and independent candidacies does not manifest itself until after the major parties have adopted their platforms and nominated their candidates.”). Consequently, a deadline for showing support which is too early may be an arbitrary restriction precluding third party candidates from accessing a general election ballot. See MacBride, 558 F.2d at 448 (rejecting as arbitrary a deadline for party signature requirements nine months before general election and ninety days before primary election). We have nevertheless upheld deadlines for showing voter support as early as one week before a primary election, Libertarian Party, 764 F.2d at 542, and the Supreme Court has upheld deadlines occurring even before primary elections are held. Compare Am. Party of Tex., 415 U.S. at 787, 94 S.Ct. 1296 (<HOLDING>) and Jenness, 403 U.S. at 433-34, 91 S.Ct. 1970
holding that 120 days notice was satisfied by 30 days work plus 90 days pay holding deadline 120 days before election was not unreasonable or unduly burdensome holding that plaintiffs request for substantially similar product types was not overbroad unduly burdensome or oppressive holding delay of 51 days to be unreasonable holding deadline for new political parties which was 90 days before primary election was particularly troublesome