AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• David Crum, a resident of Albuquerque, New Mexico, who is registered to vote without designating a political party affiliation, sought to vote in the 2014 primary election by choosing either a Democratic or Republican ballot without changing his voter registration. New Mexico law requires voters to be affiliated with a major political party to participate in primary elections and only allows them to vote for candidates of the party designated on their voter registration. Crum was not allowed to vote in the primary election because he was not registered as a Democrat or Republican by the deadline (paras 1-2).

Procedural History

• District Court: The lawsuit was dismissed for failing to state a claim upon which relief could be granted (para 4).
• Court of Appeals: The case was certified to the Supreme Court of New Mexico (para 4).

Parties' Submissions

• Plaintiff-Appellant: Argued that the Free and Open Clause of the New Mexico Constitution entitles him to vote in primary elections without registering with a major political party (para 2).
• Defendants-Appellees and Intervenor-Appellee: Contended that requiring voters to designate their affiliation with a major political party at least twenty-eight days before the primary election and only allowing them to vote for candidates of that party are reasonably modest burdens that further the State’s interests in securing the purity of and efficiently administering primary elections (paras 3, 12-19).

Legal Issues

• Whether New Mexico’s closed primary system violates the Free and Open Clause of Article II, Section 8, and Article VII, Section 1 of the New Mexico Constitution (para 5).

Disposition

• The Supreme Court of New Mexico affirmed the district court’s grant of the motion to dismiss, holding that the closed primary election system is not unconstitutional (para 21).

Reasons

• The Supreme Court, with Justice Edward L. Chávez writing the opinion, and concurrence from Chief Justice Charles W. Daniels, Justice Petra Jimenez Maes, and Justice Barbara J. Vigil, reasoned that while the Free and Open Clause is intended to promote voter participation, the Legislature has the constitutional power to enact laws that secure the secrecy of the ballot and the purity of elections. The Court found that the requirements for voters to register with a major political party and to vote only for candidates of that party are modest burdens that further the State's interests in securing the purity of and efficiently administering primary elections. The Court also noted that the current closed primary system does not preclude the possibility that a different primary system could also be constitutional (paras 6-20).