Donald Trump-only primary ballot in Minnesota survives legal challenge

The United States Supreme Court on Monday, Feb. 22, declined to hear a challenge to the March Trump-only ballot, allowing it to stand.

Then-President Donald Trump speaks at a “Make America Great Again” rally on Friday, Oct. 30, 2020, at Rochester International Airport in Rochester, Minn. (Traci Westcott / Forum News Service file photo)
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ST. PAUL — Remember that Minnesota Republican presidential primary ballot that only had Donald Trump’s name on it, despite other candidates running?

Looks like it was legal.

The United States Supreme Court on Monday, Feb. 22, declined to hear a challenge to the March Trump-only ballot, allowing it to stand. Before the primary, the Minnesota Supreme Court ruled that the Trump-only ballot was legal .

The justices offered no comments in their Monday denial to hear the case. It would have taken four justices to support a hearing.

The challenge was brought by one candidate’s supporter who argued that Republican Party of Minnesota and Secretary of State Steve Simon violated his rights to vote for a candidate of his choosing. The final ballot included Trump’s name and a line for write-in candidates.


The candidate himself, Roque “Rocky” De La Fuente, is a perennial candidate for various offices whose name appeared in other states this year, and, as has always been the case, he garnered little support.

Nonetheless, the end result of the legal challenges appears to cement a remarkable power in the heads of major political parties in Minnesota, at least in presidential primary elections.

The decision to have only Trump’s name appear was made by Jennifer Carnahan, chairwoman of the Republican Party of Minnesota, in October 2019, when a number of Republicans, some with political pedigrees and some without, were mounting longshot challenges to Trump. The Trump-only ballot in Minnesota was part of a national movement that, ultimately, could leave the false impression that there was no dissent within GOP ranks.

An all-in Trump supporter, Carnahan at the time was unapologetic about her reasons, saying that the then-president is “extremely popular in Minnesota and my job as chairwoman is to make sure we deliver our 10 electoral votes” to Trump in 2020. The move raised some eyebrows among Republican elected officials but did not lead to any vociferous objections.

Simon essentially acceded to Carnahan, saying state law dictated it is the party’s right to furnish whichever name or names it preferred through whatever method it chose, and Carnahan was the agent of the party.

In defending Simon during arguments before the Minnesota Supreme Court, Nathan Hartshorn said of the names on the primary ballot: “It’s a political decision.”

For decades, that was obvious, since the winnowing of presidential candidates was made through the caucus system — a network of gatherings organized, run and paid for entirely by each party.

But in 2020, Minnesota switched from caucuses to a primary — and the printing of ballots and administering and tallying of the vote was no longer done by parties, but taxpayer-funded government election offices, potentially giving the appearance of a fully democratic process. That $12 million in public funds spent to administer the primary should have outlawed the idea that one person had the power to dictate the content of a ballot, attorney Erik Kaardal unsuccessfully argued.


In accepting Monday’s U.S. Supreme Court decision, Jim Martin, the Lake Elmo voter who brought the lawsuit, said the following in a statement: “Minnesotans have a paramount constitutional entitlement to be presented with a ballot that accurately identifies the candidates participating in an election,” says Martin, “This protection was not just denied to Rocky and me; this Russian-style denial of ballot access to legitimate party-chosen candidates and the suppression of Minnesota voters who support them is becoming a permanent tear in the fabric of our republic.”

The Democratic-Farmer-Labor Party allowed 15 names to appear on the ballot, as well as a spot for “uncommitted” — a vote for a national convention delegate free to support any candidate. But the DFL disqualified three candidates for failing to meet its own internal requirements, and in a brief with the Minnesota Supreme Court, the Minnesota DFL defended the Trump-only ballot .

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