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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.