Anderson v. Celebrezze
Encyclopedia
Anderson v. Celebrezze, 460 U.S. 780 (1983), was a case in which the Supreme Court of the United States
in which Ohio's filing deadline for independent candidates was determined to be unconstitutional.
was a declared candidate for the 1980 presidential election
. On 16 May 1980, Anderson's supporters filed a nominating petition to the Ohio Secretary of State
's office. Then-secretary Anthony J. Celebrezze Jr.
rejected the petition, because it was not filed by the state's deadline of seventy-five days prior to the presidential primary. At that time, the primary election was held on the Tuesday following the first Monday in June. In 1980, the deadline would have been 20 March.
ruled that the statute was unconstitutional on two grounds. First, the statute violated the First Amendment to the United States Constitution
by placing too high of a burden to petition the government. Second, the deadline was earlier than that required by candidates in the major parties, thereby violating the Equal Protection Clause
of the Fourteenth Amendment to the United States Constitution
. This decision was later reversed by the United States Court of Appeals
.
The dissent additionally stated that states had discretion in allowing or refusing to allow national candidates on their ballots. In light of a sensible system of petitioning, the Supreme Court should not interfere:
at Justia
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
in which Ohio's filing deadline for independent candidates was determined to be unconstitutional.
Background
John B. AndersonJohn B. Anderson
John Bayard Anderson is a former United States Congressman and Presidential candidate from Illinois. He was a U.S. Representative from the 16th Congressional District of Illinois for ten terms from 1961 through 1981 and an Independent candidate in the 1980 presidential election. He was previously...
was a declared candidate for the 1980 presidential election
United States presidential election, 1980
The United States presidential election of 1980 featured a contest between incumbent Democrat Jimmy Carter and his Republican opponent, Ronald Reagan, as well as Republican Congressman John B. Anderson, who ran as an independent...
. On 16 May 1980, Anderson's supporters filed a nominating petition to the Ohio Secretary of State
Ohio Secretary of State
The Secretary of State is responsible for overseeing elections in the State of Ohio. The Secretary of State also is responsible for registering business entities and granting them the authority to do business within the state, registering secured transactions, and granting access to public...
's office. Then-secretary Anthony J. Celebrezze Jr.
Anthony J. Celebrezze Jr.
Anthony Joseph "Tony" Celebrezze Jr. was an American politician of the Democratic party, who served as Ohio Attorney General, Ohio Secretary of State and an Ohio State Senator. He was the son of Anthony J. Celebrezze Sr....
rejected the petition, because it was not filed by the state's deadline of seventy-five days prior to the presidential primary. At that time, the primary election was held on the Tuesday following the first Monday in June. In 1980, the deadline would have been 20 March.
Early court rulings
The district courtUnited States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
ruled that the statute was unconstitutional on two grounds. First, the statute violated the First Amendment to the United States Constitution
First Amendment to the United States Constitution
The First Amendment to the United States Constitution is part of the Bill of Rights. The amendment prohibits the making of any law respecting an establishment of religion, impeding the free exercise of religion, abridging the freedom of speech, infringing on the freedom of the press, interfering...
by placing too high of a burden to petition the government. Second, the deadline was earlier than that required by candidates in the major parties, thereby violating the Equal Protection Clause
Equal Protection Clause
The Equal Protection Clause, part of the Fourteenth Amendment to the United States Constitution, provides that "no state shall ... deny to any person within its jurisdiction the equal protection of the laws"...
of the Fourteenth Amendment to the United States Constitution
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
. This decision was later reversed by the United States Court of Appeals
United States court of appeals
The United States courts of appeals are the intermediate appellate courts of the United States federal court system...
.
Majority opinion
The Court overturned the Appellate Court's ruling and reinstated that of the district court. Among other points, the majority stated:Dissenting opinion
The dissenting opinion of the court pointed to Ohio's deadline for partisan candidates, which was the same as that of independent candidates:The dissent additionally stated that states had discretion in allowing or refusing to allow national candidates on their ballots. In light of a sensible system of petitioning, the Supreme Court should not interfere:
External links
at FindLawFindLaw
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at Justia
- 460 U.S. 780 at Oyez.orgOyez.orgThe Oyez Project at the Chicago-Kent College of Law is an unofficial online multimedia archive of the Supreme Court of the United States, especially audio of oral arguments...