U.S. Term Limits, Inc. v. Thornton (Article I, 1995)
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Overview
Overview
States cannot impose term limits on federal congressional candidates; such limits violate the Constitution's Qualifications Clauses.
The Facts
Facts
U.S. Term Limits, Inc., an organization supporting term limits for Congress, challenged an Arkansas state constitutional amendment that prohibited candidates who had served three or more terms in the House or two or more terms in the Senate from appearing on the ballot. Arkansas defended the amendment as a valid exercise of state power over elections. The Arkansas Supreme Court upheld the amendment, but the U.S. Supreme Court granted review.
The Issue
Issue
Whether the Constitution permits a state to impose term limits on its federal congressional representatives and senators by restricting ballot access to candidates who have served specified terms, or whether such restrictions add impermissible qualifications for federal office beyond those enumerated in the Constitution.
The Rules
Rule
U.S. Term Limits, Inc. v. Thornton, 514 U.S. 779 (1995), held that states may not impose additional qualifications for candidates to federal office beyond the age, citizenship, and residency requirements enumerated in Article I, Sections 2 and 3 of the Constitution. The qualifications for Congress are fixed by the Constitution; neither states nor Congress may alter them. The decision rested on both the text and history of Article I and the democratic principle that voters, not states, control who may serve.
The Application
Analysis
Arkansas's ballot-access restriction, preventing candidates with prior service from appearing on the ballot, effectively added a term-service qualification for federal office, which the Qualifications Clauses prohibit. Although states retain general authority over election administration, the Court found they cannot use that power to impose additional qualifications for Congress beyond those enumerated in Article I, regardless of the formal mechanism employed. The substance of Arkansas's amendment was to restrict candidacy based on prior service, and the Constitution's Qualifications Clauses are exclusive and exhaustive, leaving no room for state-imposed additions. Therefore, the amendment violated the Constitution and could not stand.
The Conclusion
Conclusion
The Supreme Court held 5-4 that states cannot impose term limits on federal congressional candidates. Justice Stevens wrote that the Qualifications Clauses (Art. I, §§2-3) establish exclusive, exhaustive qualifications for Congress, and states lack power to add additional qualifications. The Court rejected arguments that the Tenth Amendment or Elections Clause granted states such authority, establishing that only a constitutional amendment could impose congressional term limits.
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