## Facts

- California election laws barred official party governing bodies from endorsing or opposing candidates in party primary elections and made it a misdemeanor for a primary candidate to claim official party endorsement.
- Other provisions prescribed aspects of internal party governance, including the organization and composition of party governing bodies, term limits for the state central committee chair, and a requirement that the chair alternate between Northern and Southern California residents.
- Party organizations, members, and politically active individuals challenged these provisions as violating First Amendment rights of political speech and association, applied to the states through the Fourteenth Amendment.
- A federal district court granted summary judgment to the challengers, and the Ninth Circuit affirmed.
- State election officials sought Supreme Court review.

## Issues

1. Whether California’s ban on party governing bodies endorsing or opposing candidates in primary elections, and its related criminal prohibition on candidates claiming official party endorsement, violate the First and Fourteenth Amendments.
2. Whether California’s regulations controlling parties’ internal structure and leadership unconstitutionally burden parties’ and members’ First Amendment associational rights.

## Decision

- The Supreme Court affirmed.
- The Court held unconstitutional the ban on primary endorsements and the related prohibition on candidates claiming party endorsement.
- The Court also held unconstitutional the provisions regulating internal party governance (including leadership term limits and geographic rotation requirements).
- The challenged provisions burdened core political speech and associational rights and were not justified by a compelling, narrowly tailored state interest.

## Legal Principles

- Political parties and their members have First Amendment rights to engage in core political speech, including communicating support for candidates in primary elections.
- The freedom of association protects a party’s ability to identify its members, select and promote its preferred candidates, and determine its internal organization and leadership.
- Laws burdening core political speech and political association are subject to strict scrutiny and must be supported by a compelling governmental interest and narrow tailoring.
- A state may protect the electoral process against external harms (e.g., fraud), but it may not suppress party speech or restructure parties’ internal affairs to protect a party from itself or to manage intraparty disputes.

## Conclusion

The Court invalidated California statutes that restricted party primary endorsements and dictated internal party governance, holding that these regulations impermissibly burdened political parties’ and their members’ First Amendment speech and associational rights without a compelling and narrowly tailored justification.


Eu v. S.F. Cnty. Democratic Cent. Comm., 489 U.S. 214 (1989)