Buckley v. American Constitutional Law Foundation, Inc., 525 U.S. 182, 35 (1999)

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216

BUCKLEY v. AMERICAN CONSTITUTIONAL LAW FOUNDATION, INC.

Opinion of OTMConnor, J.

The Court succinctly described this standard in Burdick v. Takushi, 504 U. S. 428 (1992):

"[W]hen [First and Fourteenth Amendment] rights are subjected to severe restrictions, the regulation must be narrowly drawn to advance a state interest of compelling importance. But when a state election law provision imposes only reasonable, nondiscriminatory restrictions upon the First and Fourteenth Amendment rights of voters, the State's important regulatory interests are generally sufficient to justify the restrictions." Id., at 434 (internal quotation marks and citations omitted).

Applying this test, in Burdick, we upheld as reasonable Hawaii's prohibition on write-in voting, holding that it imposed only a limited burden upon the constitutional rights of voters. See id., at 433-441. See also Timmons v. Twin Cities Area New Party, 520 U. S. 351, 362-370 (1997) (up-holding Minnesota law that banned fusion candidacies on the ground that the State had asserted a "sufficiently weighty" interest). The application of this flexible standard was not without precedent. Prior to Burdick, the Court applied a test akin to rational review to regulations that governed only the administrative aspects of elections. See Rosario v. Rockefeller, 410 U. S. 752, 756-762 (1973) (upholding requirement that voters enroll as members of a political party prior to voting in a primary election on the ground that the regulation did not impose an onerous burden and advanced a legitimate state interest).

Under the Burdick approach, the threshold inquiry is whether Colorado's regulations directly and substantially burden the one-on-one, communicative aspect of petition circulation or whether they primarily target the electoral process, imposing only indirect and less substantial burdens on communication. If the former, the regulation should be subject to strict scrutiny. If the latter, the regulation should be subject to review for reasonableness.

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