Anthony Navarro v. Langdon Neal
2013 U.S. App. LEXIS 9878
7th Cir.2013Background
- Illinois ballot access law provides three paths to placement on general-election ballots for state legislative races.
- In 2012, five Republican candidates failed to collect required nominating petition signatures and were denied ballot placement.
- Plaintiffs filed in Sept. 2012 for injunctive and declaratory relief, alleging the statute violates First/Fourteenth Amendment rights.
- The district court dismissed as to all relief on laches grounds, including declaratory relief seeking future- election relief.
- Court lower court found the petition-signature requirement reasonable and nondiscriminatory, serving election integrity and voter clarity purposes.
- Court holds that laches does not bar declaratory relief because relief would apply to future elections and delay did not prejudice the Board.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether laches bars declaratory relief as to future elections | Navarro contends laches should not bar declaratory relief | Board asserts delay prejudices election administration | Laches does not bar declaratory relief |
| Constitutionality of the 5/7-61 petition requirement | Signatures requirement burdens rights without compelling justification | Requirement serves important regulatory interests in preventing confusion and fraud | Statute passes reasonable, nondiscriminatory scrutiny |
| Appropriate level of scrutiny under Burdick framework | The burden is too severe for voters’ rights | Regulatory interest justifies the burden; no strict scrutiny needed | Law imposes reasonable, nondiscriminatory restrictions warranting intermediate scrutiny under Burdick |
| State interest in preventing voter confusion supports ballot access restrictions | Not shown to prevent voter confusion | Restrictions prevent ballot clutter and frivolous candidates | Court affirms statute as serving important regulatory interests |
| Are signature requirements substantively tied to ballot integrity | Only one candidate on ballot shows no confusion problem | Relaxing requirements risks frivolous candidates and voter confusion | Requirements remain connected to ballot integrity; constitutionality upheld |
Key Cases Cited
- Burdick v. Takushi, 504 U.S. 428 (1992) (severe vs. reasonable ballot-access restrictions; level of scrutiny varies with burden)
- Munro v. Socialist Workers Party, 479 U.S. 189 (1986) (ballot-access interests are important and can justify restrictions)
- Am. Party of Texas v. White, 415 U.S. 767 (1974) (state interests in elections can justify access requirements)
- Lee v. Keith, 463 F.3d 763 (7th Cir. 2006) (petition-submission as ballot-access tool; constitutional but not dispositive here)
- Nader v. Keith, 385 F.3d 729 (7th Cir. 2004) (discusses ballot-access design and voter confusion considerations)
- Protect Marriage Ill. v. Orr, 463 F.3d 604 (7th Cir. 2006) (petition-submission requirements connected to preventing voter confusion and preserving integrity)