[EL] National Popular Vote Passes Crucial Milestone

[Tara Ross]

1.  Yes, "any state's decision about how it chooses electors can affect who wins the presidency," particularly when the race is close. But NPV takes matters a step further. The decisions of a few states will do more than impact who wins the presidency. It will change the very method by which we elect presidents. It will institute new rules for the presidential election game, without bothering to first obtain the consent of the governed. Honestly, for a group that claims to love democracy so much, I think that is a bit shocking.

2.  I reject the implication that every vote is not meaningful under the Electoral College system. But, yes, absolutely I think Massachusetts ditches NPV rather than give its votes to Sarah Palin. And probably it will reverse its decision on NPV if it becomes politically convenient to do so later.  As I mentioned, Massachusetts has taken similar steps in other elections before. It is not a stretch to imagine that it will do so again.

 

 

 

From: Rob Richie [mailto:rr at fairvote.org] 
Sent: Thursday, June 09, 2011 2:34 PM
To: Tara Ross
Cc: law-election at uci.edu
Subject: Re: [EL] National Popular Vote Passes Crucial Milestone

 

Tara,

 

This debate could go on all day, so I suspect this will be my final message. But (relatively) briefly:

 

1. You state that the founders that "they did not intend for a handful of states to start making decisions for other states about how presidents are to be elected." And yet it's a simple fact that any state's decision about how it chooses electors can affect who wins the presidency. After losing by three  electoral votes in 1796, for example, Jefferson moved to get Virgina to allocate electors by winner-take-all. If five votes had flipped from Jefferson to Adams in 1800, Adams would have won, which could have happened with a single state like Virginia or New York using a rule that divided electoral votes more equitably, as Pennsylvania did that year (Pennsylvania was 8-7 for Jefferson rather than 15-0 for him).

 

But there's certainly nothing in the Constitution that reflects your guess about founders' intent  -- and that's going to determine what judges do, not what you and I may surmise might have been their intent.

 

2. So to be clear, you think that even though a landslide majority of Massachusetts voters support a national popular vote for president, even though the entire election will have been organized around the idea that every vote would be equally meaningful and even though the national political ramifications of their action would be devastating for their party's nominee, the Massachusetts legislature might brazenly convene a special session in the days before the election to seek to break their agreement in the national popular vote plan just so that Massachusetts electoral votes didn't go to Sarah Palin? Let's just say we have different political judgment along with a different interpretation of the enforceability of the NPV compact.

 

Rob

 

 

On Thu, Jun 9, 2011 at 2:43 PM, Tara Ross <tara at taraross.com> wrote:

As you say, Rob, voters rarely know the mechanisms by which things work.  But, in the Massachusetts example we've been discussing, a majority of the state's voters - largely liberal Democrats - WILL know that their votes are about to be given to Sarah Palin....and they will also know (often without knowing or caring about details) that those lawyers can do something about it!  They will wholeheartedly support the lawyers who are going to "fix it" so Massachusetts does not go for Sarah Palin.  Given the constitutional problems with NPV, the lawyers will have a field day with this and will tie up the election in court for at least weeks, if not months.

 

Re: your final point about how electors can be constitutionally allocated:  

 

Your argument that states can give their electors to the winner of the national popular vote would be a lot stronger if NPV states were not insisting upon taking such action through an interstate compact.  If Massachusetts TRULY believes that it's in Massachusetts's best interest to give its electors to the winner of the national popular vote, then its legislature should vote to commit to such action NOW.  Today.  Without waiting for other states to jump on board.  Its insistence on acting with other states is problematic.  The mechanism for acting with other states to make such fundamental changes is a constitutional amendment, not an interstate compact.

 

So, in short, yes the Founders did "punt[ ] the decision for states...rather than impose a certain rule on them." But they intended for each state to make decisions for itself only.  They did not intend for a handful of states to start making decisions for other states about how presidents are to be elected.

 

 

 

From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Rob Richie
Sent: Thursday, June 09, 2011 11:26 AM


To: law-election at uci.edu
Subject: Re: [EL] National Popular Vote Passes Crucial Milestone

 

Hi, Sean

 

Elections for president are a big deal and I can guarantee that a change to a national popular vote will be notice. Once the National Popular Vote plan is enacted, everyone will know about the change who glances at a newspaper, listens to a radio, catches news on television or talks to a friend who knows anything about politics. The overwhelming number of voters will expect an election in which the winner of the national popular vote becomes president; the mechanism will be a back story for wonky places like this listserv.You and Tara may suggest otherwise, but with all due respect, I simply and strongly disagree. It's quite similar  to term limits -- most voters rarely know the mechanism that makes term limits work, but they understand the concept and see it working without typically grasping that the mechanism is based on denying ballot access to term limited incumbents.

 

Poll numbers have been consistently clear that voters quite rationally favor guaranteeing that the winner of the most popular votes in all 50 states becomes president more than guaranteeing that the winner of their state earns that state's electoral votes. It's no surprise: certainly most people on the day after an election would prefer to see their candidate having been president while losing their state than see their candidate losing while winning their state. it's the national outcome that matters to people, and polls from a full range of sources consistently find that a super-majority of Americans think the candidate who wins the most votes in all 50 states should be president. See a great rundown of polls, including some specifically asking the question about whether it matters that the winner has lost one's state, at this URL.

 

As to legal challenges, I can't imagine a judge ordering that the winner-take-all rule must be used. That would fly in the face of recent history -- I sure didn't hear any suggestion in 2008 that a voter in Nebraska could have sued the state for awarding an electoral vote to Obama because he won one of the state's congressional districts. It also flies in the face of the longer arc of history, as the winner-take-all rules isn't remotely established in the Constitution and was not the norm for decades. That rule's origins are far from noble either, as it it is a product of brass-knuckle partisan politics -- e.g., partisans in states wanting to favor the candidate or party expected to win that state by the greatest extent possible, knowing that other states controlled by partisans favoring other candidates/parties were doing the same thing.

 

That progress to the winner-take-all rule with a lot of tinkering underscores another key point that Tara glossed over in her romantic vision of the founders in Philadelphia anticipating politics as we've known it every since. Most of our founders were quite open to fact-based thinking, learning from experience and and adjusting rules to new circumstances -- which is why they established the Electoral College without any instruction to states on what to do, instead punting the decision for states to make rather than impose a certain rule on them. It should be no surprise that, often under the influence of men who were at the constitutional convention, states in the nation's first half-century regularly changed their rules allocating electoral laws -- in 1800, for example, only two states used a winner-take-all rule based on a popular vote in their state. 

 

That 1800 election is also instructive for making it clear that the original rule for the Electoral College -- e.g, electors casting two votes, and the candidate with the most votes (if a majority) becoming president, and the candidate with the second most votes becoming vice-president -- was a failure. So before the 1804 election they changed the Constitution by adopting the 12th amendment, hardly being deferential to what was done in Philadelphia in 1787.

 

When we look at the impact of the winner-take-all rule today, the facts are clear that most Americans and most states are hurt by that rule, but are in bind about how to change it without the National Popular Vote plan-- and I think those facts would have been quite convincing as demanding reform if presented to those in the founding generation transported into our world. Tara again waxes a bit romantically about all states getting their turn as swing states, but she's not looking at the numbers. I'll paste in below a summary of some key facts from a mini-report on "Not Your  Parents' Presidential Elections" we're putting up on the web soon, from our longer Presidential Election Inequality analysis.

 

-Rob

 

Not Your Parents' Presidential Elections

Summary: The number of swing states (generously defined as ones projected to be won by 9% or less in a year in which the major parties candidates split the national popular vote) has dropped sharply since 1988, especially among our nation's largest and smallest states. In 2008, only one of the 13 smallest states and only 4 of the 27 smallest states were swing states. This trend shows no indication of changing, all trends pointing to wider division -- indeed, in 2008 only 3 of the smallest 13 states were within even a 15% partisanship disparity. As the other end of the population spectrum, among our 11 largest population states today, fewer than half were swing states in 2004 and 2008 -- down from 10 out of 11 of these states in the 1960 and the 1976 presidential elections and 8 in the 1988 election.

 

None of the 2008 non-swing states are expected to become swing states in 2012, but some 2008 swing states may well move to non-swing state status, which would continue a 50-year trend presented below.

 

Swing States (within 9%) by # 2008 Electoral Votes (EV's), 1960-2008* (Number of EVs in State) Year >14 9-14 5 to 8 <5 Total 2008 5 6 3 1 15 2004 4 6 5 1 16 1988 8 4 8 6 27 1976 10 6 8 5 29 1960 10 7 8 6 31 Partisanship Disparity (P), All States, 1960-2008 Year P=<9% 9%< P< 20% P>=20% Notes 2008 15 19 17 13 R & 4 D landslide states 2004 16 20 15 10 R & 5 D landslides states 1988 27 22 2 1 R & 1 D landslide states 1976 29 14 8 5 R & 3 D landslides states 1960 31 13 6 2 R & 4 D landslide states * Includes DC in all years except 1960 

 

 

On Thu, Jun 9, 2011 at 9:59 AM, Sean Parnell <sparnell at campaignfreedom.org> wrote:

Others (notably Tara) have far more insight than I on this issue, but I'd just like to offer a few quick reactions to Rob.

 

1.       Rob and I clearly have different views of the lengths politicians will go to in order to achieve favored outcomes. After witnessing the shenanigans in Massachusetts over how to fill empty U.S. Senate seats and watching in '02 how then-former Senator Frank Lautenberg made it onto the ballot after then-Senator Toricelli elected not to run at a very late date, I have little faith that there won't be at least an attempt to game NPV.

2.       Which brings up another point - it doesn't need to be the state legislature the opts out of NPV. A judge could rule the state's decision to enter NPV wasn't proper and strike down the law authorizing it. 'Reformers' routinely claim that our judicial system is corrupt, bought by campaign donors or 'special interests' (witness the smear against Clarence Thomas by Common Cause and ThinkProgress) - now they're going to pledge themselves to the idea that the Texas State Supreme Court isn't going to jump in and decide that Texans voted 2:1 for a Republican, and that's where their electoral votes should go?

3.       I think Rob overstates the degree to which the public cares about and supports NPV. I've no doubt it polls well, as does "good jobs at good wages" legislation and "healthy families in safe communities" legislation. But I doubt that too many people will be aware of or notice if NPV achieves the magic 270-vote level. I'm pretty confident that hardcore partisans almost certainly will notice, however, if late in the campaign cycle they discover that their state is looking to go 3:2 for their candidate but their electoral votes may go the other way and put the candidate they loathe in the White House.

 

Best,

 

Sean Parnell

President

Center for Competitive Politics

http://www.campaignfreedom.org

http://www.twitter.com/seanparnellccp

124 S. West Street, #201

Alexandria, VA  22310

(703) 894-6800 phone

(703) 894-6813 direct

(703) 894-6811 fax

 

From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Rob Richie
Sent: Wednesday, June 08, 2011 7:06 PM


To: law-election at uci.edu
Subject: Re: [EL] National Popular Vote Passes Crucial Milestone

 

These questions provide a good opportunity to plug an excellent resource: Every Vote Equal: A State-Based Plan for Electing the President by National Popular Vote. I'm included as a co-author, but lead author John Koza deserves all the credit.

The book is available online for free at www.everyvoteequal.com <http://www.everyvoteequal.com/> , It's well-organized, with a detailed index and table of contents to help find what you're looking for. Chapter 10 walks through a number of questions about national popular vote, including Mark's one relating to withdrawal.

 

My experience has been that opponents often resort to a "parade of horrors" that essentially amount to throwing a lot of mud in the hope that it sticks. I hasten to say that it's certainly not true that mudslinging is the only way to oppose the National Popular Vote plan -- there are legitimate questions to address. But so often the answer turns out to be that a national popular vote is equal or superior to the status quo -- this relates to concerns about recounts, the impact of third party candidates, the potential impact of voter fraud and much else.

 

It also applies to the issue of withdrawal that Mark has raised. While the blackout provision may well be litigated, NPV proponents have a strong case to make. But let's suppose a worst-cast scenario where it were struck down and courts ruled that a state cannot be bound by the blackout provision. Then let's enter the real world of politics as it is in America and how Sean's theoretical constitutional crisis might unfold. (Speaking of "equal or superior".... I think we all were around in 2000.)

 

First, keep in mind that the National Popular Vote plan's national enactment will not have been a secret. It will have been a huge story, both as it neared adoption and when finally enacted. As a presidential election year unfolds, it's all people will be talking about when discussing the general election. They will quickly shift into a national popular vote state of mind, and discussion of a dozen swing states will be replaced by strategies for getting the most votes nationally, involving all states and their voters. People will be excited about this -- 70% or more think it's the way presidents should be elected, and now it will be happening.

 

But despite this, suppose partisans running a state grow convinced that their party's nominee can't win the national popular vote, but might win under current state-by-state winner-take-all rules. Already you've lost me, frankly, because such a prediction is very hard to make. A lot of people (including me) going into the 2000 election thought that Gore might win the Electoral College while losing the popular vote -- and of course it went the other way. To win the Electoral College, you have to be close in the popular vote. And iif you're close in the popular vote, you of course vave a change to win -- just ask John Kerry, who at 7 pm ET on election night 2004 was expected by many to win the national popular vote and the presidency

 

Despite this unlikely calculation, let's suppose we still have some brazen partisans who have decided this is the way to go. So under the intense spotlight of a presidential race, the governor calls a special session (as would be necessary in nearly all states), and the majority decides to run roughshod over dissenting legislators, break its interstate contract and resort to the old system that has the support of only some 20% to 30% of voters in that state and around the nation.

 

As with the enactment of National Popular Vote plan, this action would not go unnoticed. And I can't imagine a scenario where partisans would actually think this would help them. If they're already bound to lose the national popular vote, such a brazen violation of good sense and popular opinion is going to lose their national standard bearer a lot of votes.

 

Third, this brazen act of self-destructive irrationality only would matter if the state led by these addled partisans happened to have enough electoral votes to undo the compact. But keep in mind that although the compact is triggered by states having at least 270 electoral votes, that number is a lower bound, not an upper one. Given NPV's popularity among voters, there is every reason to think that the compact will ultimately secure far more than 270 electoral votes in its participating states. Every additional elector will make Mark's scenario even more implausible -- and indeed at a certain point unless there was an even more unlikely coordinated exodus of states.

 

Now, contrast this with the status quo. Right now, under current law, a state controlled by one party that might be won in the presidential race the other party could try to change its rules to give their side electoral votes. For instance, Georgia and North Carolina, which were controlled by Democrats at that time, could have gone to the congressional district or proportional allocation system in the fall of 2000. And if either one of them had, Al Gore would have won the presidential race. Indeed in 2004, Colorado voted on a ballot measure to go proportional allocation of electoral votes in that very election.

 

Nothing is stopping states from doing this except the same political factors that would stop them from trying to cheat the National Popular Vote compact -- it would be seen as hyperpartisan and "against fair play." But unlike National Popular Vote, states would not be inhibited by an interstate compact. And furthermore, NPV will likely push states far past 270 electoral votes where no one state could undo it.

 

Every Vote Equal goes into this in far more detail. Check out the answers on potential withdrawal after the election here, for example:

http://nationalpopularvote.com/pages/answers/m9.php

 

Rob Richie

 

 

 

On Wed, Jun 8, 2011 at 5:30 PM, Sean Parnell <sparnell at campaignfreedom.org> wrote:

Mark's critique is an important one, and one that we note in the letter that CCP routinely sends to states considering NPV legislation. I'd also note that given the questions surrounding whether the NPV can truly be binding on a state, it is almost certain that some state will at least attempt to withdraw or look into their ability to withdraw from the NPV should it appear advantageous. I suspect that even an unsuccessful attempt to withdraw would spark a constitutional crisis and significant civic trauma, let alone a successful attempt. 

 

Oh, and for those of you unfamiliar with Tara Ross, she literally wrote the book on preserving the Electoral College Enlightened Democracy: The Case for the Electoral College <http://www.amazon.com/gp/product/B002JING2A?ie=UTF8&tag=colonialpress-20&linkCode=as2&camp=1789&creative=390957&creativeASIN=B002JING2A> , and I'm thrilled she's joined us here.

 

Sean Parnell

President

Center for Competitive Politics

http://www.campaignfreedom.org <http://www.campaignfreedom.org/> 

http://www.twitter.com/seanparnellccp

124 S. West Street, #201

Alexandria, VA  22310

(703) 894-6800 phone

(703) 894-6813 direct

(703) 894-6811 fax

 

From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Scarberry, Mark
Sent: Wednesday, June 08, 2011 5:03 PM
To: law-election at uci.edu


Subject: Re: [EL] National Popular Vote Passes Crucial Milestone

 

We can argue about whether it is a good idea in effect to scrap the electoral college. We can argue about the partisan political effects of doing so. We can certainly argue about whether such a sub rosa attempt to amend the Constitution without using Article V is a breach of constitutional principles (and thus should be rejected whether or not adoption or enforcement of the NPV compact would raise justiciable issues)

 

But it's important not to lose sight of the question whether such a compact could be binding. Under Article II, state legislatures have plenary power to allocate electoral votes on whatever basis they may choose (subject to the 14th, 15th, 19th etc. Amendments), including, I suppose the basis of the national popular vote. The NPV compact proponents in fact rely on that plenary power and even say that state legislatures cannot be limited in their exercise of it "at any time." See http://www.nationalpopularvote.com/pages/explanation.php ("3- Sentence Description" of NPV Compact) ["Under the U.S. Constitution, the states have exclusive and plenary (complete) power to allocate their electoral votes, and may change their state laws concerning the awarding of their electoral votes at any time."] 

 

But of course there is a strong argument that the NPV compact itself violates that constitutional rule, by purporting to bind states to the NPV method of allocating electoral votes during a six-month blackout period beginning on July 20 of each presidential election year. It is not at all clear that state legislatures can deprive themselves for such a period of the Article II power to decide how to allocate electors.* If the blackout provision is not binding, then each state's legislature would be free to game the NPV system, by backing out at the last minute if it thinks the national popular vote is going to go against the candidate that voters in the state seem to prefer (or that the state legislature prefers). The blackout period seems to be an essential element of the NPV proposal precisely in order to prevent such gaming of the system. 

 

As the proponents say:

 

"The purpose for the delay in the effective date of a withdrawal is to ensure that a withdrawal will not be undertaken-perhaps for partisan political purposes-in the midst of a presidential campaign or in the period between the popular voting in early November and the meeting of the Electoral College in mid-December." See http://www.nationalpopularvote.com/resources/EVE-CH-6-Ed1-Pr4.pdf (at page 266)."

 

Would NPV compact proponents still be in favor the compact without the blackout provision?

 

Mark Scarberry

 

Mark S. Scarberry

Pepperdine Univ. School of Law

Malibu, CA 90263

(310)506-4667

 

*Congress seemingly has provided that the method of selecting electors cannot be changed after the date on which electors are chosen. Article II, sec. 1, cl. 4 gives Congress the power to force states to choose their electors by a date set by Congress, and thus state legislatures could not effectively change their method of selection of electors for that election after that date (election day: the first Tuesday after the first Monday in November). State legislatures are not otherwise limited (except that Congress has only committed to following the state's procedures for determining disputes about which electors have been chosen if those procedures were adopted before the date set by Congress for selection of electors and only if, remember Bush v. Gore, the state's processes have been completed at least six days before the date set by Congress for electors to meet and cast their votes - the first Monday after the second Wednesday in December. See 3 U.S.C. sections 1, 5, and 7 (conveniently available at http://www.archives.gov/federal-register/electoral-college/provisions.html#law). But the NPV compact would purport to prevent changes as of July 20.

 

From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Tara Ross
Sent: Wednesday, June 08, 2011 11:23 AM
To: Jamin Raskin; rhasen at law.uci.edu; law-election at uci.edu
Subject: Re: [EL] National Popular Vote Passes Crucial Milestone

 

I am new to this listserv and should introduce myself.  My name is Tara Ross, and I've spent much time defending and writing about the Electoral College (as some on this list know). Jamie will not be surprised to find that I disagree with his conclusion from this morning.

 

He correctly notes that Republicans in a few parts of the country (especially New York and California) have decided to support NPV. But these Republicans are misguided if they believe NPV will help either their party or their country. We should not be celebrating New York's vote yesterday.

 

In recent months, NPV advocates have been working hard to obtain support from Republicans and conservatives. Their latest sales pitch is that NPV is good for Republicans because it will eliminate the focus on swing states and enable more conservative voices across the nation to be heard. (A nation that leans center-right should be electing a center-right president, right?) I don't blame NPV for trying to cater to conservatives, given the outcome of last November's elections; however, I do wonder why more Republicans don't question the validity of this logic. Support for NPV has been disproportionately Democratic in the past. Why would so many Democrats sponsor something with the alleged purpose of electing more Republican presidents?

 

In my opinion, these Republicans are being pretty naïve to assume that their party will benefit the most if NPV is implemented. The Democratic Party is likely to gain the most in the short term: Elimination of the Electoral College will create a new focus on urban centers-currently a Democratic strength. In the long term, however, I doubt that anyone can predict which party will benefit the most from this radical change to our election process. NPV advocates tend to assume that they can change the presidential election procedure but that virtually everything else in our political universe will remain unchanged. What a dangerous assumption. Arguably, everything from campaign strategies to the strength of our two-party system will be impacted. 

 

Even if we could predict which party would benefit the most, it is wrong to eliminate the Electoral College based purely on temporary, partisan gain. I suppose some will say I am being too idealistic to think that politicians should act in a non-political manner. But these officials would serve their constituents best if they remembered that the founding generation deliberately created constitutional safeguards such as the Electoral College so that freedom might be protected over the course of decades. Surely the Founders would be horrified at the partisan logic that is sometimes used to support NPV. 

 

With the current system in place, presidential candidates can't succeed without winning concurrent victories across the nation from many states. The system has built-in incentives, ensuring that candidates reach out to a variety of voters from many regions and states. Such a system is good for the health of a country as large and diverse as our own, whether you are Republican or Democrat. Republicans in New York should have remembered that before hastily casting aside an institution that has served us so well for so long.

 

 

 

From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Jamin Raskin
Sent: Wednesday, June 08, 2011 10:08 AM
To: rhasen at law.uci.edu; law-election at uci.edu
Subject: [EL] National Popular Vote Passes Crucial Milestone

 

Yesterday, the National Popular Vote legislation passed in two state legislative chambers.

In New York, the Republican-controlled State Senate voted 49-10 to approve the interstate agreement, making it the first GOP-controlled chamber in the country to do so. Senate Republicans voted 23-8 (with 1 excused), and Democrats voted 26-2 (with 2 excused). Republican Senators who had been cross-endorsed by the Conservative Party voted 17-7 in favor of the bill.

This is an important political breakthrough for the National Popular Vote.

  The Delaware House also passed the NPV legislation yesterday.
 
States that have passed the NPV legislation have assembled 29% of the electoral college votes needed to bring the agreement into effect.
 


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Executive Director

FairVote   
6930 Carroll Avenue, Suite 610
Takoma Park, MD 20912
www.fairvote.org  <http://www.fairvote.org/>  rr at fairvote.org
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Please support FairVote through action and tax-deductible donations -- see http://fairvote.org/donate. For federal employees, please consider  a gift to us through the Combined Federal Campaign (FairVote's  CFC number is 10132.) Thank you!




-- 
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Respect for Every Vote and Every Voice" 

Rob Richie
Executive Director

FairVote   
6930 Carroll Avenue, Suite 610
Takoma Park, MD 20912
www.fairvote.org  <http://www.fairvote.org>  rr at fairvote.org
(301) 270-4616

Please support FairVote through action and tax-deductible donations -- see http://fairvote.org/donate. For federal employees, please consider  a gift to us through the Combined Federal Campaign (FairVote's  CFC number is 10132.) Thank you!




-- 
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Respect for Every Vote and Every Voice" 

Rob Richie
Executive Director

FairVote   
6930 Carroll Avenue, Suite 610
Takoma Park, MD 20912
www.fairvote.org  <http://www.fairvote.org>  rr at fairvote.org
(301) 270-4616

Please support FairVote through action and tax-deductible donations -- see http://fairvote.org/donate. For federal employees, please consider  a gift to us through the Combined Federal Campaign (FairVote's  CFC number is 10132.) Thank you!

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