There's no need, because the convention process is easier. But Richard Winger of Ballot Access News, the leading site on such issues, writes:
Iowa ballot access for U.S. House candidates in primaries is severe. (Loebsack) could probably have won a lawsuit against the county distribution requirement. All county distribution requirements that have been tested in court, for candidate or party ballot access, have been eliminated (except in Pennsylvania). In 1969 the U.S. Supreme Court said county distribution requirements are unconstitutional for statewide petitions, since they give more power to residents of low-population counties than high-population counties. The 2000 U.S. Supreme Court decision Bush v Gore reinforced the old 1969 decision. Since Bush v Gore came out, several courts have even invalidated county distribution requirements for initiatives.
In fact, it's easier in Iowa for third parties and independents to get on the ballot for US House: 300 signatures from the district, no county requirement. Loebsack needed to get a total of 1716 AND meet county requirements.
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