Mandel v. Bradley

Background

Bruce Bradley, an independent who ran for the U.S. Senate in Maryland in 1976, filed nominating petitions under a state rule that required independent candidates to submit signatures 70 days before party primaries. In presidential years that filing date falls roughly 230–240 days before the general election. The State board rejected many of Bradley’s signatures and denied him a ballot spot. Bradley and his supporters sued, and a three-judge District Court held the early deadline unconstitutional and ordered an extension, relying on a prior summary affirmance in a different case.

Reasoning

The Court held that the District Court wrongly treated a prior summary affirmance as controlling law and failed to apply the proper test from an earlier full decision (Storer v. Brown). The Court explained that a summary affirmance settles the judgment but does not necessarily adopt the lower court’s reasoning. The Court distinguished the earlier summary case because that case combined an early deadline with a tight short period for collecting signatures, while Maryland’s law had no such short gathering period. The Supreme Court vacated the District Court’s judgment and sent the case back so the trial court can examine the facts and apply the Storer standards about whether a diligent independent could reasonably qualify.

Real world impact

Independent candidates in Maryland are not yet relieved of the early filing schedule. The remand requires the District Court to make factual findings about how difficult it is to get signatures and whether other election features lessen the burden. Bradley later did qualify and ran, but the Court’s ruling means the question is open and not finally resolved.

Dissents or concurrances

Justices Brennan and White wrote separate opinions emphasizing how lower courts should treat summary dispositions; Justice Stevens dissented, arguing the statute unfairly burdens independents and would have affirmed the lower court.