## Facts

- Connecticut law limited voting in a party primary to voters listed on that party’s most recent enrollment list.
- Plaintiffs were registered voters who intentionally remained unaffiliated with any political party and therefore could not vote in any party primary.
- Plaintiffs challenged the statute under 42 U.S.C. § 1983, alleging:
  - Equal protection violations because enrolled party members could vote in primaries while unaffiliated voters could not.
  - First Amendment violations because participation required public party enrollment, burdening their claimed right not to associate and their preference to keep political affiliation private.
  - Unconstitutional burden on voting because primaries strongly affected who would appear on general-election ballots.
- The state and the major parties defended the system as protecting party autonomy in choosing nominees and preventing strategic participation by nonmembers.

## Issues

1. Whether restricting primary voting to enrolled party members violates the Fourteenth Amendment rights of otherwise qualified, unaffiliated voters.
2. Whether conditioning primary participation on party enrollment violates the First Amendment right to associate, including a claimed right not to associate and to keep political affiliation private.
3. Whether the state’s interests in protecting party nominee selection and preventing manipulation justify a closed-primary system.

## Decision

- The three-judge district court dismissed the complaint and denied plaintiffs’ motion for summary judgment.
- The court held that Connecticut’s closed-primary statute was constitutional under the First and Fourteenth Amendments.
- The Supreme Court summarily affirmed the judgment.

## Legal Principles

- The right to vote and the right to associate in support of candidates may be subject to reasonable regulation in the context of party nomination procedures.
- A state may limit participation in a party’s primary to enrolled members to protect the party’s associational interests and the integrity of its nomination process.
- Requiring party enrollment as a condition for participating in that party’s primary can be treated as a minimal, permissible condition rather than an unconstitutional burden or compelled association.
- Enrolled party members and unaffiliated voters are not similarly situated for purposes of choosing a party’s nominees; differential access to a party primary may be constitutionally permissible when tied to party membership.

## Conclusion

Connecticut’s closed-primary scheme permissibly restricted primary voting to enrolled party members, reflecting a constitutional balance between voter participation interests and the state’s and parties’ interests in protecting party autonomy and preventing nonmember manipulation of nominee selection.


Nader v. Schaffer, 417 F. Supp. 837 (D. Conn.), aff’d, 429 U.S. 989 (1976)