WASHINGTON STATE GRANGE v. WASHINGTON STATE REPUBLICAN PARTY

Legal Principle at Issue

Whether Washington's "top-two" primary system violated the First and Fourteenth Amendments of the U.S. Constitution, which protect freedom of association and guarantee equal protection under the law.

Action

Reversed. Petitioning party received a favorable disposition.

Facts/Syllabus

After the U.S. Court of Appeals for the Ninth Circuit invalidated Washington’s blanket primary system on the ground that it was nearly identical to the California system struck down in California Democratic Party v. Jones (2000), state voters passed an initiative providing that candidates must be identified on the primary ballot by their self-designated party preference; that voters may vote for any candidate; and that the two top vote-getters for each office, regardless of party preference, advance to the general election.

The respondent Washington State Republican Party claim that the new law, on its face, violates a party’s associational rights by usurping its right to nominate its own candidates and by forcing it to associate with candidates it does not endorse. The District Court granted respondents summary judgment, enjoining the initiative's implementation. The Ninth Circuit affirmed.