18 F.4th 542
6th Cir.2021Background
- In 1992 Michigan voters adopted a constitutional amendment imposing term limits on state legislators (six years in the House; eight years in the Senate).
- A prior Sixth Circuit decision (Citizens for Legislative Choice v. Miller) upheld Michigan’s state-office term limits; federal limits were later held unconstitutional by the Supreme Court.
- A bipartisan group of long-serving Michigan legislators sued, claiming the term-limit provision violates their First and Fourteenth Amendment rights (ballot access and freedom of association) and two Michigan constitutional procedural provisions.
- The district court granted summary judgment for Michigan; the legislators appealed to the Sixth Circuit.
- The Sixth Circuit addressed (1) whether it had jurisdiction despite a Supreme Court summary dismissal in Moore v. McCartney and (2) the merits of federal constitutional claims, then declined supplemental jurisdiction over novel state-law claims and remanded them.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction despite Moore summary dismissal | Moore’s summary dismissal means federal courts lack jurisdiction to review state term-limit challenges | Moore is a summary dismissal from an era of appeals of right and does not deprive federal courts of jurisdiction over federal-question claims | Court has jurisdiction under 28 U.S.C. § 1331 and may hear the case |
| Standard of review for candidate challenges (Anderson-Burdick applicability) | Anderson-Burdick balancing applies to ballot-access and association claims arising from term limits | Term limits are qualifications for office (not election-law restrictions); Anderson-Burdick is inapposite; use qualification-analysis framework | Anderson-Burdick does not apply; term limits are qualifications for office and are reviewed under rational-basis scrutiny |
| Merits of First/14th Amendment claims (candidates and voters) | Term limits violate ballot-access and association rights by barring experienced candidates and depriving voters of choice | States may set qualifications for office; no fundamental right to run for or vote for a particular candidate class; term limits are rationally related to legitimate state interests (citizen legislature, curb careerism) | Claims dismissed: rational-basis review applies and Michigan’s term limits are constitutional as to the federal claims |
| State-law challenges (procedural defects and Title-Object Clause) | Amendment violated Michigan constitutional procedural rules and Title-Object Clause | Federal court can resolve state-law claims if necessary | Court declines supplemental jurisdiction over novel state issues, vacates district court’s resolution of state claims and remands to dismiss them without prejudice |
Key Cases Cited
- Citizens for Legislative Choice v. Miller, 144 F.3d 916 (6th Cir. 1998) (earlier Sixth Circuit decision upholding Michigan state-term limits)
- Moore v. McCartney, 425 U.S. 946 (U.S. 1976) (summary dismissal for want of a substantial federal question in a state term-limits case)
- U.S. Term Limits, Inc. v. Thornton, 514 U.S. 779 (U.S. 1995) (held states may not add qualifications for federal office; treated term limits as qualifications)
- Anderson v. Celebrezze, 460 U.S. 780 (U.S. 1983) (Anderson-Burdick framework for election-law burdens on voting and associational rights)
- Burdick v. Takushi, 504 U.S. 428 (U.S. 1992) (clarified balancing test for election restrictions)
- Gregory v. Ashcroft, 501 U.S. 452 (U.S. 1991) (state authority to define qualifications for state office reviewed under rational basis)
- Clements v. Fashing, 457 U.S. 957 (U.S. 1982) (candidacy is not a fundamental right; candidacy restrictions subject to rational-basis review)
- DeBoer v. Snyder, 772 F.3d 388 (6th Cir. 2014) (treatment of Supreme Court summary dismissals in circuit precedent)
- Musson Theatrical, Inc. v. Fed. Exp. Corp., 89 F.3d 1244 (6th Cir. 1996) (factors supporting dismissal of supplemental state-law claims when federal claims are resolved)
- Timmons v. Twin Cities Area New Party, 520 U.S. 351 (U.S. 1997) (use of Anderson-Burdick sliding-scale approach in election-law context)