DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
231074P.pdf 12/01/2023 Ind.-Alliance Party of Minn. v. Steve Simon
U.S. Court of Appeals Case No: 23-1074
U.S. District Court for the District of Minnesota
[PUBLISHED] [Gruender, Author, with Stras and Kobes, Circuit Judges]
Civil case - Election law. The plaintiff challenged the lawfulness of a
Minnesota law, Minn. Stat. Sec. 204B.07, subd. 4, requiring that voters
swear an oath before signing a minor-party nominating petition, alleging
it violated the First Amendment; the district court declined to apply
strict scrutiny because the plaintiff plausibly alleged that "at most" the
oath requirement imposed an insubstantial burden on First Amendment
associational rights, and the important election interests justified that
insubstantial burden. Held: Not every electoral law that burdens
associational rights is subject to strict scrutiny, and the district court
did not err in rejecting plaintiff's argument that burdens to
associational rights automatically are subject to strict scrutiny; the
oath does not prevent signers from changing their mind after signing a
nominating petition and only requires them to swear it is not their
present intention to vote in the upcoming primary; as such, signatories do
not violate their oath if they change their minds and the oath is not a
severe burden on their associational rights; the insubstantial burden the
oath imposes is justified by legitimate state interests in promoting
election integrity and reliability by discouraging party raiding and
spoiler candidates.