Robert Graham v. Frank Tamburri

Summary

The court affirmed the exclusion of Tamburri’s name from the Libertarian primary ballot. It held that the amended signature requirements did not severely burden his First Amendment rights because they required signatures from only 0.25 percent of eligible signers and were attainable by a reasonably diligent minor-party candidate; the requirements were therefore rationally related to the state’s interest in ensuring a significant modicum of support. The court also rejected Tamburri’s arguments that the complaint required verification and that service on county officials was defective.