Gonzalez v. Surgeon, 284 Conn. 573

Summary

The Connecticut Supreme Court considered whether General Statutes § 9-410(c), which limits the candidates for whom a person may circulate primary-election petitions, was unconstitutionally vague and unlawfully restricted freedom of speech and association. The court held that the statute was sufficiently clear and imposed only a limited burden on core political speech, and it affirmed the trial court’s judgment for the defendants.

Holdings

1. Section 9-410(c) is not unconstitutionally vague because its meaning is clear from the statute's context, purpose, and legislative history, even under the more stringent vagueness test applied to statutes implicating First Amendment rights.
2. Section 9-410(c) does not violate the First Amendment because it imposes only a slight burden on core political speech and furthers important state interests.

Questions Presented

1. Whether § 9-410(c) is void for vagueness under the due process clause of the Fifth Amendment because it does not clearly specify which petitions must be rejected when a circulator works for multiple candidates or whether it applies to placeholder candidates.
2. Whether § 9-410(c) violates the First Amendment rights of free speech and association by restricting circulators to one candidate or slate for the same office.

Disposition

affirmed