Manifold v. Blunt

863 F.2d 1368, 1988 WL 131917
CourtCourt of Appeals for the Eighth Circuit
DecidedDecember 14, 1988
DocketNo. 88-2394
StatusPublished
Cited by13 cases

This text of 863 F.2d 1368 (Manifold v. Blunt) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Manifold v. Blunt, 863 F.2d 1368, 1988 WL 131917 (8th Cir. 1988).

Opinions

MAGILL, Circuit Judge.

I. INTRODUCTION

This case involves an equal protection challenge to Missouri’s “new party” ballot access statute. The Libertarian Party of Missouri and several of its members (Libertarians) challenged the constitutionality of Missouri’s statutory requirement that new political parties certify their presidential electors earlier than established parties. The district court1 denied the Libertarians’ motion for an injunction requiring the Secretary of the State of Missouri to place the Libertarian Party candidates for President and Vice-President of the United States on Missouri’s 1988 general election ballot. This expedited appeal followed. On September 22, 1988, 860 F.2d 1086, this panel issued a final order affirming the order of the district court, Judge Heaney dissenting, with opinion and dissent to follow. We issued mandate at that time. We now reaffirm the order of the district court.

II. BACKGROUND

The Libertarian Party initiated this action after the Libertarians’ candidates for President and Vice-President were declared ineligible to appear on Missouri’s general election ballot. On August 1,1988, the Libertarian Party of Missouri presented Missouri’s Secretary of State with a recognition petition containing sufficient signatures to qualify the Libertarians as a new political party under Missouri law.2 [1370]*1370The Libertarians did not present their final list of presidential electors or declarations of their candidacy until September 7, 1988.3 On September 8, 1988, the Secretary of State informed the Libertarian Party that its candidates for president and vice-president would not appear on the Missouri ballot for the November 1988 election because the party had failed to file the final list of electors, along with their candidacy state[1371]*1371ments, by August 1, 1988. The Secretary of State accepted the Libertarian Party as a newly recognized party for offices other than president and vice-president. According to this ruling, the Missouri ballot for the November 1988 election will include Libertarian candidates for governor, lieutenant governor, treasurer, secretary of state, United States senator and United States representative — but will not list Libertarian presidential and vice-presidential candidates.

After learning that the Secretary of State refused to include the Libertarian presidential and vice-presidential candidates on the November ballot, the Libertarians sought to have certain provisions of the Missouri election laws4 declared unconstitutional on equal protection grounds5 and to permanently enjoin the Secretary of State from printing the ballot without the names of the Libertarian presidential and vice-presidential candidates listed on it. On September 16, 1988, the district court denied the Libertarian Party’s request for relief, refusing to enjoin the state from printing the 1988 general election ballot without the Libertarian presidential and vice-presidential candidates.

The district court applied the method of analysis set forth by the United States Supreme Court in Anderson v. Celebrezze, 460 U.S. 780, 103 S.Ct. 1564, 75 L.Ed.2d 547 (1983). In Anderson, the Court held that, when faced with a restriction on voters’ rights to vote for candidates of their choice or candidates’ right to run for office, a court must first consider the character and magnitude of the asserted injury, then identify and evaluate the state’s interest asserted as justification for the burden imposed by the rule. Anderson, 460 U.S. at 789, 103 S.Ct. at 1570. The district court found that the Libertarians clearly established the character and magnitude of the rights they allege have been violated. The court determined that the state’s interest in assuring the integrity of the election ballot justified the burden imposed on new parties. Finally, the court found that requiring new parties to file a final list of electors and their candidacy statements with the recognition petition is a reasonable means of advancing the state’s interest.

The Libertarian Party appealed to this court. We agreed to review the matter immediately in light of Missouri’s requirement that absentee ballots be available by September 27, 1988.6

III. DISCUSSION

A. Statutory Construction

The Libertarian Party’s argument on appeal focuses on the language of the Missouri statute that requires a new party to include the names of candidates for presidential electors with the party’s recognition petition “if presidential electors are to be nominated by petition.” Mo.Rev. Stat. § 115.315 (emphasis added). The Libertarians argue that the statute does not, on its face, require new parties to submit information about their presidential electors at the time they submit their recognition petition. Their argument implies that new parties, at their own option, may choose to nominate electors through the recognition petition, or may choose to nominate electors by some other method not subject to the recognition petition deadline.

We find that Missouri law clearly requires new parties to include a list of presidential electors and their candidacy statements at the time of filing a new party recognition petition.7 Section 115.327, enti-[1372]*1372tied “Declaration of candidacy, when required, form of” states:

When submitted for filing, each petition for the * * * formation of a new political party shall include a declaration of candidacy for each candidate to be nominated by the petition. Each declaration of candidacy for the office of presidential elector shall be in the form provided in section 115.399.

Mo.Rev.Stat. § 115.327. As the district court found, § 115.327 requires new parties to include presidential elector information as part of their recognition petition.

The Libertarians bolster their assertion that elector candidacy statements need not be submitted at the same time as recognition petitions with language from our ruling in Libertarian Party v. Bond, 764 F.2d 538 (8th Cir.1985). In Libertarian Party v. Bond, we stated, in reference to § 115.317, that “[o]nce a new party meets the signature requirement, it need do nothing more in order to get its candidates on the ballot.” 764 F.2d at 542. Taken in proper context, however, this quotation was comparing the requirements of § 115.317 with the overly stringent recognition schemes found unconstitutional in other states. See Williams v. Rhodes, 393 U.S. 23, 89 S.Ct. 5, 21 L.Ed.2d 24 (1968) (ballot access scheme declared unconstitutional where, even after meeting the signature requirement, the new party was required to engage in elaborate primary election machinery to get its candidates on the ballot). Furthermore, in light of the statutory requirement that new parties include presidential elector information with their recognition petitions, a new party must include such information on the petition in order to meet the signature requirement of § 115.317.

B.

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Manifold v. Blunt
863 F.2d 1368 (Eighth Circuit, 1988)

Cite This Page — Counsel Stack

Bluebook (online)
863 F.2d 1368, 1988 WL 131917, Counsel Stack Legal Research, https://law.counselstack.com/opinion/manifold-v-blunt-ca8-1988.