Presidential candidate Ralph Nader (search) won a spot Wednesday on the November ballot in Washington state but suffered setbacks in his effort to be listed on Michigan, Oregon and Texas ballots.

The secretary of state's office in Washington, where Nader won 4 percent of the vote in 2000, said he would be listed as an independent after submitting 1,983 signatures. The minimum required is 1,000.

Also Wednesday, a federal judge rejected Nader's claims that Texas' tough ballot access requirements for independent candidates are unconstitutional. Nader's campaign tried to get him on the ballot by collecting voter signatures but turned them in two weeks after the state deadline in May.

Nader supporters were in federal court in Michigan seeking an order to list him as the Reform Party candidate there. But U.S. District Judge Bernard Friedman ruled that Secretary of State Terri Lynn Land could not be expected to choose between Michigan's two warring Reform Party (search) factions.

Only one has nominated Nader for the state ballot. Land said she wouldn't recognize the nomination until the two factions decide which was legitimate.

Nader also failed to qualify for the Oregon ballot Wednesday because some petition sheets turned in by his supporters failed to comply with the law.

Oregon Secretary of State Bill Bradbury said the Nader campaign fell about 200 signatures short of the 15,306 registered voters' signatures needed to put Nader on the Nov. 2 ballot.

Nader spokesman Kevin Zeese said the consumer advocate would challenge the Michigan and Oregon rulings.

"It's a very serious attack on democracy going on," Zeese said. "They're really undermining a chance for third parties to have a voice in the system."

He denounced what he claimed were illegal Democratic-supported tactics, including intimidation and harassment of Nader's signature gatherers.

"If as a result of this we have to spend all our time in Florida, that's what we'll do," Zeese said. On Tuesday, Florida election officials agreed to put Nader of their ballots as the Reform Party candidate.

Democrats believe Al Gore would have carried Florida in 2000, and thus have won the presidency, had Nader not been on the ballot as a Green Party candidate.

In Michigan, Judge Friedman said he might reconsider his decision, depending on how the Michigan Court of Appeals rules after hearing arguments Wednesday on whether Nader should be on Michigan ballots as an independent.

The Board of State Canvassers deadlocked 2-2 last week on whether to certify the 50,000 signatures turned in to get Nader on the Nov. 2 ballot as an independent. The board's Republicans voted yes; the Democrats, no. Republicans gathered about 45,000 of the signatures. Nader needed 30,000 to get on the ballot.

Michigan faces a Friday deadline for getting candidates and ballot issues on the Nov. 2 ballot.

Zeese said Nader wants to be on the Michigan ballot as a Reform Party candidate, not an independent. He has said, however, that Nader wouldn't reject the GOP-collected signatures until he exhausts his efforts to get on the ballot as the Reform Party candidate.

Nader also secured a place Tuesday on the ballots in Connecticut and Wyoming, but failed to win a spot in Massachusetts after state officials ruled he did not collect enough signatures and had defects in his paperwork.

So far, Nader is officially on the ballot in 15 states and Washington, D.C., and can appear on at least five others through his Reform Party endorsement. He has submitted petitions to be on the ballot in at least 15 other states, but Democrats have filed legal challenges in many of those states to keep him off ballots.

Democrats already have shut Nader off the ballot in several states, including Arizona, Missouri, Maryland, Illinois and Pennsylvania, by uncovering irregularities in his petitions. Still, Nader is on track to appear on ballots in many states actively contested by President Bush and Democrat John Kerry.