Williams v. Rhodes

Facts of the Case

The Ohio American Independent Party and the Socialist Labor Party both brought suit to challenge the validity of a series of election laws, as applied to them, 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. The district court ruled that the restrictive Ohio election laws unconstitutional but refused to grant the plaintiffs the full relief they had sought. Both parties appealed. The Court affirmed the district court’s judgment with reference to the Socialist Labor Party and did not require that party on the ballot. The Court modified the judgment regarding the Ohio American Independent Party and granted that party the right to have its name printed on the ballot.

Question

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

CONCLUSION

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.

Case Information

  • Citation: 393 US 23 (1968)
  • Argued: Oct 7, 1968
  • Decided Oct 15, 1968