not on the requirement for “candidates [to] show a ‘modicum’ of support prior to their placement on the ballot.” Appellant’s Br. at 10. Instead, they specifically challenge as undue and excessive the percentage of support they are required to show under the statute. Id. (“[T]he issue in this case is whether the modicum of support that Section 16.1-11-36 actually requires— more than 15 percent of the eligible pool for some candidates — is constitutional.”). The Supreme Court often focuses on the amount of support a candidate is required to show when determining whether a ballot access restriction is constitutional, specifically considering the percentage of signatures or votes required. See, e.g., Munro v. Socialist Workers Party, 479 U.S. 189, 190, 107 S.Ct. 533, 93 L.Ed.2d 499 (1986) (<HOLDING>); Am. Party of Tex., 415 U.S. at 774-75, 783,
holding that state may not compel political parties to allow nonmembers to vote in primary elections holding that state may not compel political party to allow nonmembers to vote in its primary elections holding as constitutional a 1 vote requirement in a blanket primary holding that the right to vote is fundamental holding that a fair referendum assuring the equal right to vote under  101a1 includes the right of members to have the vote scheduled at a time when they can exercise their vote and the right to be free from intimidation or fear of reprisal