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

a grueling, months-long process that includes wooing hundreds of party insiders and,often, running in elections called “delegate primaries.” See §§ 9-405, 9-407. In short, justto get on the primary ballot in these districts, candidates must run in and win actualelections, and they must conduct campaigns to win the support of political insiders. Yetin the State’s other districts, candidates are able to get on the ballot by meeting a simplepetition requirement.Connecticut stands alone among the 50 states and the District of Columbia in itsrefusal, by state law, to allow its candidates for most state offices and all federal officesaccess to a direct primary – that is a primary where candidates achieve ballot status bypaying a fee, submitting petition signatures, or submitting a declaration of candidacy.See Survey of Primary Ballot Access Laws in 50 States and District of Columbia (50-State Survey) (attached hereto as Exhibit 1). Indeed, Connecticut stands alone in itsmaintenance of a dual system of primary ballot access that establishes starkly differentstandards of primary ballot access based on solely on geography, one set of which isseverely burdensome.In 44 states and the District of Columbia, state law requires the major politicalparties to use primaries as the means of nominating the party’s candidate for the generalelection. Id. In all of these jurisdictions, access to the ballot is direct and usually quitesimple – candidates qualify for the ballot by submitting petitions or by paying a filing fee.Id. A handful of these states also have a convention system, but each also provides foralternative access to the primary ballot by petition. None of the remaining five statesprohibit the party from using a direct primary system to nominate candidates – asConnecticut does for candidates in multi-town districts. As detailed in Exhibit 1, these2