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Moore v. Ogilvie

Supreme Court of the United States · 1969 · Constitutional Law
Constitutional LawEqual ProtectionElection LawBallot AccessEqual Protection Clauseone person one voteballot accessindependent candidates

Facts

Illinois required independent candidates for statewide office to file petitions signed by at least 25,000 qualified electors, including at least 200 qualified voters from each of at least 50 counties. In 1968, the appellants filed petitions containing 26,500 qualified voter signatures, but they were denied certification because they did not satisfy the 50-county distribution proviso. The Court noted that 93.4% of Illinois' registered voters lived in the 49 most populous counties, while only 6.6% lived in the remaining 53 counties. The challenged requirement therefore prevented voters in the 49 populous counties alone from forming a new party or placing candidates on the ballot, while a much smaller and more dispersed rural electorate could do so.

Issue

Whether Illinois may, consistent with the Equal Protection Clause, require independent candidates for statewide office to obtain 25,000 signatures including at least 200 signatures from each of at least 50 counties. Also, whether the case was moot after the 1968 election had passed.

Rule

When a State uses nominating petitions as an integral part of its election process, the procedure must satisfy the Equal Protection Clause and may not employ a rigid county-based formula that favors residents of sparsely populated counties over residents of populous counties in the exercise of political rights. A challenge to such an election law is not moot when the burden remains in place for future elections and is capable of repetition yet evading review.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Oregon requires an independent candidate for governor to file 30,000 valid signatures. The statute also requires that at least 250 signatures come from each of 20 counties, even though more than 90% of registered voters live in 12 counties around Portland, Eugene, and Salem. Maya Torres submits 34,000 signatures, all valid, but fails to satisfy the 20-county distribution rule.

If Maya challenges the county-distribution requirement under the Equal Protection Clause, which is the strongest argument under the governing doctrine?

Explanation. The majority treated nominating petitions as an integral part of the election process, so equal protection applies. A rigid county-based formula in a statewide election is invalid when it favors residents of less populated counties over those in populous counties by giving the former greater practical political strength. The defect is not the mere existence of a signature requirement, but the unequal weighting created by the county distribution rule. (Derived from Moore v. Ogilvie (n.d.).)