Tansley v. Grasso

315 F. Supp. 513, 1970 U.S. Dist. LEXIS 10716
CourtDistrict Court, D. Connecticut
DecidedJuly 31, 1970
DocketCiv. A. Nos. 13937-13939
StatusPublished
Cited by8 cases

This text of 315 F. Supp. 513 (Tansley v. Grasso) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tansley v. Grasso, 315 F. Supp. 513, 1970 U.S. Dist. LEXIS 10716 (D. Conn. 1970).

Opinion

MEMORANDUM OF DECISION

CLARIE, District Judge.

The plaintiffs have petitioned the Court to declare unconstitutional and invalid that part of Conn.Gen.Stat. § 9-400,1 which imposes as a condition [515]*515precedent that a prospective candidate receive the support of at least 20% of the delegate strength in a district convention on any roll call vote, in order to qualify to run in a district office primary which would select the party endorsed nominee.2 The plaintiffs represent that they have otherwise satisfied all the requirements of § 9-400.

District conventions are required for the choosing of candidates for all district offices pursuant to Conn.Gen.Stat. § 9-382. The plaintiffs claim, however, that those running for the same office as they, i. e., in the cases of Tansley and Verriker, state senator, and in the case of Rotatori, probate judge, but whose district is territorially confined to a single municipality as opposed to a multiple town district, are not subject to the same 20% qualifying requirement. These latter offices are classified as “municipal offices”3 and a convention is not required by law prior to their selection as party-endorsed candidates. The statutes precribe that the local party rules may provide for their selection in one of three ways, namely:

“(1) by the enrolled members of such party in the municipality at a caucus or (2) by delegates to a convention chosen in accordance with such rules by such enrolled members or (3) by the town committee of such party.” Conn.Gen.Stat. § 9-390.

To force a primary for a municipal office a potential nominee must obtain 5% of signatures of the electors on the last completed party registration list in the respective district and pay a statutory filing fee.4 This qualifying difference [516]*516between a district and municipal classification of nominees for the same office (senator or judge of probate), the plaintiffs assert constitutes an invidious discrimination against them and is in contravention to the equal protection clause provided under the fourteenth amendment.5

A three-judge district court was convened to hear the plaintiffs’ claims. Jurisdiction is present pursuant to 28 U.S.C. § 1343. See Ex parte Young, 209 U.S. 123, 28 S.Ct. 441, 52 L.Ed. 714 (1908); Baker v. Carr, 369 U.S. 186, 82 S.Ct. 691, 7 L.Ed.2d 663 (1962); Williams v. Rhodes, 393 U.S. 23, 89 S.Ct. 5, 21 L.Ed.2d 24 (1968). The Court finds that the legislature could reasonably conclude that valid practical grounds existed for distinguishing between single and multiple town state senatorial and probate districts and that the challenged statutes are constitutional.

State statutes validly enacted are presumed to be constitutional. United States v. Carolene Products Co., 304 U.S. 144, 148, 58 S.Ct. 778, 82 L.Ed. 1234 (1938); Becker Steel Co. v. Cummings, 296 U.S. 74, 80, 56 S.Ct. 15, 80 L.Ed. 54 (1935); Alaska Packers Assn. v. Industrial Accident Commission, 294 U.S. 532, 543, 55 S.Ct. 518, 79 L.Ed. 1044 (1935). It is the plaintiffs’ burden, if they are to prevail, to demonstrate the invidious discrimination they have alleged. Home Telephone & Telegraph Co. v. Los Angeles, 211 U.S. 265, 281, 29 S.Ct. 50, 53 L.Ed. 176 (1908); Alaska Packers Assn. v. Industrial Accident Commission, supra. In Alaska Packers, the Supreme Court, in upholding a California statute, stated:

“Indulging the presumption of constitutionality which attaches to every state statute, we cannot say that this one, as applied, lacks a rational basis or involved any arbitrary or unreasonable exercise of state power.” 294 U.S. at 543, 55 S.Ct. at 522.

So also in this case, a rational basis for the enactment of the differing standards for the qualification to run in a primary is present.

At the local level, the structure of the two major political parties in Connecticut is by town committee. The statutes provide for the selection of party-endorsed candidates for municipal offices by caucus, convention, or by the town committee, at the discretion of said local committee in accordance with the party rules. Conn.Gen.Stat. § 9-390, quoted supra. While the legislature could have specifically required conventions at this electoral level, it chose otherwise for the obvious reason that it was dealing with [517]*517a different set of circumstances. The recognition of this circumstance at the single-town level is further evidenced by the fact that the legislature provided alternative methods, in § 9-390, for candidate selection even among identical single-town districts, i. e., by caucus, convention or tov/n committee.6 Thus, it may have felt that when dealing with a single town, the interests of the various party factions are adequately represented by party caucus or by the town committee. In this latter group the members themselves are elected and subject to being challenged through the primary system. Conn.Gen.Stat. § 9-406. The interests and objectives of party members in a single municipality are likely to be more uniform, than would be the case where multiple municipalities were involved.

The legislative history of the state primary laws, the various amendments and the legislative action on proposed amendments not adopted, indicate at least that many of the legislators were of the opinion that the caucus provided adequate representation in the smaller towns. See the Joint Standing Committee Hearings on Election, 1957, page 70 et seq. and 1963, page 40 et seq. This conclusion was based on the less complicated party structure and the similarity of interests at the local level. The same conclusion could reasonably have been reached as to the single-town municipal district offices.

When the party endorsement for a district office is at stake, a convention is required 7 for the apparent purpose of granting proportionate representation

from each of the various municipalities in the district. Where multiple municipalities are territorially involved, the interests of the various delegates to the nominating convention are likely to differ at least on local issues.

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Bluebook (online)
315 F. Supp. 513, 1970 U.S. Dist. LEXIS 10716, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tansley-v-grasso-ctd-1970.