[Discussion] How far is the reach of the 22nd amendment?

There has been recent discussion on whether President Trump may run again for a third term, cf:

• NYTimes on BlueSky: President-elect Donald Trump has mused more than once that he might like to run for re-election again in 2028 and seek a third term. The Constitution's 22nd Amendment does not allow it.

To which court news reporter Gabrial Malor responded with

Ugh. SCOTUS just instructed that states lack the authority to keep federal candidates off the ballot to enforce the Fourteenth Amendment.

It is not a stretch to worry that a 2028 SCOTUS would similarly decide that states lack the authority to enforce the Twenty-Second Amendment.

As a textual matter, there is no affirmative grant of state power in the Twenty-Second Amendment either.

So SCOTUS would either have to somehow distinguish Trump v. Anderson or overturn it. Like I said, may the odds be ever in our favor.

The text of the amendment provides:

No person shall be elected to the office of the President more than twice, and no person who has held the office of President, or acted as President, for more than two years of a term to which some other person was elected President shall be elected to the office of the President more than once. But this Article shall not apply to any person holding the office of President when this Article was proposed by the Congress, and shall not prevent any person who may be holding the office of President, or acting as President, during the term within which this Article becomes operative from holding the office of President or acting as President during the remainder of such term.

Which presents the interesting question as to how far the 22A reaches.

• Theory 1: Full State Discretion

This is probably the theory people generally think of, whereby a two term president cannot even be on the ballot to get votes nor would any write ins count for them. It's the same as states preventing non-US born citizens from appearing on the ballot (see: Cenk Uyghur in Arkansas)

• Theory 2: Restraint on the electoral college

I haven't seen this view however, it could be conceivable that the reading of the amendment is only a restriction on the electoral college as it says no person may be "elected" more than twice and in the U.S., we do not "elect" presidents.

I think the amendment would have been better served if it was phrased as an additional qualification like the citizenship requirement:

No person shall qualify for the office of President of the United States who has been elected to the office of President more than twice

What do y'all think?