Semple v. Griswold

In Semple v. Griswold, the Tenth Circuit upheld an amendment to the Colorado Constitution that instituted stricter requirements for petitions to make it onto the ballot by mandating signatures from two percent of voters in every state senate district. Relying heavily on the Supreme Court decision Evenwel v. Abbott, the court held that variances in the number of registered voters in each district did not violate the Equal Protection Clause. By extending Evenwel to the direct democracy context, the Tenth Circuit overlooked key differences between representational and direct democratic models. As a result, Semple will curtail methods of direct legislation--such as ballot initiatives--that give voters a stronger voice in state governance.