Peters v. JohnsAnnotate this Case
Rachel Johns sought the Democratic party’s nomination for Missouri State Representative in the District 76. She filed a declaration of candidacy with the Missouri Secretary of State, in which she stated under oath, that she “will qualify” to hold the office of state representative pursuant to the Missouri Constitution’s requirements for that office. Respondent Joshua Peters, another candidate for the Democratic party’s nomination for Missouri State Representative in the District 76, filed a petition pursuant to section 115.526, RSMo 2000, seeking to disqualify Johns as a candidate and have her name removed from any official election ballot. Peters argued that Johns could not meet the two-year durational voter registration requirement of article III, section 4 of the Missouri Constitution because she did not register to vote until February 4, 2015, which was less than two years before the general election date of November 8, 2016. Although Johns agreed that she did not meet the two-year voter registration requirement, she argued that such requirement is constitutionally invalid as applied to her. The circuit court determined that the voter registration requirement did not violate the First or Fourteenth Amendments. Johns appealed. The Supreme Court affirmed: "The State’s justification for the durational voter registration requirement’s burden on voting rights is the same as the justification it offers for the burden on Johns herself. The State’s interests in regulating the fairness of its elections and ensuring that candidates for state representative demonstrate sufficient seriousness about the electoral systems and social and civic engagement are legitimate. The two-year durational voter registration requirement is rationally related to those interests and a reasonable method of furthering them. Accordingly, article III, section 4 does not violate the First Amendment voting rights of the voters of District 76."