Term limits; Jurisdiction; Moore v McCartney; Challenges to term limits brought as candidates; Whether the claims had to be analyzed under the Anderson-Burdick framework; Citizens for Legislative Choice v Miller; Challenges to term limits brought as voters; State-law claims 

[This appeal was from the WD-MI.] The court held that Michigan’s term limits for legislators, approved by Michigan voters, are constitutional where they are “rationally related to their purported goal: electing a citizen legislature.” Plaintiffs-legislators argued that term limits violate their ballot-access and freedom-of-association rights under the First and Fourteenth Amendments, and also violate the Michigan Constitution. The district court granted defendants summary judgment. After holding that it had jurisdiction over the case where it raised questions under the U.S. Constitution, the court considered plaintiffs’ claims as both candidates and voters. Regarding their claims as candidates, they argued that the limits prevented “experienced candidates from running for state legislative office.” The court first rejected their argument that their claims must be analyzed under the Anderson-Burdick framework, as are other election regulations, because “term limits are not state election laws.” Instead, they “are the state’s attempt to set qualifications for its officeholders.” It reasoned that instead of “keeping eligible candidates off the ballot[,] . . . term limits restrict eligibility for office.” The court declined “to apply heightened scrutiny, because candidates do not have a fundamental right to run for office.” It held that term limits pass rational-basis review. As voters, plaintiffs argued that their rights were violated where they were prevented from voting for experienced candidates. The court again applied rational-basis review, holding that “[j]ust as candidates have no fundamental right to run for office, voters have no fundamental right to ‘vote for a specific candidate or even a particular class of candidates.’” But it vacated the district court’s rulings on plaintiffs’ state-law claims as to whether the term-limit amendment was procedurally defective and whether it violated the Michigan Constitution’s Title-Object Clause, to allow the state courts to consider the issues. Affirmed in part, vacated in part, and remanded.