## Facts

- Ohio required independent presidential candidates to file a statement of candidacy and nominating petitions by March 20, 1980, to appear on the November general-election ballot.
- John B. Anderson announced an independent presidential candidacy on April 24, 1980.
- Anderson’s supporters filed nominating petitions on May 16, 1980, satisfying signature requirements, but the Ohio Secretary of State rejected the filing as late.
- Anderson and supporting Ohio voters sued, alleging the deadline violated rights of political association and voting under the First and Fourteenth Amendments.
- The federal district court granted summary judgment for Anderson and ordered his name placed on the ballot.
- The Sixth Circuit reversed and upheld the deadline, relying in part on the State’s asserted interest in voter education.
- The Supreme Court granted certiorari and reviewed the constitutionality of the early deadline as applied to independent presidential candidates.

## Issues

1. Whether Ohio’s March filing deadline for independent presidential candidates unconstitutionally burdens voters’ and candidates’ First and Fourteenth Amendment rights.
2. What standard governs review of ballot-access restrictions affecting associational and voting rights.
3. Whether Ohio’s asserted interests (including voter education, administrative efficiency, ballot integrity, and avoiding confusion) justify the burden imposed on independent candidacies in a presidential election.

## Decision

- The Court reversed the Sixth Circuit in a 5–4 decision (Justice Stevens for the Court).
- The Court held that Ohio’s early filing deadline imposed an unconstitutional burden on the voting and associational rights of Anderson’s supporters.
- The Court invalidated the deadline as applied to independent presidential candidates.

## Legal Principles

- Challenges to election regulations require a balancing inquiry: courts evaluate (1) the character and magnitude of the burden on First and Fourteenth Amendment rights, (2) the legitimacy and strength of the State’s interests, and (3) whether the burden is necessary to serve those interests.
- A ballot-access burden that falls unevenly on independent candidates or new and small parties can discriminate against voters and candidates outside major parties and substantially burden protected associational choices.
- In presidential elections, courts must consider that state restrictions can affect a nationwide electoral process and may warrant closer examination of justifications offered by a single State.
- State interests such as voter education and orderly administration may justify some regulation, but they do not sustain an early deadline when major-party nomination choices occur later and when less restrictive means can address administrative concerns.

## Conclusion

Ohio’s March deadline for independent presidential candidates was unconstitutional because it significantly burdened political association and voting rights, and the State’s asserted interests did not make the early restriction necessary, particularly given the national character and timing of presidential campaigns.


Anderson v. Celebrezze, 460 U.S. 780 (1983)