Brown v. Chote

Background

A man who wanted to run for the U.S. House from California’s 17th District sued the State over rules that require candidates to pay a filing fee before their names appear on a primary ballot. Under California law, fees ranged from a few hundred dollars for state offices to larger amounts for U.S. Senate and House races. The plaintiff said he was indigent, tried to get nomination forms, and presented a check marked “written under protest.” He asked a federal court for a temporary order letting him appear on the June primary ballot without paying the fee.

Reasoning

Because the deadline for filing was imminent, a three-judge federal court granted a preliminary injunction allowing indigent, otherwise eligible candidates to appear on the ballot by filing an affidavit of indigency instead of paying. The State appealed directly to this Court. The Supreme Court reviewed only whether the lower court abused its discretion in issuing that temporary relief. Finding the record limited but recognizing the risk that the candidate would be blocked from the ballot without immediate relief, the Court held there was no abuse of discretion. It affirmed the grant of interim relief but explicitly did not decide whether the fee law is ultimately constitutional.

Real world impact

The immediate effect is that eligible indigent candidates may be allowed onto the ballot without paying the fee while the case continues. The decision does not settle the larger constitutional question, and the case was sent back to the district court for further proceedings, including a possible full trial on the fee’s legality.