Fusion Voting
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Electoral fusion in the United States is an arrangement where two or more
United States political parties This list of political parties in the United States, both past and present, does not include Independent politician, independents. Not all states allow the public to access voter registration data. Therefore, voter registration data should not b ...
on a
ballot A ballot is a device used to cast votes in an election and may be found as a piece of paper or a small ball used in voting. It was originally a small ball (see blackballing) used to record decisions made by voters in Italy around the 16th cent ...
list the same
candidate A candidate, or nominee, is a prospective recipient of an award or honor, or a person seeking or being considered for some kind of position. For example, one can be a candidate for membership in a group (sociology), group or election to an offic ...
, allowing that candidate to receive votes on multiple party lines in the same election. Electoral fusion is also known as fusion voting, cross endorsement, multiple party nomination, multi-party nomination, plural nomination and ballot freedom. Electoral fusion was once widespread in the U.S. and legal in every state. However, as of 2024, it remains legal and common only in New York and Connecticut.


Overview

In 2016, ''Business Insider'' wrote: "Fusion voting gives voters a chance to support a major candidate while registering their unhappiness with that candidate's party. A cross-endorsement from a smaller party like the
Working Families Party The Working Families Party (WFP) is a progressive minor political party in the United States, founded in New York in 1998. There are active chapters in California, Colorado, Connecticut, Delaware, the District of Columbia, Georgia, Illinois ...
can also help inform voters about where candidates stand on certain issues". In 2019, ''
The Nation ''The Nation'' is a progressive American monthly magazine that covers political and cultural news, opinion, and analysis. It was founded on July 6, 1865, as a successor to William Lloyd Garrison's '' The Liberator'', an abolitionist newspaper ...
'' wrote: "Fusion is a response to the winner-take-all electoral system. It solves the '
wasted vote In electoral systems, a wasted vote is any vote cast that is not "used" to elect a winner, and so is not represented in the outcome. However, the term is vague and ill-defined, having been used to refer to a wide variety of unrelated concepts ...
' or '
spoiler Spoiler or Spoilers may refer to: Arts, entertainment and media * Spoiler (media), something that reveals significant plot elements * The Spoiler, DC Comics superheroine Stephanie Brown Film and television * ''Spoiler'' (film), 1998 American ...
' dilemmas that otherwise plague third parties, and allows citizens who don't fit neatly into the Democratic or Republican boxes to nevertheless participate constructively in politics". Before the
Civil War A civil war is a war between organized groups within the same Sovereign state, state (or country). The aim of one side may be to take control of the country or a region, to achieve independence for a region, or to change government policies.J ...
, fusion voting was a common electoral tactic of
abolitionist Abolitionism, or the abolitionist movement, is the political movement to end slavery and liberate enslaved individuals around the world. The first country to fully outlaw slavery was Kingdom of France, France in 1315, but it was later used ...
forces, who formed a number of anti-slavery third parties, including the
Liberty Liberty is the state of being free within society from oppressive restrictions imposed by authority on one's way of life, behavior, or political views. The concept of liberty can vary depending on perspective and context. In the Constitutional ...
and
Free Soil The Free Soil Party, also called the Free Democratic Party or the Free Democracy, was a political party in the United States from 1848 to 1854, when it merged into the Republican Party. The party was focused on opposing the expansion of slav ...
parties. These and other abolitionist third parties cross-nominated major party candidates running under the Whig label, fusing more than one party behind a single candidate. After the Civil War, agrarian interest groups and the political parties they founded continued to use fusion voting to form alliances between third parties and the weaker of the two major parties, usually the Democrats in the West and Midwest. In the 19th and early 20th century, minor parties used fusion as a way to signal that their support for a major party candidate brought a meaningful number of voters to the candidate. Votes for fusion candidates were tallied first by party, then added together to produce the outcome. Historian Peter Argersinger argues that this helped "maintain a significant third party tradition by guaranteeing that dissenters' votes could be more than symbolic protest". Fusion allowed minor parties to avoid the "wasted vote" and "spoiler" dilemmas that small parties face in a non-proportional voting system. The People's Party (also known as the Populists) is regarded as the most successful third party of the era. That success produced a counter-reaction from the dominant major parties, who then used state legislatures to enact bans against fusion in the late nineteenth and early 20th century. In northern and western states, fusion was largely banned by Republican-led legislatures. One Republican
Minnesota Minnesota ( ) is a U.S. state, state in the Upper Midwestern region of the United States. It is bordered by the Canadian provinces of Manitoba and Ontario to the north and east and by the U.S. states of Wisconsin to the east, Iowa to the so ...
state legislator said: "We don't propose to allow the Democrats to make allies of the Populists,
Prohibitionists Prohibition is the act or practice of forbidding something by law; more particularly the term refers to the banning of the manufacture, storage (whether in barrels or in bottles), transportation, sale, possession, and consumption of alcoholic be ...
, or any other party, and get up combination tickets against us. We can whip them single-handed, but don't intend to fight all creation." In southern states, fusion was largely banned by Democrats who supported
Jim Crow The Jim Crow laws were state and local laws introduced in the Southern United States in the late 19th and early 20th centuries that enforced racial segregation, " Jim Crow" being a pejorative term for an African American. The last of the ...
, in an attempt to prevent political alliances between newly-enfranchised Black voters and poor white farmers. Most states banned fusion by the early 20th century. South Dakota banned the practice in 1999, Delaware banned it in 2011, and South Carolina banned it in 2022. In '' Timmons v. Twin Cities Area New Party'' (1997), the
US Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all Federal tribunals in the United States, U.S. federal court cases, and over Stat ...
ruled that prohibiting electoral fusion does not violate the
First Amendment First most commonly refers to: * First, the ordinal form of the number 1 First or 1st may also refer to: Acronyms * Faint Images of the Radio Sky at Twenty-Centimeters, an astronomical survey carried out by the Very Large Array * Far Infrared a ...
of the Constitution. Electoral fusion was once widespread in the US, but as of 2024, it remains legal and common only in New York and
Connecticut Connecticut ( ) is a U.S. state, state in the New England region of the Northeastern United States. It borders Rhode Island to the east, Massachusetts to the north, New York (state), New York to the west, and Long Island Sound to the south. ...
. It is partially legal in three others: California allows fusion in presidential elections only, and
Pennsylvania Pennsylvania, officially the Commonwealth of Pennsylvania, is a U.S. state, state spanning the Mid-Atlantic (United States), Mid-Atlantic, Northeastern United States, Northeastern, Appalachian, and Great Lakes region, Great Lakes regions o ...
and
Maryland Maryland ( ) is a U.S. state, state in the Mid-Atlantic (United States), Mid-Atlantic region of the United States. It borders the states of Virginia to its south, West Virginia to its west, Pennsylvania to its north, and Delaware to its east ...
permit it in certain elections, including but not limited to the
judiciary The judiciary (also known as the judicial system, judicature, judicial branch, judiciative branch, and court or judiciary system) is the system of courts that adjudicates legal disputes/disagreements and interprets, defends, and applies the law ...
. In Oregon and Vermont, a system of dual-labeling exists, which allows a candidate to list multiple party endorsements on a single line, but disallows the traditional fusion system in which a minor party has its own ballot line and votes are tallied by party. In
New Hampshire New Hampshire ( ) is a U.S. state, state in the New England region of the Northeastern United States. It borders Massachusetts to the south, Vermont to the west, Maine and the Gulf of Maine to the east, and the Canadian province of Quebec t ...
, fusion is legal in rare cases when primary elections are won by
write-in candidate A write-in candidate is a candidate whose name does not appear on the ballot but seeks election by asking voters to cast a vote for the candidate by physically writing in the person's name on the ballot. Depending on electoral law it may be poss ...
s. As of 2024, the
Alianza de País Country Alliance () is an electoral alliance in Puerto Rico for the 2024 Puerto Rican general election composed by two progressive, anti-colonial parties of Puerto Rico. Background In the 2016 gubernatorial election, the independent candid ...
in Puerto Rico, the New Jersey Moderate Party, the Common Sense Party in Michigan and the United Kansas Party are attempting to use litigation to bring back fusion voting in their areas.
New Mexico New Mexico is a state in the Southwestern United States, Southwestern region of the United States. It is one of the Mountain States of the southern Rocky Mountains, sharing the Four Corners region with Utah, Colorado, and Arizona. It also ...
,
Massachusetts Massachusetts ( ; ), officially the Commonwealth of Massachusetts, is a U.S. state, state in the New England region of the Northeastern United States. It borders the Atlantic Ocean and the Gulf of Maine to its east, Connecticut and Rhode ...
, and
Rhode Island Rhode Island ( ) is a state in the New England region of the Northeastern United States. It borders Connecticut to its west; Massachusetts to its north and east; and the Atlantic Ocean to its south via Rhode Island Sound and Block Is ...
had bills to allow fusion voting.


Historical examples


Presidential elections

In
1872 Events January * January 12 – Yohannes IV is crowned Emperor of Ethiopia in Axum, the first ruler crowned in that city in over 500 years. *January 20 – The Cavite mutiny was an uprising of Filipino military personnel of Fort S ...
, both the newly formed Liberal Republican Party and the Democratic Party nominated the Liberal Republican
Horace Greeley Horace Greeley (February 3, 1811 – November 29, 1872) was an American newspaper editor and publisher who was the founder and newspaper editor, editor of the ''New-York Tribune''. Long active in politics, he served briefly as a congres ...
as their candidate for US President: "If
he Democratic Party He or HE may refer to: Language * He (letter), the fifth letter of the Semitic abjads * He (pronoun), a pronoun in Modern English * He (kana), one of the Japanese kana (へ in hiragana and ヘ in katakana) * Ge (Cyrillic), a Cyrillic letter cal ...
was to stand any chance at all against Grant, it must avoid putting up a candidate of its own who would merely split the opposition vote. It must take Greeley." In the presidential election of 1896,
William Jennings Bryan William Jennings Bryan (March 19, 1860 – July 26, 1925) was an American lawyer, orator, and politician. He was a dominant force in the History of the Democratic Party (United States), Democratic Party, running three times as the party' ...
was nominated by both the Democratic Party and the
Populist Party Populist Party may refer to: Asian and European political parties and movements *Croatian Popular Party (1919), a Croatian right-wing party also known as Croatian Populist Party * Indonesian National Populist Fortress Party, an Indonesian populist ...
, albeit with different vice presidential candidates,
Arthur Sewall Arthur Sewall (November 25, 1835 – September 5, 1900) was an American shipbuilder from Maine, best known as the Democratic nominee for Vice President of the United States in 1896, running mate to William Jennings Bryan. From 1888 to 1896, he s ...
for the Democrats and Thomas E. Watson for the Populists. This election led to the downfall of the Populist Party, especially in Southern states (such as Watson's Georgia, as well as North Carolina and Tennessee) where the Populist party had engaged in electoral fusion or other alliances with Republicans against the dominant
Bourbon Democrat Bourbon Democrat was a term used in the United States in the later 19th century and early 20th century (1872–1904) to refer to members of the Democratic Party who were ideologically aligned with fiscal conservatism or classical liberalism, es ...
s. In the
1936 Events January–February * January 20 – The Prince of Wales succeeds to the throne of the United Kingdom as King Edward VIII, following the death of his father, George V, at Sandringham House. * January 28 – Death and state funer ...
and
1940 A calendar from 1940 according to the Gregorian calendar, factoring in the dates of Easter and related holidays, cannot be used again until the year 5280. Events Below, events related to World War II have the "WWII" prefix. January *Janu ...
, the
American Labor Party The American Labor Party (ALP) was a political party in the United States established in 1936 that was active almost exclusively in the state of New York. The organization was founded by labor leaders and former members of the Socialist Party of ...
nominated
Franklin Roosevelt Franklin Delano Roosevelt (January 30, 1882April 12, 1945), also known as FDR, was the 32nd president of the United States, serving from 1933 until his death in 1945. He is the longest-serving U.S. president, and the only one to have served ...
for president, and in
1944 Events Below, the events of World War II have the "WWII" prefix. January * January 2 – WWII: ** Free France, Free French General Jean de Lattre de Tassigny is appointed to command First Army (France), French Army B, part of the Sixt ...
, the
Liberal Party of New York The Liberal Party of New York is a political party in New York (state), New York. Its political platform, platform supports a standard set of socially liberal policies, including abortion rights, increased spending on education, and universal h ...
cross-nominated Roosevelt, fusing with the ALP. Roosevelt won the state of New York in each election, but in 1940 and 1944 he would not have won New York without the support of votes gained via the fusion parties and their voters.
Donald Trump Donald John Trump (born June 14, 1946) is an American politician, media personality, and businessman who is the 47th president of the United States. A member of the Republican Party (United States), Republican Party, he served as the 45 ...
appeared on the 2016 presidential ballot in California with two ballot labels by his name, as the nominee of both the Republican Party and the
American Independent Party The American Independent Party (AIP) is an American political party that was established in 1967. The American Independent Party is best known for its nomination of Democratic then-former Governor George Wallace of Alabama, who carried five s ...
, a small far-right party. Trump was the first fusion presidential candidate on the California ballot in at least eighty years.


Connecticut

Connecticut allows cross-endorsements, listing candidates on more than one ballot line. Minor parties include the
Working Families Party The Working Families Party (WFP) is a progressive minor political party in the United States, founded in New York in 1998. There are active chapters in California, Colorado, Connecticut, Delaware, the District of Columbia, Georgia, Illinois ...
and Independent Party. In 2010,
Dannel Malloy Dannel Patrick Malloy (; born July 21, 1955) is an American politician who served as the 88th governor of Connecticut from 2011 to 2019. A member of the Democratic Party, he chaired the Democratic Governors Association from 2016 to 2017. In Ju ...
won within the Working Families' margin.


New York

In 1936, labor leaders in New York City took advantage of fusion and founded the American Labor Party (ALP). Their immediate goal was to provide a way for New Yorkers who despised the
Tammany Hall Tammany Hall, also known as the Society of St. Tammany, the Sons of St. Tammany, or the Columbian Order, was an American political organization founded in 1786 and incorporated on May 12, 1789, as the Tammany Society. It became the main local ...
political machine to support Franklin Roosevelt without voting for the Democratic Party. In its first showing at the polls, the party garnered a significant amount of the vote in New York City but was not important with regard to Roosevelt's victory. In the 1937 election cycle, the ALP built on its past performance by electing members to the city council, and by delivering so many votes to Mayor
Fiorello La Guardia Fiorello Henry La Guardia (born Fiorello Raffaele Enrico La Guardia; December 11, 1882September 20, 1947) was an American attorney and politician who represented New York in the U.S. House of Representatives and served as the 99th mayor of New Yo ...
that the ''New York Times'' ran a front page article declaring that the ALP held the balance of power in city and state politics. The importance of the ALP was demonstrated again in 1938 when the party provided the margin of victory for the Democratic candidate for Governor, and in 1940 when the ALP did the same for President Roosevelt. In the 1944 presidential election, fusion provided CIO unions in New York an opportunity to build and back a labor party, an uncommon occurrence in the US. Labor leaders knew that fusion permitted them to field candidates and win elections on the American Labor Party line in local elections, and to back Democrats in statewide or national races where they did not have the capacity to field successful candidates. Given the presence of fusion in New York, the Greater New York Industrial Union Council (GNYIUC), the CIO's local labor federation in New York, formally affiliated with the party making it the political arm of the New York CIO. This relationship would continue until 1948 when the GNYIUC opted to back Henry Wallace for president, instead of using fusion to back President Truman. This led to internal conflicts within the CIO and ultimately contributed to the decision by the national CIO to revoke the charter of the GNYIUC, thereby ending its relationship with the ALP. As of 2023, to obtain or maintain automatic ballot access, a party's candidate for
Governor A governor is an politician, administrative leader and head of a polity or Region#Political regions, political region, in some cases, such as governor-general, governors-general, as the head of a state's official representative. Depending on the ...
in
midterm election Apart from general elections and by-elections, a midterm election refers to a type of election where the people can elect their representatives and other subnational officeholders (e.g. governor, members of local council) in the middle of the t ...
years or
President President most commonly refers to: *President (corporate title) * President (education), a leader of a college or university *President (government title) President may also refer to: Arts and entertainment Film and television *'' Præsident ...
in presidential years must receive either 130,000 votes or 2% of votes cast (whichever is greater) on that party's line. Other parties, such as the Libertarian Party of New York and the
Green Party of New York The Green Party of New York is the affiliate of the Green Party of the United States in the U.S. state of New York. It was founded in 1992 and is a part of the Green Party movement. The Party has had ballot access at various points in its hi ...
, have sought ballot access by first getting a gubernatorial candidate on the ballot via
petition A petition is a request to do something, most commonly addressed to a government official or public entity. Petitions to a deity are a form of prayer called supplication. In the colloquial sense, a petition is a document addressed to an officia ...
(by collecting 45,000 valid signatures of
registered voters In electoral systems, voter registration (or enrollment) is the requirement that a person otherwise eligible to vote must register (or enroll) on an electoral roll, which is usually a prerequisite for being entitled or permitted to vote. The ru ...
), and then by getting 130,000 votes for that candidate on their line. As a general rule, neither party uses electoral fusion, and both rely on their own candidates. The Green Party, which had first achieved ballot status in 1998, failed to gain 50,000 votes (then the requirement) and also lost its ballot status in 2002, but regained its line when the 2010 election results were certified. In 2018, Larry Sharpe, the Libertarian Party candidate for governor in New York, received over 90,000 votes, giving the party ballot status for the first time in its history. In July 2019, the
New York Legislature The New York State Legislature consists of the two houses that act as the state legislature of the U.S. state of New York: the New York State Senate and the New York State Assembly. The Constitution of New York does not designate an offici ...
passed a budget bill that included the creation of a Public Campaign Financing Commission, which was given authority to investigate and create rules for
public financing of campaigns Campaign financealso called election finance, political donations, or political financerefers to the funds raised to promote candidates, political parties, or policy initiatives and referendums. Donors and recipients include individuals, corpora ...
. The
Conservative Party of New York The Conservative Party of New York State is an List of political parties in the United States, American political party founded in 1962 following conservative dissatisfaction with the New York Republican State Committee, Republican Party in New Y ...
and the
Working Families Party The Working Families Party (WFP) is a progressive minor political party in the United States, founded in New York in 1998. There are active chapters in California, Colorado, Connecticut, Delaware, the District of Columbia, Georgia, Illinois ...
each filed lawsuits against the state in response, alleging that the commission was a disguised attempt to end fusion voting and thus the existence of New York's third parties.


Oregon

Prior to 1958, Oregon practiced a form of fusion that required the state to list multiple nominating parties on the candidate's ballot line.
Sylvester Pennoyer Sylvester Pennoyer (July 6, 1831May 30, 1902) was an American educator, attorney, and politician in Oregon. He was born in Groton (town), New York, Groton, New York, attended Harvard Law School, and moved to Oregon at age 25. A History of the Demo ...
was elected governor in 1886 and 1890 as a candidate of the Democratic and People's parties. In 1906, seven members of the Oregon House were also elected as candidates of the People's Party and either the Democratic or Republican parties. In 2008, a lawsuit was brought by the
Independent Party of Oregon The Independent Party of Oregon (IPO) is a centrist political party in the U.S. state of Oregon with more than 140,000 registrants since its inception in January 2007. The IPO is Oregon's third-largest political party and the first political party ...
against the Oregon Secretary of State claiming that modifications to the ballot design statute in 1995 once again required the state to list multiple nominating parties on the candidate's ballot line. The lawsuit gave rise to legislation to allow candidates to list up to three party labels after their name. This bill passed both houses of the Oregon legislature during the 2009 legislative session. Governor
Ted Kulongoski Theodore Ralph Kulongoski ( ; born November 5, 1940) is an American politician, judge, and lawyer who served as the List of Governors of Oregon, 36th governor of Oregon from 2003 to 2011. A member of the Democratic Party (United States), Democrati ...
signed the bill into law on 23 July 2009.


Pennsylvania

In Pennsylvania, fusion can occur when members of a party write in the name of a member of a different party in a primary election and secure enough write-in votes to nominate that party's candidate. For example, if Bob Jones is running for school board in a primary election as a Democrat and secures both enough votes from members of his own party as well as enough write-in votes from members of the Republican Party, then electoral fusion occurs, and Bob will appear on the ballot as both a Republican and a Democrat. Similarly, a member of one party may lose their own party's nomination in a primary election but gain enough write-in votes from members of the opposing party to win that party's nomination. For example, in May 2023, Stephen Zappala lost the Democratic primary for
Allegheny County District Attorney The Allegheny County district attorney is the elected district attorney for Pittsburgh and Allegheny County, Pennsylvania. The office is responsible for the prosecution of violations of Pennsylvania commonwealth laws (federal law violations are pr ...
to challenger Matt Dugan. However, although Zappala is a Democrat, he received the requisite number (500 or more) of write-in votes from Republicans to appear as a Republican on the ballot in November 2023. Running on the ballot as a Republican, Zappala won the general election in November 2023, beating Dugan.


Vermont

In Vermont, candidates can only run in one party primary, but can run write-in campaigns in others. Political science professor Jack Gierzynski said "When parties work together in a fusion sense, they're much more likely to be successful. ... rogressivesrunning on a fusion ticket has had a big influence on moving the public policy needle to the left." Fusion voting had been at risk due to a
sore loser Sportsmanship is an aspiration or ethos that a sport or activity will be enjoyed for its own sake, and with proper consideration for fairness, ethics, respect, and a sense of fellowship with one's competitors. A "sore loser" refers to one w ...
provision of
ranked-choice voting Ranked-choice voting may be used as a synonym for: * Ranked voting, a term used for any voting system in which voters are asked to rank candidates in order of preference * Instant-runoff voting (IRV), a specific ranked voting system with single-wi ...
legislation.


Wisconsin

In
Milwaukee Milwaukee is the List of cities in Wisconsin, most populous city in the U.S. state of Wisconsin. Located on the western shore of Lake Michigan, it is the List of United States cities by population, 31st-most populous city in the United States ...
,
Wisconsin Wisconsin ( ) is a U.S. state, state in the Great Lakes region, Great Lakes region of the Upper Midwest of the United States. It borders Minnesota to the west, Iowa to the southwest, Illinois to the south, Lake Michigan to the east, Michig ...
, during the heyday of the sewer socialists, the Republican and Democratic parties would agree not to run candidates against each other in some districts, concentrating instead on defeating the socialists. These candidates were usually called
non-partisan Nonpartisanship, also known as nonpartisanism, is a lack of affiliation with a political party and a lack of political bias. While an ''Oxford English Dictionary'' definition of ''partisan'' includes adherents of a party, cause, person, etc., ...
, but sometimes were termed fusion candidates instead."Fusion In Many Districts; Old Parties Unite On Legislative Candidates" ''
Milwaukee Journal The ''Milwaukee Journal Sentinel'' is a daily morning broadsheet printed in Milwaukee, Wisconsin, where it is the primary newspaper and also the largest newspaper in the state of Wisconsin, where it is widely read. It was purchased by the G ...
'' 1 November 1918; p. 9, col. 2


See also

*
Apparentment Apparentment is the name given to the system, sometimes provided for in elections conducted according to the party-list proportional representation system, which allows parties to specify electoral alliances. The system has been used in Switze ...
*
Approval voting Approval voting is a single-winner rated voting system where voters can approve of all the candidates as they like instead of Plurality voting, choosing one. The method is designed to eliminate vote-splitting while keeping election administration ...
*
Cross-filing In United States, American politics, cross-filing (similar to the concept of electoral fusion) occurs when a candidate runs in the Partisan primary, primary election of not only their own party, but also that of one or more other parties, generall ...
*
Democratic backsliding in the United States Democratic backsliding has been identified as a trend in the United States at the state and national levels in various indices and analyses, primarily during the Jim Crow era and in the 21st century. It is "a process of regime change towards auto ...
*
Fusionism in North Carolina From 1894 to 1900 the North Carolina Republican Party and the People's Party (United States), Populist Party collaborated via electoral fusion to compete against the North Carolina Democratic Party. This political coalition was dubbed Fusionism. ...
*
Ranked-choice voting in the United States Ranked-choice voting (RCV) can refer to one of several ranked voting methods used in some cities and states in the United States. The term is not strictly defined, but most often refers to instant-runoff voting (IRV) or single transferable vote ( ...
*
Strategic voting Strategic or tactical voting is voting in consideration of possible ballots cast by other voters in order to maximize one's satisfaction with the election's results. Gibbard's theorem shows that no voting system has a single "always-best" strat ...


References


Further reading

*


External links


History of Fusion Politics in 1890s North Carolina

Cross-Endorsement by Political Parties
{{DEFAULTSORT:Electoral Fusion Election campaign terminology Voting theory ca:Coalició política es:Coalición política fr:Coalition politique pt:Coligação eleitoral