The state's rights argument comes back around in an unexpected way.

Accordingly, states exercise their plenary appointment power not only to regulate the electors themselves, but also to regulate candidate access to presidential ballots. Absent a separate constitutional constraint, then, states may exercise their plenary appointment power to limit presidential ballot access to those candidates who are constitutionally qualified to hold the office of President. And nothing in the U.S. Constitution expressly precludes states from limiting access to the presidential ballot to such candidates. See Lindsay v. Bowen, 750 F.3d 1061, 1065 (9th Cir. 2014).