The Rise and Fall of the Party Line
April 30, 2026
In March 2025, New Jersey Governor Phil Murphy signed into law A5116/S4142, codified at N.J. Rev. Stat. § 19:23-23.2 (Murphy quietly signs primary ballot design bill, New Jersey Globe (link)), a redesign of the state’s primary ballots removing the “party line.” Governor Murphy signs bill revamping design of primary ballots, NJ Monitor (link). The party line, which had allowed local party leaders to place endorsed candidates in a prominent position on the ballot, enabled local political parties to put their thumbs on the scales for decades. New Jersey’s ballot design that gave party bosses big influence is officially dead, Politico (link). But by the time of this 2025 law, the long-controversial practice peculiar to New Jersey was on life support. The 2024 case Kim v. Hanlon explains how the party line fell out of favor. Kim v. Hanlon (3d Cir. 2024) (link).
New Jersey has been a stronghold for machine politics since the days of Tammany Hall. In the early 20th century, political bosses like Jersey City’s Frank Hague and Atlantic City’s Nucky Johnson perpetuated powerful party organizations that employed patronage and spoils system tactics to guarantee electoral success. Book review: The Garden State’s legendary bosses – North and South, Star Ledger (link). At the peak of this system in the early 1900s, these machines had absolute control over party nominations. Understanding the party line in NJ, Rutgers University (link). Though state reforms spearheaded by Governor Woodrow Wilson implemented direct primary elections, gradual changes to the law re-empowered local parties and the party line emerged. Understanding the party line, Rutgers. In recent years, the line has been effective in aiding the local parties’ preferred candidates—one study determined the line caused an 11.6% change in voter behavior, a swing that outpaces those caused by voter ID laws and voter roll purges in impact. Hanlon at 150-51; New Jersey’s ballot, Politico.
Caption: An example of a ballot utilizing the party line structure. Hanlon at 148. Note the clustering of county-endorsed Democrats placed prominently in Column B, while disfavored candidates are placed far off to the side (in what candidates call “ballot Siberia”). Why Everyone in New Jersey Politics Is Talking About ‘the Line’, NY Times (link).
It was in this context that Andy Kim, a New Jersey congressman, sought the Democratic nomination for the 2024 Senate race. Kim’s most prominent primary opponent, First Lady Tammy Murphy, utilized her and her husband’s connections to garner endorsements from county parties, proving especially successful with those that allowed their county chairs to directly choose the winner. Buzz grows for Andy Kim in unusual New Jersey Senate primary, The Hill (link). Kim publicly objected to this trend and, along with other Democratic primary candidates in co-occurring races, sought an injunction against several county clerks to halt ballots with the party line feature.
The District Court of New Jersey found that the party line system, by providing an advantage to beneficially-placed candidates, placed a severe burden on the candidates’ First Amendment rights. Kim v. Hanlon, No. CV241098ZNQTJB, 2024 WL 1342568 (D.N.J. Mar. 29, 2024), aff’d, 99 F.4th 140 (3d Cir. 2024). The county clerks’ claimed interests, including preserving candidates’ right to associate and communicate as well as alleviating voter confusion, were not “especially compelling.” Voter confusion was especially dubious, the District Court asserted, because the party line seemed to cause more confusion in some cases: a county ballot in the 2020 Democratic primary, for example, resulted in the invalidation of nearly one-third of votes when confused voters mistakenly selected multiple candidates for the same position. The District Court additionally determined the county line, in putting a thumb on the scale before votes are cast, likely violated the Elections Clause: while the Clause allows states to regulate of the “manner” of elections, the favoritism of organization-endorsed candidates likely exceeds this scope and thus renders the state pre-empted by federal election laws. Finding that Kim and the other candidates’ harms would be irreparable if the ballot proceeded (and that this harm outweighs any burden on the state), the District Court granted the injunction.
The Camden County Democratic Committee (CCDC), a county party intervenor at the district court level, appealed the case. Upon determining the case was justiciable and that the CCDC could appeal to defend its own interests, the Third Circuit upheld the injunction. Kim v. Hanlon (3d Cir. 2024). To justify this, the Third Circuit mirrored logic seen in the lower court opinion—the county line discriminates based on associational choices and policy positions and thus must be held to strict scrutiny under First Amendment doctrine; the CCDC’s interests likely do not outweigh the burden on Kim and the other candidates, as the CCDC can still endorse candidates and communicate that endorsement through other channels, and therefore the First Amendment is likely violated; and the favoring of county-endorsed candidates improperly stacks the deck before voting, thus likely violating the Elections Clause.
In the aftermath of Hanlon and the accompanying public attention, the party line was phased out. In reaction to the injunction, First Lady Murphy dropped out of the 2024 Senate race, clearing the way for Congressman Kim to win the nomination and ultimately become senator. Tammy Murphy withdraws from U.S. Senate race, NJ Monitor (link). Following the implementation of the law removing the party line from ballots permanently, candidates began to focus less on securing county party support: as Rutgers professor Julia Sass Rubin observed during the 2025 elections, “[M]any Democrats and Republican candidates, including pretty legitimate candidates with a shot at winning, [are] choosing not to go for an endorsement. That would have been unheard of before.” Could absence of party line lead to primary election surprises?, NJ Spotlight News (link). County parties are not yet voiceless, but recent results are mixed—Congresswoman Mikie Sherrill likely benefited from strong party organizational support in her win of New Jersey’s 2025 gubernatorial primary, while Alalilia Mejia prevailed in a 2026 special congressional primary election even as county parties endorsed other candidates. New Jersey’s ‘county line’ is gone. But the fight over its constitutionality continues, Politico (link).
In triggering the end of the party line system, Kim v. Hanlon holds importance in reshaping the New Jersey political environment away from machine politics. While recent results are helpful as early indicators, the full effects of the change in ballot structure are yet to be seen.