## Facts

- Ralph Nader ran as an independent presidential candidate in 2004 and sought placement on the Illinois general-election ballot.
- Illinois required non-major-party candidates to submit nominating petitions with at least 25,000 valid signatures, filed 134 days before the election, with each signer listing the address at which the signer was registered to vote.
- Nader announced his candidacy on February 22, 2004, and could begin circulating official petitions only 90 days before the June 21 filing deadline.
- Nader filed 32,437 signatures on June 21, 2004.
- A private objector challenged more than 19,000 signatures, primarily asserting the signer was not registered at the address written on the petition.
- State election proceedings struck 12,327 signatures, leaving Nader below the 25,000-signature threshold.
- Nader gathered additional signatures after the deadline, but election officials declined to consider them as untimely.
- Nader, his campaign, and supporting Illinois voters sued seeking a preliminary injunction compelling Illinois to place him on the ballot, alleging the signature threshold, address-matching rule, and early deadline were unconstitutional in combination.

## Issues

1. Whether Illinois’s combined requirements—25,000 valid signatures, signer address matching voter-registration address, and filing 134 days before the election—unconstitutionally burden First and Fourteenth Amendment rights of independent candidates and their supporters.
2. Whether the asserted burdens were “severe” (triggering heightened scrutiny) or instead reasonable, nondiscriminatory regulations justified by the state’s election-administration interests on a motion for preliminary injunction.

## Decision

- The Seventh Circuit affirmed the denial of a preliminary injunction.
- Applying the Anderson-Burdick balancing approach, the court held the combined ballot-access requirements did not impose a severe or constitutionally unreasonable burden.
- The court found the signature threshold served the state’s interest in requiring a modicum of support and was shown to be feasible in practice.
- The address-matching requirement was upheld as a reasonable verification and anti-fraud measure facilitating confirmation of voter eligibility.
- The 134-day deadline, though early, was upheld as justified by administrative needs for signature review, objection resolution, and ballot preparation.
- Because plaintiffs failed to show a likelihood of success on the merits, and because late judicial intervention risked disrupting election administration, emergency relief was unwarranted.

## Legal Principles

- Under Anderson-Burdick, courts weigh the character and magnitude of burdens on voting and associational rights against the state’s justifications for its election regulations.
- Only severe burdens on ballot access ordinarily trigger strict scrutiny; reasonable, nondiscriminatory restrictions are sustained when supported by important regulatory interests.
- States may require substantial signature thresholds to ensure candidates demonstrate a modicum of support and to limit ballot clutter.
- Verification rules tying petition signatures to voter-registration records (including address-matching requirements) may be permissible anti-fraud and administrability measures.
- Early filing deadlines for ballot access may be constitutional when reasonably related to legitimate administrative timelines, particularly at the preliminary-injunction stage where likelihood of success and practical election disruption are relevant.

## Conclusion

The court held Illinois’s signature requirement, signer address-verification rule, and 134-day filing deadline—considered both individually and together—did not severely burden independent presidential ballot access and were justified by legitimate state interests; it therefore affirmed denial of a preliminary injunction to place Nader on the ballot.


Nader v. Keith, 385 F.3d 729 (7th Cir. 2004)