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

c. Overall burdens consistently skew the process to favorincumbents.Incumbents are usually guaranteed ballot status because they are likely to receivethe endorsement of the convention after the town committees have named delegate slatesthat will support the incumbent. See Nielsen Decl. at 8, 12; Haave Decl. at 5;Caplan Decl. at 11. In comparison, a candidate who is challenging an incumbent oreven one who does not have the support of party leadership faces a grueling andexpensive ballot access procedure that requires months of wooing town committees andthen delegates combined with the mounting, running, and winning of actual campaigns inan effort to win 15% of the district convention’s delegates. All of these high hurdlesmust be passed simply to get on the real primary ballot.In 1986, gubernatorial candidate Toby Moffett spent $900,000 in his unsuccessfulattempt to run against Gov. William O’Neill in a real primary. Caplan Decl. at 16.Plaintiff Campbell spent $40,000 in his unsuccessful attempt to get primary ballot accessto challenge Rep. Christopher Shays. See Campbell Decl. at 16. In a delegate primarybattle in West Hartford during the campaign for the 1998 Democratic nomination for the1st Congressional District, almost $60,000 was spent. See Rapoport Decl. at 26.Indeed, the process is so burdensome that some candidates who were not the partyfavorites have been known to back out of the primary even after achieving real primaryballot status because their means were exhausted. See Nielsen Decl. at 11.Challengers – or any non-favored candidate – in these multi-town districts areforced by this cumbersome system to run three or even four campaigns on their way toelection. First, they must campaign among the party insiders for delegates. See Caplan13