According to a statute of the state of Kiowa, a candidate for state office may have his name placed on the official election ballot only if he files with the appropriate state official a petition containing a specified number of voter signatures. Roderick failed to get his name placed on the state ballot as an independent candidate for governor because he failed to file a petition with the number of voter signatures required by state statute. In a suit against the appropriate state officials in federal district court, Roderick sought an injunction against the petition signature requirement on the ground that it was unconstitutional. Which of the following, if established, constitutes the strongest argument for Roderick?
Compliance with the petition signature requirement is burdensome. The objectives of the statute could be satisfactorily achieved by less burdensome means. Because of the petition signature requirement, very few independent candidates have ever succeeded in getting on the ballot.  The motivation for the statute was a desire to keep candidates off the ballot if they did not have strong support among voters.