# Burdick v. Takushi **Status: stub — expand.** **504 U.S. 428 (1992).** The Court upheld Hawaii's ban on write-in voting and, in doing so, restated [[Anderson v. Celebrezze]] as a **sliding scale**: a regulation imposing a *severe* burden on First and Fourteenth Amendment rights must be narrowly tailored to a compelling state interest, while "reasonable, nondiscriminatory restrictions" are sustained by the state's important regulatory interests alone. **The case is usually decided the moment the word is chosen.** Because "severe" and "reasonable" carry entirely different outcomes and neither is defined, the characterization step does the work that scrutiny normally does — which is why a framework that reads as balancing operates as deference. Stage 6 of [[How a Candidate Gets on the Ballot]].