WILLIAMS v. RHODES

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Case Basics
Docket No. 
543
Appellant 
Glen A. Williams et al.
Appellee 
James A. Rhodes, Governor of Ohio
Consolidation 
Socialist Labor Party et al. v. Rhodes, Governor of Ohio, et al., No. 544
Opinion 
Advocates
(argued the cause for appellants in No. 543)
(argued the cause for appellants in No. 544)
(argued the cause for appellees in both cases)
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Facts of the Case 

To be placed on the ballot in a presidential election, Ohio law required a new political party obtain voter signatures totaling 15% of the number of ballots cast in the preceding gubernatorial election. Both the American Independent Party and the Socialist Labor Party sought ballot access in Ohio for the 1968 presidential election. The American Independent Party, formed by supporters of George C. Wallace, obtained the requisite number of signatures but failed to file its petition for ballot access prior to the February 7, 1968 deadline. The Socialist Labor Party, which until 1948 had been on the ballot, failed to collect enough signatures and was also kept off the ballot. The parties filed separate suits in U.S. District Court against several state officials, including Governor James A. Rhodes, contending that being kept off the ballot violated their rights under the Equal Protection Clause of the Fourteenth Amendment. The cases were consolidated, and the court ruled that each party must be given write-in access but did not require the state to print the parties' candidates' names on the ballot. The American Independent Party requested and was granted an injunction forcing the state to add the party's candidates to the ballot while the case was on appeal. The Socialist Labor Party filed a similar request, but did so much later, and was denied primarily to avoid confusion in requiring the reprinting of another set of ballots.

Question 

Did Ohio violate the parties' equal protection rights under the Fourteenth Amendment by refusing to print their candidates' names on the ballot?

Conclusion 
Decision: 6 votes for Williams, 3 vote(s) against
Legal provision: Equal Protection

Yes. In a 6-3 opinion authored by Justice Hugo L. Black, the Court found that Ohio failed to show a compelling interest in limiting the parties' ballot access. The Court concluded that Ohio's restrictions gave the two major parties a "total monopoly" and imposed a significant, unequal burden on minority groups. Given this fact, and the particular importance of the right to vote, Ohio's arguments that its restrictive policies maintained an orderly process and ensured an electoral victor would have at least 50% of the vote failed to meet the necessary standard of a compelling state interest. The Court struck down the Ohio restrictions and granted the American Independent Party full ballot access. To avoid confusion and a last-minute reorganization of the ballot, however, it denied the Socialist Labor Party such access for the 1968 election, in accordance with the injunctive order.

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WILLIAMS v. RHODES. The Oyez Project at IIT Chicago-Kent College of Law. 04 April 2014. <http://www.oyez.org/cases/1960-1969/1968/1968_543>.
WILLIAMS v. RHODES, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1960-1969/1968/1968_543 (last visited April 4, 2014).
"WILLIAMS v. RHODES," The Oyez Project at IIT Chicago-Kent College of Law, accessed April 4, 2014, http://www.oyez.org/cases/1960-1969/1968/1968_543.