Matter of Bachmann v. Coyne, 48 N.Y.2d 604 (1979)
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A political party’s rules cannot be more restrictive than the state’s Election Law regarding the designation or nomination of candidates, particularly for judicial office.
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Summary
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This case concerns the validity of a Conservative Party rule requiring party authorization for judicial nominations, where the state’s Election Law allows such nominations without party authorization under specific circumstances. The New York Court of Appeals affirmed the Appellate Division’s decision, holding that the party rule was invalid because it was more restrictive than the Election Law. The court emphasized that while the Election Law generally requires candidates to be enrolled members of the party, it provides exceptions for judicial nominations, rendering the party’s stricter rule inconsistent and unenforceable.
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Facts
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The Conservative Party had a rule requiring party authorization for judicial nominations. However, Section 6-120 of the New York Election Law allows for the nomination of individuals who are not enrolled members of the party for judicial office without requiring party committee authorization.
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Procedural History
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The case originated from a dispute over the application of the Conservative Party’s rule regarding judicial nominations. The Appellate Division ruled that the party’s rule was invalid because it conflicted with Section 6-120 of the Election Law. The New York Court of Appeals subsequently affirmed the Appellate Division’s decision.
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Issue(s)
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Whether a political party’s rule requiring party authorization for judicial nominations is valid when the state’s Election Law permits such nominations without authorization.
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Holding
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No, because the Conservative Party rule which would require party authorization for a judicial nomination is more restrictive than the statute and, therefore, invalid.
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Court’s Reasoning
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The court reasoned that the Election Law specifies when a primary designating petition for party nomination is valid, stating it