The Ohio filing deadline overturned by the Supreme Court in
Anderson applied equally to candidates participating in a primary.
460 U.S. at 799, 103 S.Ct. at 1575. 75 L.Ed.2d at 564. The Supreme Court observed, however:
Id. (emphasis added). The Supreme Court found that the consequences of failing to meet the deadline were different for party primary participants and independents, since the parties' nominees would appear on the general election ballot even if they had not met the filing deadline.
Id. Under Ohio's scheme, the major parties were able to include consideration of all events prior to their conventions in their selection of a nominee, whereas “the independent's judgment must be based on a history that ends in March.”
Id. 460 U.S. at 800–801, 103 S.Ct. at 1575–76, 75 L.Ed.2d at 564–65. Additionally, the early filing deadline for party primary candidates was adequately justified by administrative concerns which did not apply to independent candidacies.
Id. 460 U.S. at 801, 103 S.Ct. at 1576, at 565. Finally, the successful primary candidate acquires a corresponding benefit—the support of an experienced political organization—for having entered the fray earlier.
Id. This benefit was not enjoyed by independent candidates.
Id.