¶  25 However, the United States Supreme Court has rejected the notion that "any burden upon the right to vote must be subject to strict scrutiny," emphasizing that "[o]ur cases do not" support that "erroneous assumption." Burdick v. Takushi, 504 U.S. 428, 432, 112 S.Ct. 2059, 119 L.Ed.2d 245 (1992) (upholding a state's ban on write-in candidates).  The Burdick Court explained that states have the right to regulate their state elections, and it noted that "government must play an active role in structuring" those elections.  Id. at 433, 112 S.Ct. 2059. The Court emphasized that "there must be a substantial regulation of elections if they are to be fair and honest" and promote order in our democracy.  Id. The Court acknowledged that such regulations would necessarily impose some burdens upon voters.  Id. It concluded, however, that "to subject every voting regulation to strict scrutiny ... would tie the hands of [s]tates seeking to assure that elections are operated equitably and efficiently."  Id. Thus, the level of scrutiny used to review a state election law depends on the extent of the burden imposed on voters' rights guaranteed by the First and Fourteenth Amendments to the United States Constitution.  Id. at 434, 112 S.Ct. 2059.  As such, only "severe" restrictions are subject to strict scrutiny review.  Id. (citing Norman v. Reed, 502 U.S. 279, 289, 112 S.Ct. 698, 116 L.Ed.2d 711 (1992)). Accordingly, in Burdick, the ban on write-in voting, as part of a larger system that afforded "constitutionally sufficient ballot access, d[id] not impose an unconstitutional burden" and was not subject to strict scrutiny analysis.  Id. at 441, 112 S.Ct. 2059;  see also Rodriguez v. Popular Democratic Party, 457 U.S. 1, 8, 10-11, 102 S.Ct. 2194, 72 L.Ed.2d 628 (1982) (rejecting constitutional challenge to Puerto Rico's system of allowing only members of ex-representative's party to elect interim representative and noting that choice of system entitled to substantial deference).