Bullock v. Carter

Case Overview

Bullock v. Carter, 405 U.S. 134 (1972), struck down Texas's primary-election filing-fee system as a violation of the Equal Protection Clause of the Fourteenth Amendment. Would-be candidates for local office in the Texas Democratic primary challenged a scheme that required filing fees running as high as $8,900, with no write-in route or other alternative for those who could not pay. Chief Justice Burger, writing for the Court, held that because the fees fell with unequal weight on candidates and voters according to their ability to pay, and barred otherwise qualified candidates from the ballot, the system had to be closely scrutinized rather than reviewed for a mere rational basis. The Court concluded the fees could be sustained only if reasonably necessary to a legitimate state objective, and that Texas's interests in limiting the ballot and financing its primaries did not meet that test, since those costs could be covered by means other than charging the candidates. The ruling affirmed a three-judge district court, 321 F. Supp. 1358 (N.D. Tex. 1970). Justices Powell and Rehnquist took no part in the decision.