—it was held that a provision of the Wyoming Constitution declaring that the governor should not be eligible to any other office during the term for which he was elected could not prevent the governor from becoming a member of the United States House of Representatives or the United States Senate because the qualifications for those offices are established by the United …

To the contrary, an impressive number of courts have determined that States lack the authority to add qualifications.

Whenever States have attempted to require qualifications for the office of United States Senator other than those named in the third clause of § 3 of Article 1 of the Constitution of the United States, they have been uniformly rejected by the State courts.

—holding that it is unconstitutional qualification for state to require its governor to resign in order to run for Congress

Instead, we continue to believe that " `[i] f no person can be elected to that office who does not possess these qualifications, it follows by a familiar rule of interpretation that any person who does possess them may be elected.'"

—state constitution cannot bar Governor and Lieutenant Governor from becoming members of Congress during term

For court cases relying on Justice Story's view that states do not have the power to add to the Qualifications Clauses

—the Wyoming Supreme Court undertook a detailed historical analysis and concluded that the Qualifications Clauses were exclusive.

The First Circuit, however, has addressed this issue, and concluded that "the test to determine whether or not the `restriction'amounts to a `qualification'within the meaning of Article I, Section 3, is whether the candidate `could be elected if his name were written in by a sufficient number of electors.'"