In re the Nomination Petitions and Papers of Carl Stevenson as a Candidate for State Representative in the 134th Legislative District

Summary

The Supreme Court of Pennsylvania vacated the Commonwealth Court's order striking Carl Stevenson's name from the ballot and remanded for an immediate determination of individual signature challenges to his nominating paper. The court declined at that stage to resolve the constitutional challenge to Pennsylvania's residency requirement for circulators, while retaining limited jurisdiction to address the issue if necessary.

Holdings

1. The Commonwealth Court's order was not sustainable on the record because it rejected Stevenson's First Amendment and reliance arguments without meaningful substantive analysis and did not resolve the potentially dispositive individual signature challenges.
2. The case had to be remanded for an immediate hearing and determination of the individual signature challenges.
3. The Supreme Court declined to decide the ultimate merits of the First Amendment challenge at that stage.
4. A state court's lack of obligation to follow lower federal-court rulings does not relieve it of its obligation to decide a properly presented federal claim on its merits.

Questions Presented

1. Whether the Commonwealth Court properly sustained the global challenge and ordered Stevenson's name removed from the ballot without substantively addressing his First Amendment and reliance arguments.
2. Whether the case should be remanded for determination of the individual signature challenges before deciding the constitutional question.
3. Whether the Supreme Court should decide the constitutionality and enforceability of 25 P.S. § 2911(d)'s residency requirement.

Disposition

vacated