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On May 13, U.S. District Court Judge John Koeltl, a Clinton appointee, refused to enjoin the New York ballot access changes made in 2020. Libertarian Party of NY v New York State Board of Elections, s.d., 1:20cv-5820. The opinion says the 2% vote test for president/governor, and the new number of signatures for a statewide office (45,000), are not severe.
The decision cites only precedents that upheld state ballot access laws, and doesn’t mention any precedents that struck them down. It does not mention the March 29, 2021 decision of the Sixth Circuit that struck down Michigan’s 30,000-signature requirement for statewide independent candidates.