Having classified the burden as intermediate, “[a]t the second step of
Anderson-Burdick we consider the State's justifications for the restrictions.”
Schmitt v. LaRose, 933 F.3d 628, 641 (6th Cir. 2019). The State offers several justifications for enforcing the ballot-access laws. First, requiring a modicum of support for ballot access furthers the State's substantial interest in fair and orderly elections by avoiding “overcrowded ballots.”
See id. (quoting
Jolivette v. Husted, 694 F.3d 760, 769 (6th Cir. 2012)). Second, the in-person signature requirements further the State's interest in verifying the authenticity of the signatures, thereby “decreas[ing] the odds that fraud will corrupt Ohio's election process.” (Appellee Br. at p. 36). Third, the State argues that enforcement of the deadlines for submitting petitions ensures that election officials have time to verify the signatures, that any necessary judicial review can proceed, and that ballots can be printed in time to send to military and overseas voters. Plaintiffs do not meaningfully dispute these interests, which—as we observed in
Thompson—are legitimate.
959 F.3d at 811.