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U.S. Term Limits, Inc. v. Thornton

Supreme Court of the United States · Constitutional Law
Constitutional LawQualifications ClausesFederal ElectionsTenth AmendmentElections ClauseTerm LimitsArticle IQualifications Clauses

Facts

Arkansas adopted Amendment 73 to its state constitution in 1992. Section 3 provided that anyone elected to three or more terms in the U.S. House from Arkansas, or two or more terms in the U.S. Senate from Arkansas, could not be certified as a candidate and could not have his or her name placed on the ballot for that federal office. Respondent Bobbie Hill and others sued for a declaratory judgment that § 3 was unconstitutional, and Arkansas defended the amendment. Although the measure did not absolutely bar service because a candidate could run as a write-in, its stated aim was to limit the terms of elected officials.

Issue

May a State impose term-limit-type restrictions on candidates for Congress by denying ballot access to otherwise constitutionally qualified candidates who have already served a specified number of terms? More broadly, does the Constitution permit States to add to the qualifications for Members of Congress, either directly or indirectly through ballot-access rules?

Rule

The qualifications for service in the United States Congress are fixed in the Constitution and are exclusive. States have no reserved or delegated power to add to those qualifications, and they may not accomplish indirectly through ballot-access restrictions what the Constitution forbids them to do directly. The Elections Clause authorizes procedural regulations of elections, not rules that favor or disfavor classes of candidates or evade the Qualifications Clauses.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Ohio enacts a statute providing that anyone seeking election to the U.S. House from Ohio must have lived in the congressional district for at least four years before the election. Maya Ortiz, age 34, has been a U.S. citizen for 12 years and lives in Columbus, but she moved into the district 10 months ago.

If Ohio refuses to place Maya on the ballot solely because she lacks four years of district residency, is the statute constitutional?

Explanation. Article I fixes the qualifications for Representatives, and those qualifications are exclusive. A State may not require more, including district residency beyond the Constitution’s requirement that the candidate be an inhabitant of the State when elected. The majority treated state-added district residency rules as impermissible additions, not valid election procedures. (Derived from U.S. Term Limits, Inc. v. Thornton (n.d.).)