Given the fact that both options were equally suited to prevent party splinteringor extreme factionalism, the only possible interest underlying theRepublicans' choice, as the court saw it, was to advantage the Republican StateCommittee's favored nominee. That additional increment of power aggrandize-ment (or some might say, autonomy) for the party elite could not be fabricatedinto a state interest. Citing
Anderson v. Celebrezze,
a case in which thetwo incumbent parties allegedly constructed ballot access rules thatdisadvantaged independent candidates, the court rejected the argument that a party could use the state in order to "assure monolithic control over its ownmembers and supporters" and denied that the "particular interests of themajor parties can. b-
Although at the primary all candidates are members of the same party, theyrepresent different political ideas and have different qualifications for nationaland party leadership .... In politics, one challenges establishments in primaries, not elections .... If discriminatory requirements prevent--candidates from obtaining -- place on the ballot and delegates pledged to them,then the primary becomes little more than a state-sponsored endorsement of thecandidate of the party leadership.
In both cases, the court rejected almost out of hand any
interest infiltering out its disfavored candidates, let alone a
interest in giving the party the right to define its own membership. Applying the precedentinvolving general election ballot access laws, the New York courts, like those