David Perney


In 1989, Judge Harrison L. Winter of the United States Court of Appeals for the Fourth Circuit announced that "under appropriate circumstances" a write-in vote for Donald Duck would be constitutionally protected as an exercise of a citizen's right to vote.' This pronouncement added to the growing but muddled field of jurisprudence concerning the right to vote. In Burdick v. Takushi, the United States Supreme Court eased back the broad parameters of the right to vote that the Fourth Circuit appeared to define. The goal of this Note is to outline the reasoning of the Burdick v. Takushi decision, to define the decision's effect on the write-in vote, and to explore the implications of the decision on the nature and extent of the right to vote.

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