De La Fuente v. Padilla, 930 F.3d 1101

Roque De La Fuente, an independent presidential candidate, challenged California Election Code §§ 8400 and 8403 after 2016; those provisions require independent statewide candidates to collect signatures equal to 1% of registered voters and to submit them 88–193 days before the election. In 2016 that meant 178,039 valid signatures in 105 days.
De La Fuente claimed the requirements were "cost prohibitive" (estimating $3–4 million to pay canvassers) and violated his First and Fourteenth Amendment rights by severely burdening ballot access.
California defended the statutes as reasonable regulations serving important state interests: streamlining the ballot, avoiding overcrowding, and reducing voter confusion.
The district court granted summary judgment for the Secretary of State; De La Fuente appealed.
The Ninth Circuit found De La Fuente had Article III standing because he had an actual, imminent injury from the ballot-access rules given his declared candidacy and past experience.
On the merits, the court applied the Anderson/Burdick balancing framework and concluded the burden was not severe because California’s overall scheme also permits minor-party and write-in access and the 1% threshold is a modest, neutral preliminary showing of support.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether De La Fuente has Article III standing	De La Fuente is running for President and would be injured by California’s ballot-access rules	Secretary argued his injury was speculative if he might run in a major party primary	Court: De La Fuente has concrete, imminent injury and thus standing
Whether the ballot-access requirements "seriously restrict" political opportunity (triggering strict scrutiny)	The 1% signature requirement and time window are effectively prohibitive and severely burden ballot access	The overall California scheme provides alternatives (minor parties, write-ins); the rules are neutral and not generally severe	Court: Restrictions are not severe; do not seriously restrict political opportunity
Appropriate standard of review under Anderson/Burdick	De La Fuente urged strict scrutiny due to severe burden	Secretary urged relaxed scrutiny because burdens are minimal and laws serve important regulatory interests	Court: Apply less exacting (balancing) review because burdens are non-severe
Whether California’s laws are justified under the balancing test	The laws unconstitutionally burden access by imposing an excessive, practically insurmountable cost	The laws are reasonably tailored to important state interests (prevent overcrowding, confusion); 1% is proportionate given California’s large electorate	Court: Laws reasonably relate to important state interests and are constitutional; judgment affirmed

Ariz. Libertarian Party v. Hobbs, 925 F.3d 1085 (9th Cir. 2019) (analysis of ballot-access regulations under Anderson/Burdick)
Nader v. Cronin, 620 F.3d 1214 (9th Cir. 2010) (examining ballot-access burdens and overall scheme)
Anderson v. Celebrezze, 460 U.S. 780 (1983) (framework for balancing election-law burdens against state interests)
Burdick v. Takushi, 504 U.S. 428 (1992) (application of balancing framework in ballot-access cases)
Jenness v. Fortson, 403 U.S. 431 (1971) (recognizing state interest in preliminary showing of support)
Munro v. Socialist Workers Party, 479 U.S. 189 (1986) (upholding reasonable ballot-access restrictions without judicial demand for particularized proof of confusion)
Storer v. Brown, 415 U.S. 724 (1974) (upholding signature-gathering requirements as not impossible burdens)
Ariz. Green Party v. Reagan, 838 F.3d 983 (9th Cir. 2016) (discussing when restrictions rise to severe burdens triggering strict scrutiny)