In re Candidacy of Independence Party Candidates Moore v. Kiffmeyer

Summary

The Minnesota Supreme Court considered whether Independence Party candidates who failed to meet a statutory primary-vote threshold could appear on the 2004 general election ballot. The court held that the primary threshold law violated the petitioners' First and Fourteenth Amendment rights to vote and associate because it served no rational state purpose, and ordered the Secretary of State to certify the candidates who received the most primary votes as the party's nominees.

Holdings

1. The primary threshold law violated petitioners' First and Fourteenth Amendment rights to vote and to associate for the advancement of political beliefs because it denied Independence Party candidates access to the general-election ballot without any rational state purpose.
2. The Secretary of State was ordered to certify the Independence Party candidates who received the most votes in the primary as the party's nominees for placement on the general-election ballot.

Questions Presented

1. Whether the 1996 Legislature repealed the primary threshold law and whether that repeal later expired or revived the prior law.
2. Whether the post-primary nominating-petition process referenced in the primary threshold law was available to the Independence Party candidates.
3. Whether applying the primary threshold law to deny Independence Party candidates access to the general-election ballot violated the First and Fourteenth Amendments to the United States Constitution and analogous rights under the Minnesota Constitution.

Disposition

other