Williams v. Rhodes

Williams v. Rhodes
Williams v. Rhodes
	Supreme Court of the United States
Argued October 7, 1968; Decided October 15, 1968
Full case name	Williams et al. v. Rhodes, Governor of Ohio et al.
Citations	393 U.S. 23 ( more ) 89 S. Ct. 5; 21 L. Ed. 2d 24; 1968 U.S. LEXIS 2959; 45 Ohio Op. 2d 236
Case history
Prior	290 F. Supp. 983 (S.D. Ohio 1968)
Holding
	Ohio's restrictive election laws, taken as a whole, were invidiously discriminatory and violated the Equal Protection Clause because they gave the two old, established parties a decided advantage over new parties. Judgment of the District Court affirmed with reference to the Socialist Labor Party case, but modified in the Independent Party case.
Court membership
	Chief Justice Earl Warren Associate Justices Hugo Black · William O. Douglas ; John M. Harlan II · William J. Brennan Jr. ; Potter Stewart · Byron White ; Abe Fortas · Thurgood Marshall
Case opinions
Majority	Black, joined by Douglas, Brennan, Fortas, Marshall
Concurrence	Douglas
Concurrence	Harlan (in judgment only)
Concur/dissent	White
Concur/dissent	Stewart
Dissent	Warren
Laws applied
	U.S. Const. amends. I, XIV

Last updated November 19, 2024

Williams v. Rhodes, 393 U.S. 23 (1968), is a decision by the United States Supreme Court which held that Ohio had violated the equal protection rights under the Fourteenth Amendment of two political parties by refusing to print their candidates' names on the ballot.

Background

Facts

Separate suits were brought by the American Independent Party and the Socialist Labor Party, challenging the validity of Ohio election laws insofar as they precluded the parties' being placed on the ballots to choose electors pledged to particular candidates for the presidency and vice presidency of the United States; the attack on the validity of these laws was rested on the ground that they violated the equal protection clause of the Fourteenth Amendment—on the ground that they denied plaintiffs and the voters who might wish to vote for them the equal protection of the laws, guaranteed against state abridgment by the Equal Protection Clause of U.S. Const. amend. XIV.

Under the Ohio election laws, a new political party seeking ballot position in presidential elections must obtain petitions signed by qualified electors totaling 15% of the number of ballots cast in the last gubernatorial election and must file these petitions early in February of the election year. These requirements and other restrictive statutory provisions virtually preclude a new party's qualifying for ballot position and no provision exists for independent candidates doing so. The Republican and Democratic parties may retain their ballot positions by polling 10% of the votes in the last gubernatorial election and need not obtain signature petitions. The Ohio American Independent Party (an appellant in No. 543), was formed in January 1968, and during the next six months by securing over 450,000 signatures exceeded the 15% requirement but was denied ballot position because the February deadline had expired. The Socialist Labor Party (an appellant in No. 544), an old party with a small membership, could not meet the 15% requirement. Both Parties brought actions challenging the Ohio election laws as violating the Equal Protection Clause of the Fourteenth Amendment.

District court

A three-judge District Court held those laws unconstitutional and ruled that the parties were entitled to write-in space but not ballot position.

In both cases, the United States District Court for the Southern District of Ohio ruled that the restrictive Ohio election laws unconstitutional but refused to grant the plaintiffs the full relief they had sought. It held that a series of restrictive Ohio election laws resulted in a denial of equal protection of the laws but refused to grant plaintiffs the full relief they sought against defendants, a governor and associated individuals. The District Court, composed of three judges, held the election laws unconstitutional, and granted relief only to the extent of allowing write-in ballots, but refused to order the names of the parties to be printed on the ballots. (290 F Supp 983.)

Interlocutory relief

The parties appealed to the Supreme Court. The independent party immediately sought interlocutory relief from Justice Stewart, which he granted by order after a hearing at which Ohio represented that it could place the party's name on the ballot without disrupting the election if there was not a long delay. Several days after that order the Socialist Labor Party sought a stay which he denied because of that party's failure to move quickly for relief, the state having represented that at that time the granting of relief would disrupt the election.

Immediately after entry of the District Court's judgment, the American Independent Party sought and obtained from Justice Stewart, as Circuit Justice, an injunction ordering the party's candidates to be placed on the ballot pending appeal. (21 L Ed 2d 69, 89 S Ct 1.) A like motion filed by the Socialist Labor Party several days later was denied by the Circuit Justice because of the party's failure to move quickly to obtain relief. (21 L Ed 2d 72, 89 S Ct 3.)

Certiorari and arguments

Both parties appealed. October 7, 1968, Argued.

Opinion of the court

On appeal, the Supreme Court of the United States affirmed in the Socialist Labor Case, but modified the District Court's judgment in the American Independent Party Case, granting that party the right to have its name printed on the ballot. Black wrote for a 5-4 court.

The Court held that defendants had failed to show any "compelling interest" that would justify imposing heavy burdens on the right to vote and to associate. The totality of the Ohio restrictive laws imposed a burden on voting and associational rights, which the court held was invidious discrimination in violation of the Equal Protection Clause.

It was held that (1) the equal protection clause was violated by the Ohio election laws, which made it virtually impossible for any party except the Republican and Democratic Parties to qualify on the ballot, and (2) the American Independent Party was, and the Socialist Labor Party was not, entitled to have its name placed on the ballots, because the former promptly sought injunctive relief in the United States Supreme Court, thus avoiding interruption of the state's electoral process, and the latter delayed in seeking such relief.

Held:

1. The controversy in these cases is justiciable. P. 28.

2. State laws enacted pursuant to Art. II, § 1, of the Constitution to regulate the selection of electors must meet the requirements of the Equal Protection Clause of the Fourteenth Amendment. pp. 28–29.

3. Ohio's restrictive election laws taken as a whole are invidiously discriminatory and violate the Equal Protection Clause because they give the two old, established parties a decided advantage over new parties. pp. 30–34.

(a) The state laws here involved heavily burden the right of individuals to associate for the advancement of political beliefs and the right of qualified voters to cast their votes effectively. pp. 30–31.

(b) The State has shown no "compelling interest" justifying those burdens. pp. 31–32.

4. Under the circumstances here Ohio must allow the Independent Party and its candidates for president and Vice President to remain on the ballot, subject to compliance with valid state laws. Ohio is not at this late date required to place the Socialist Labor Party on the ballot for the coming election. pp. 34–35.

Other opinions

Concurrence

Justice Douglas, in a separate opinion, with emphasis somewhat different from the court's, joined in the court's opinion.

Concurrence with results

Justice Harlan concurred in the results, but would rest the decision entirely on the proposition that Ohio's statutory scheme violated the basic rights of political association assured by the First Amendment, which are protected against state infringement under the due process clause of the Fourteenth Amendment.

Concurrence/dissents

Justice Stewart dissented with respect to the American Independent Party, expressing the view that the Ohio election laws were within the power of the Ohio legislature. However, he concurred in No. 544 in the denial of equitable relief to the Socialist Labor Party.

Justice White also dissented with respect to the American Independent Party, expressing the view that neither the due process clause nor the equal protection clause of the Fourteenth Amendment prohibited Ohio from requiring that the appointment of presidential electors be carried out through the political party process, and concurred in No. 544 insofar as the Socialist Party was denied relief in the Supreme Court.

Dissent

Chief Justice Warren dissented, expressing the view that Ohio should not be compelled to place the candidates of either the American Independent Party or the Socialist Labor Party on the ballot for the impending presidential election. As regards the latter party, he would remand to the District Court for a clearer determination of the serious constitutional questions raised in the instant cases.

Related Research Articles

The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments. Usually considered one of the most consequential amendments, it addresses citizenship rights and equal protection under the law and was proposed in response to issues related to formerly enslaved Americans following the American Civil War. The amendment was bitterly contested, particularly by the states of the defeated Confederacy, which were forced to ratify it in order to regain representation in Congress. The amendment, particularly its first section, is one of the most litigated parts of the Constitution, forming the basis for landmark Supreme Court decisions such as Brown v. Board of Education (1954) regarding racial segregation, Loving v. Virginia (1967) regarding interracial marriage, Roe v. Wade (1973) regarding abortion, Bush v. Gore (2000) regarding the 2000 presidential election, Obergefell v. Hodges (2015) regarding same-sex marriage, and Students for Fair Admissions v. Harvard (2023) regarding race-based college admissions. The amendment limits the actions of all state and local officials, and also those acting on behalf of such officials.

Bush v. Gore, 531 U.S. 98 (2000), was a landmark decision of the United States Supreme Court on December 12, 2000, that settled a recount dispute in Florida's 2000 presidential election between George W. Bush and Al Gore. On December 8, the Florida Supreme Court had ordered a statewide recount of all undervotes, over 61,000 ballots that the vote tabulation machines had missed. The Bush campaign immediately asked the U.S. Supreme Court to stay the decision and halt the recount. Justice Antonin Scalia, contending that all the manual recounts being performed in Florida's counties were illegitimate, urged his colleagues to grant the stay immediately. On December 9, the five conservative justices on the Court granted the stay, with Scalia citing "irreparable harm" that could befall Bush, as the recounts would cast "a needless and unjustified cloud" over Bush's legitimacy. In dissent, Justice John Paul Stevens wrote that "counting every legally cast vote cannot constitute irreparable harm." Oral arguments were scheduled for December 11.

Santa Clara County v. Southern Pacific Railroad Company, 118 U.S. 394 (1886), is a corporate law case of the United States Supreme Court concerning taxation of railroad properties. The case is most notable for a headnote stating that the Equal Protection Clause of the Fourteenth Amendment grants constitutional protections to corporations.

Ballot access are rules and procedures regulating the right to candidacy, the conditions under which a candidate, political party, or ballot measure is entitled to appear on voters' ballots in elections in the United States.

Smith v. Allwright, 321 U.S. 649 (1944), was a landmark decision of the United States Supreme Court with regard to voting rights and, by extension, racial desegregation. It overturned the Texas state law that authorized parties to set their internal rules, including the use of white primaries. The court ruled that it was unconstitutional for the state to delegate its authority over elections to parties in order to allow discrimination to be practiced. This ruling affected all other states where the party used the white primary rule.

Board of Trustees of the University of Alabama v. Garrett, 531 U.S. 356 (2001), was a United States Supreme Court case about Congress's enforcement powers under the Fourteenth Amendment to the United States Constitution. The Supreme Court decided that Title I of the Americans with Disabilities Act was unconstitutional, insofar as it allowed states to be sued by private citizens for money damages.

The Equal Protection Clause is part of the first section of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "nor shall any State ... deny to any person within its jurisdiction the equal protection of the laws." It mandates that individuals in similar situations be treated equally by the law.

Ray v. Blair, 343 U.S. 214 (1952), is a major decision of the Supreme Court of the United States. It was a case on state political parties' requiring of presidential electors to pledge to vote for the party's nominees before being certified as electors. It ruled that it is constitutional for states to allow parties to require such a pledge of their candidates for elector, and that it was not a breach of otherwise qualified candidates' rights to be denied this position if they refused the pledge. However, the violation of any pledge a faithless elector made was not at issue. It officially defined state electors as representatives of their respective states, not the federal government. The case was argued on March 31, 1952 and the Court announced its decision on April 3, 1952; the majority and dissenting opinions were issued on April 15, 1952.

Nevada Department of Human Resources v. Hibbs, 538 U.S. 721 (2003), was a United States Supreme Court case which held that the Family and Medical Leave Act of 1993 was "narrowly targeted" at "sex-based overgeneralization" and was thus a "valid exercise of [congressional] power under Section 5 of the Fourteenth Amendment."

Austin v. Michigan Chamber of Commerce, 494 U.S. 652 (1990), was a decision of the Supreme Court of the United States regarding campaign finance regulations. The majority opinion authored by Thurgood Marshall held that the Michigan Campaign Finance Act, which burdened political speech by prohibiting corporations from using treasury money to make independent expenditures to support or oppose candidates in elections, was appropriately justified by a compelling state interest so as to overcome a First Amendment challenge. The court also found no Fourteenth Amendment violation, stating that Congress could treat press corporations and nonpress corporations differently without violating the Equal Protection Clause. Upholding the restriction on corporate political speech, The Court stated that "Corporate wealth can unfairly influence elections"; however, the Michigan law still allowed the corporation to make such expenditures from a segregated fund.

Anderson v. Celebrezze, 460 U.S. 780 (1983), was a United States Supreme Court case in which the Court held that Ohio's filing deadline for independent candidates was unconstitutional.

Hunter v. Erickson, 393 U.S. 385 (1969), was a United States Supreme Court case.

Shelley v. Kraemer, 334 U.S. 1 (1948), is a landmark United States Supreme Court case that held that racially restrictive housing covenants cannot legally be enforced.

Citizens for Equal Protection v. Bruning, 455 F.3d 859, was a federal lawsuit filed in the United States District Court for the District of Nebraska and decided on appeal by the United States Court of Appeals for the Eighth Circuit. It challenged the federal constitutionality of Nebraska Initiative Measure 416, a 2000 ballot initiative that amended the Nebraska Constitution to prohibit the recognition of same-sex marriages, civil unions, and other same-sex relationships.

Communist Party of Indiana v. Whitcomb, 414 U.S. 441 (1974), was a United States Supreme Court case based on the First Amendment to the U.S. Constitution that invalidated Indiana's loyalty oath requirement.

Mark S. Massa is an American lawyer who has served as an associate justice of the Indiana Supreme Court since April 2, 2012, when he succeeded Justice Randall T. Shepard.

Chiafalo v. Washington, 591 U.S. 578 (2020), was a United States Supreme Court case on the issue of "faithless electors" in the Electoral College stemming from the 2016 United States presidential election. The Court ruled unanimously, by a vote of 9–0, that states have the ability to enforce an elector's pledge in presidential elections. Chiafalo deals with electors who received US$1,000 fines for not voting for the nominees of their party in the state of Washington. The case was originally consolidated with Colorado Department of State v. Baca, 591 U.S. ___ (2020), a similar case based on a challenge to a Colorado law providing for the removal and replacement of an elector who does not vote for the presidential candidate who received the most votes in the state, with the electors claiming they have discretion to vote as they choose under the Twelfth Amendment to the United States Constitution. On March 10, 2020, Justice Sonia Sotomayor recused herself in the Colorado case due to a prior relationship to a respondent, and the cases were decided separately on July 6, 2020. Baca was a per curiam decision that followed from the unanimous ruling in Chiafalo against the faithless electors and in favor of the state.

Truax v Raich239 US 33 (1915) was a U.S. Supreme Court case concerning U.S. labor laws, the right to work, immigration law, and the Fourteenth Amendment to the United States Constitution.

There is ongoing legal debate about the constitutionality of the National Popular Vote Interstate Compact in the United States. At issue are interpretations of the Compact Clause of Article I, Section X, and states' plenary power under the Presidential Electors Clause of Article II, Section I.

References

Text of Williams v. Rhodes, 393 U.S. 23(1968) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)

This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.