonstrated a particular level of popular support.

By contrast, the standard of review set forth in our prior decisions is clear: Whether viewed as a burden on the right to associate or as discrimination against minor parties, a provision that burdens minor-party access to the ballot must be necessary to further a compelling state interest, and must be narrowly tailored to achieve that goal. Illinois Board of Elections v. Socialist Workers Party, supra, at 184; American Party of Texas v. White, 415 U. S. 767, 780 (1974); Clements v. Fashing, 457 U. S. 957, 977, n. 2 (1982) (Brennan, J., dissenting); see also id., at 964-965 (plurality opinion). The necessity for this approach becomes evident when we consider that major parties, which by definition are ordinarily in control of legislative institutions, may seek to perpetuate themselves at the expense of developing minor parties. The application of strict scrutiny to ballot access restrictions ensures that measures taken to further a State’s interest in keeping frivolous candidates off the ballot do not incidentally impose an impermissible bar to minor-party access. See Elder, Access to the Ballot By Political Candidates, 83 Dick. L. Rev. 387, 406 (1979); Williams v. Rhodes, supra, at 32.

Appellant argues that there is no ballot access limitation here at all, and thus no need for the application of heightened scrutiny, because minor parties can appear on a primary ballot simply by meeting reasonable petition requirements. I cannot accept, however, as a general proposition, that access to any ballot is always constitutionally adequate. The Court, in concluding here that the State may reserve the general election ballot for “‘major struggles,”’ ante, at 196, quoting Storer v. Brown, 415 U. S. 724, 735 (1974), appears to acknowledge that, because of its finality, the general election is the arena where issues are sharpened, policies are hotly de*202bated, and the candidates’ positions are clarified. Nonetheless, the Court deems access to the primary adequate to satisfy minor-party rights to ballot access, even though we have characterized the primary election principally as a “forum for continuing intraparty feuds,” Storer v. Brown, supra, at 735, rather than an arena for debate on the issues. Access to a primary election ballot is not, in my view, all the access that is due when minor parties are excluded entirely from the general election.1

The Court’s conclusion stems from a fundamental misconception of the role minor parties play in our constitutional scheme. To conclude that access to a primary ballot is adequate ballot access presumes that minor-party candidates seek only to get elected. But, as discussed earlier, minor: party participation in electoral politics serves to expand and affect political debate. Minor parties thus seek “influence, if not always electoral success.” Illinois Board of Elections v. Socialist Workers Party, supra, at 185-186; cf. Williams v. Rhodes, supra, at 32 (States may not keep “all political parties off the ballot until they have enough members to win”). Their contribution to “diversity and competition in the marketplace of ideas,” Anderson v. Celebrezze, 460 U. S. 780, 794 (1983), does not inevitably implicate their ability to win elections. That contribution cannot be realized if they are unable to participate meaningfully in the phase of the electoral process in which policy choices are most seriously considered. A statutory scheme that excludes minor parties entirely from this phase places an excessive burden on the *203constitutionally protected associational rights of those parties and their adherents.

The Court suggests that any ballot access limitation that merely requires a preliminary showing of support is constitutionally acceptable. Ante, at 193. In past cases, however, we have acknowledged only that there is “an important state interest in requiring some preliminary showing of a significant modicum of support before printing the name of a political organization’s candidate on the ballot — the interest, if no other, in avoiding confusion, deception, and even frustration of the democratic process at the general election.” Jenness v. Fortson, 403 U. S. 431, 442 (1971). It still remains for the State to demonstrate that the statute is “properly drawn,” employing the “least drastic means” to achieve the State’s ends. Illinois Board of Elections v. Socialist Workers Party, 440 U. S., at 185. The State fails, in my opinion, to do so here.

I am unconvinced that the Washington statute serves the asserted justification for the law: avoiding ballot overcrowding and voter confusion. The statute streamlines the general election, where overcrowding and confusion appear never to have been much of a problem before the 1977 amendments, at the expense of an already cumbersome primary ballot. Between 1907 and 1977, no more than six minor-party candidates ever appeared on the general election ballot for any statewide office, and no more than four ever ran for any statewide office other than Governor, suggesting that the ballot was never very crowded. 765 F. 2d 1417, 1420 (CA9 1985); cf. Williams v. Rhodes, 393 U. S., at 47 (Harlan, J., concurring in result) (“[T]he presence of eight candidacies cannot be said, in light of experience, to carry a significant danger of voter confusion”). But in the 1983 special election that prompted this lawsuit, appellee Peoples, instead of being placed on the general election ballot with 2 other candidates, was placed on the primary ballot along with 32 other *204candidates: 18 Democrats and 14 Republicans. 765 F. 2d, at 1420.

The Court notes that we have not previously required a State seeking to impose reasonable ballot access restrictions to make a particularized showing that voter confusion in fact existed before those restrictions were imposed. Ante, at 194-196. But where the State’s solution exacerbates the very problem it claims to solve, the State’s means cannot be even rationally related to its asserted ends.

The Court seems not at all troubled by the State’s insistence on a clear and unencumbered general election ballot and the State’s simultaneous willingness to employ “a long and complicated ballot at the primary.” Ante, at 196. The Court evidently deems legitimate the State’s decision to befuddle the voters in the only election that now matters to minor-party candidates and their adherents in order to guarantee a negligible increase in ballot clarity at the general election. Since minor parties are only allowed access to the primary election ballot, the discovery that the State’s asserted interest in an uncrowded ballot coincidentally extends only to the general election has constitutional significance. Rather than alleviating the harm the statute purports to prevent, the law simply shifts any possible harm to the primary election, which, deliberately or unintentionally, decreases the prospect of a minor-party candidate for statewide office qualifying for the general election.

Additionally, while a State may have an interest in eliminating frivolous candidates by requiring candidates to demonstrate “a significant modicum of support” to qualify for a place on the ballot, Washington already had a mechanism that required minor-party candidates to show such support, which it retained after its imposition of the 1% primary vote requirement in 1977. Appellees did not challenge the legitimacy of the convention and petition requirements in this case, but the fact that a mechanism for requiring some showing of support previously existed casts doubt on the need for *205the imposition of still another requirement on minor-party candidates. Moreover, the application of the 1% requirement suggests it is overbroad, avoiding frivolous candidacies only by excluding virtually all minor-party candidates from general elections for statewide office.

The only purpose this statute seems narrowly tailored to advance is the impermissible one of protecting the major political parties from competition precisely when that competition would be most meaningful. Because the statute burdens ap-pellees’ First Amendment interests, it must be subjected to strict scrutiny; because it fails to pass such scrutiny, it is unconstitutional.

I — i HH

Even if I were prepared to adopt the nebulous logic the Court employs in preference to the mandatory strict standard of review in this case, I could not reach the majority’s result. While this Court has in the past acknowledged that limits on minor-party access to the ballot may in some circumstances be appropriate, we have made equally clear that States may not employ ballot access limitations which result in the exclusion of minor parties from the ballot. See Williams v. Rhodes, supra. “The Constitution requires that access to the electorate be real, not ‘merely theoretical.’” American Party of Texas, 415 U. S., at 783, quoting Jenness v. Fortson, supra, at 439.

Under this reasoning, the validity of ballot access limitations is a function of empirical evidence: A minor party is not impermissibly burdened by ballot access restrictions when “a reasonably diligent independent candidate” could be expected to satisfy the ballot access requirement. Storer v. Brown, 415 U. S., at 742; see American Party of Texas, supra, at 784, n. 16. We have therefore sustained restrictions on ballot access where they did not impose “insurmountable obstacles to fledgling political party efforts to generate support among the electorate and to evidence that support within the time allowed.” 415 U. S., at 784. In *206American Party of Texas, we sustained a 1% petition signature requirement because it was apparent that it was, in practice, neither “impossible nor impractical,” id., at 783, for minor parties to demonstrate this level of support. Indeed, two of the minor parties that were plaintiffs in American Party of Texas qualified candidates for the general election ballot under the ballot access restrictions there at issue. Id., at 779. Similarly, in Jenness v. Fortson, 403 U. S., at 439, we approved Georgia’s 5% petition requirement for ballot access, in part relying on the fact that “[t]he open quality of the Georgia system [was] far from merely theoretical” because a candidate for Governor in 1966 and a candidate for President in 1968 had each gained access to the general election ballot through the nominating petition route.

Here, by contrast, Washington’s primary law acts as an almost total bar to minor-party access to statewide general election ballots. Since the revision of Wash. Rev. Code §29.18.110 in 1977, minor-party candidates have been, in the words of the Court of Appeals, “substantially eliminated from Washington’s general election ballot.” 765 F. 2d, at 1419. The Court of Appeals found that by 1984, only one minor-party candidate had been able to surmount the 1% barrier and earn the right to participate in the general election. Ibid.2 The legislation leading to this substantial elimination of minor parties from the political arena in Washington’s general elections should not be sustained as a legitimate requirement of a demonstration of significant support.

Since Williams v. Rhodes, this Court has recognized that state legislation may not ensure the continuing supremacy of the two major parties by precluding minor-party access to the ballot as a practical matter. Yet here the Court sustains *207a statute that does just that. In doing so, the Court permits a State to pre-empt meaningful participation by minor parties in the political process by requiring them to demonstrate their support in a crowded primary election. The Court thus holds that minor parties may be excised from the electoral process before they have fulfilled their central role in our democratic political tradition: to channel dissent into that process in a constructive fashion. Respectfully, I dissent.

See Socialist Workers Party v. Secretary of State, 412 Mich. 571, 317 N. W. 2d 1 (1982), in which the Michigan Supreme Court struck down a statute requiring a showing of voter support at a primary election in order to give new political parties access to the general election ballot. The court found that such “restrictions on access work to eliminate political and ideological alternatives at the time major party candidates are selected and before campaigning has identified and sharpened the issues facing the electorate.” Id., at 588, 317 N. W. 2d, at 6-7.

This was the Libertarian candidate for State Treasurer in 1984. Brief for Appellees 9; App. 145-146. Neither the Democratic nor Republican candidates were opposed for their party nomination, and no other minor-party candidates participated in the primary. Sample Primary Election Ballot, Clark County, Washington, Sept. 18, 1984.