Crafts v. Quinn

Summary

The Maine Supreme Judicial Court dismissed an interlocutory appeal from the denial of a preliminary injunction seeking to place Libertarian and Populist presidential candidates on the 1984 ballot. The court held that the appellants did not qualify for an exception to the final judgment rule, in part because their lack of diligence and failure to satisfy petition requirements caused the timing problem. The court alternatively concluded that the Superior Court did not err in denying relief because the plaintiffs had not shown sufficient likelihood of success, and the burdens on the State and public interest outweighed the claimed injuries.

Holdings

1. The appeal was not within the death knell exception because the plaintiffs' own lack of diligence created the time pressure on which they relied, they had not completed the statutory requirements even by oral argument, and their delay impaired the opportunity for third-party challenges to the petitions.
2. The Superior Court did not plainly err or commit an error of law in denying the mandatory preliminary injunction.
3. The plaintiffs failed to demonstrate a substantial possibility that the challenged requirements were unconstitutional; Maine's minimum-signature threshold and petition-challenge procedure did not unfairly or unnecessarily burden political opportunity on the record presented.

Questions Presented

1. Whether the interlocutory appeal from the denial of a mandatory preliminary injunction was reviewable under an exception to Maine's final judgment rule, including the death knell doctrine.
2. Whether the Superior Court plainly erred or committed an error of law in denying a mandatory preliminary injunction requiring placement of the candidates' names on the ballot.
3. Whether Maine's petition, verification, consent, challenge, and filing requirements imposed an unconstitutional burden on ballot access under the First and Fourteenth Amendments.

Disposition

dismissed