MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS' MOTION ...

2. Connecticut’s unique and uniquely burdensome restrictionsgoverning access to the primary ballot in multi-town and statewidedistricts are not narrowly tailored toward achieving any legitimategovernment interest in regulating access to the primary ballot.Because the burdens imposed on voters and candidates in multi-town districts areso severe, the state must come forward with compelling government interests to justifythese restrictions, and, these restrictions must be narrowly tailored to toward achievingthat interest. See Burdick v. Takushi, 504 U.S. 428, 433 (1992); Anderson, 460 U.S. at789. The very existence of the less burdensome alternative for single-town districtsdemonstrates that Connecticut’s interest in regulating access to primary ballots can bemet by a significantly less burdensome requirement. See Rockefeller v. Powers, 78 F.3dat 46. It is not narrowly-tailored toward achieving a legitimate government interest;indeed, it is not rationally related to a legitimate government interest in regulating accessto the primary ballot.a. The traditional government interests in regulating access to theballot are clearly met by the petition requirement imposed onsingle-town districts.The cumbersome set of rules imposed on non-favored candidates seeking primaryballot status in multi-town districts is certainly not about guaranteeing “a preliminaryshowing of a modicum of support” or about avoiding “confusion, deception, and evenfrustration of the democratic process.” Jenness, 403 U.S. at 442. Connecticut has madeit clear that a simple requirement of 5% of the party’s registered voters is sufficient tosatisfy these government interests. Indeed, Connecticut applies this simple requirementto districts as large and complex as the City of Hartford and the City of Bridgeport, whileapplying the more burdensome requirements to state house seats that happen to cross a32