Case 1:20-cv-03325-AT Document 43 Filed 05/05/20 Page 18 of 30 b. The Anderson-Burdick Framework In assessing challenges to ballot-access restrictions under the First and Fourteenth Amendments, courts apply the so-called Anderson-Burdick balancing test, derived from two Supreme Court cases. In Anderson v. Celebrezze, the Supreme Court struck down as unconstitutional an Ohio law providing that independent candidates could appear on the presidential general election ballot only if they met the filing requirement by March of the election year. 460 U.S. at 805–06. The Court held that when confronted with a restriction on ballot access, a court must “first consider the character and magnitude of the asserted injury to the rights protected by the First and Fourteenth Amendments that the plaintiff seeks to vindicate,” then “identify and evaluate the precise interests put forward by the State as justifications for the burden imposed by its rule,” and then “determine the legitimacy and strength of each of those interests” and “consider the extent to which those interests make it necessary to burden the plaintiff’s rights.” Id. at 789. In Burdick v. Takushi, the Supreme Court applied that test to uphold Hawaii’s prohibition on write-in voting in general elections. 504 U.S. 428, 441–42 (1992). In doing so, the Court refined the Anderson standard, explaining that “the rigorousness of [a court’s] inquiry into the propriety of a state election law depends upon the extent to which a challenged regulation burdens First and Fourteenth Amendment rights.” Id. at 434. “[W]hen those rights are subjected to ‘severe’ restrictions, the regulation must be ‘narrowly drawn to advance a state interest of compelling importance’”—in other words, the restriction must survive the standard commonly referred to as “strict scrutiny.” Id. (citation omitted). “But when a state election law provision imposes only reasonable, nondiscriminatory restrictions upon the First and Fourteenth Amendment rights of voters, the State’s important regulatory interests are generally sufficient to 18