[EL] ELB News and Commentary 6/15/11
Steve Hoersting
hoersting at gmail.com
Wed Jun 15 05:16:50 PDT 2011
The Guest Blogger feature is a good one. It allows us to debate more
perspectives in addition to reading good new pieces and academic articles.
For those intrigued by Mr. Brudney's take on the Boeing affair, and his
concern for Senators weighing-in on NLRB's treatment of Boeing, I recommend
reading, at a minimum, this op-ed by George Will.
http://www.jewishworldreview.com/cols/will051511.php3
Mr. Will addressed Mr. Brudney's concerns, one month early, when he wrote
that, "The NLRB's complaint is not a conscientious administration of the
law; it is intimidation of business leaders who contemplate locating [not
relocating, it is worth noting] operations in right-to-work states."
Killing right-to-work is rightly and fairly a concern for U.S. Senators,
whose role is to speak the interests of states in a federal system.
"My concern here is not with the merits of the complaint but with the threat
to basic fairness."
Steve Hoersting
On Wed, Jun 15, 2011 at 12:33 AM, Rick Hasen <rhasen at law.uci.edu> wrote:
> <http://electionlawblog.org/>
> (State Supreme Court) Elections Have Consequences<http://electionlawblog.org/?p=19192>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19192> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> Collective Bargaining Law Upheld in Wisconsin<http://www.nytimes.com/2011/06/15/us/politics/15wisconsin.html?hp>:
> “Justice David T. Prosser, whose re-election bid was threatened this year
> because he was seen as a conservative who would cast the deciding vote on
> the collective bargaining measure if it came before the court, voted to
> overturn the lower court ruling. He issued his own opinion concurring with
> the majority.”
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19192&title=%28State%20Supreme%20Court%29%20Elections%20Have%20Consequences&description=>
> Posted in judicial elections <http://electionlawblog.org/?cat=19> | Comments
> Off
> “2012 Cook Political Report Redistricting Outlook”<http://electionlawblog.org/?p=19187>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19187> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> Updated <http://www.cookpolitical.com/node/10516>!
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19187&title=%E2%80%9C2012%20Cook%20Political%20Report%20Redistricting%20Outlook%E2%80%9D&description=>
> Posted in redistricting <http://electionlawblog.org/?cat=6> | Comments
> Off
> “UC Irvine School of Law Granted Provisional Accreditation by American
> Bar Association” <http://electionlawblog.org/?p=19183>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19183> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> See this press release<http://www.law.uci.edu/press_releases/06-14-11.html>
> .
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19183&title=%E2%80%9CUC%20Irvine%20School%20of%20Law%20Granted%20Provisional%20Accreditation%20by%20American%20Bar%20Association%E2%80%9D&description=>
> Posted in Uncategorized <http://electionlawblog.org/?cat=1> | Comments
> Off
> “Senior White House aide joins airline lobby”<http://electionlawblog.org/?p=19180>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19180> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> *WaPo* reports<http://www.washingtonpost.com/blogs/44/post/senior-white-house-aide-joins-airline-lobby/2011/06/14/AGMqYzUH_blog.html>.
> What about the Obama Administration anti-revolving door rules? “Under Obama
> administration ethics guidelines, Kennedy is forbidden from lobbying the
> executive branch on issues that he handled while in government for two
> years; however, those restrictions do not apply to Congress.”
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19180&title=%E2%80%9CSenior%20White%20House%20aide%20joins%20airline%20lobby%E2%80%9D&description=>
> Posted in Uncategorized <http://electionlawblog.org/?cat=1> | Comments
> Off
> “Why power isn’t speech: Nevada Commission on Ethics v. Carrigan and the
> unraveling of campaign finance doctrine”<http://electionlawblog.org/?p=19177>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19177> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> A must-read post<http://balkin.blogspot.com/2011/06/why-power-isnt-speech-nevada-commission.html>from Deborah Hellman at Balkinization.
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19177&title=%E2%80%9CWhy%20power%20isn%E2%80%99t%20speech%3A%20Nevada%20Commission%20on%20Ethics%20v.%20Carrigan%20and%20the%20unraveling%20of%20campaign%20finance%20doctrine%E2%80%9D&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>, conflict
> of interest laws <http://electionlawblog.org/?cat=20> | Comments Off
> “The Gift Tax and Contributions to Section 501(c)(4) Organizations: Less
> than Meets the Eye?” <http://electionlawblog.org/?p=19175>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19175> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> An Exempt Organization Alert<http://campaign.r20.constantcontact.com/render?llr=ve8eljbab&v=001AbyoPARFHBPBy8QEYcFvIv4d2W7-O4OvxvM0LiG3FobaJb3mzpjZ1mOS3BsJAsn9RAU7YMUUmB_5ybKnP8v2r1PEkcO8QMPGaoYS_IuogyX70IdRihbKgIs0WBqM6WMl>from Caplin & Drysdale.
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19175&title=%E2%80%9CThe%20Gift%20Tax%20and%20Contributions%20to%20Section%20501%28c%29%284%29%20Organizations%3A%20Less%20than%20Meets%20the%20Eye%3F%E2%80%9D&description=>
> Posted in tax law and election law <http://electionlawblog.org/?cat=22>
> | Comments Off
> “Wave of Super PACS File with the FEC”<http://electionlawblog.org/?p=19172>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19172> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> *Roll Call* reports<http://www.rollcall.com/news/Wave-of-Super-PACs-File-With-FEC-206452-1.html>
> .
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19172&title=%E2%80%9CWave%20of%20Super%20PACS%20File%20with%20the%20FEC%E2%80%9D&description=>
> Posted in Uncategorized <http://electionlawblog.org/?cat=1> | Comments
> Off
> Krishnakumar: More Than Meets the Eye in Justice Scalia’s Sykes Dissent?<http://electionlawblog.org/?p=19167>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19167> by Guest
> Blogger <http://electionlawblog.org/?author=9>
>
> The following is a guest post from Anita Krishankumar<http://new.stjohns.edu/academics/graduate/law/faculty/profiles/Krishnakumar>
> :
>
> Justice Scalia’s dissenting opinion in *Sykes v. United States*<http://www.supremecourt.gov/opinions/10pdf/09-11311.pdf>issued last Thursday, has quickly received a fair amount of buzz in the
> blogosphere. The buzz is understandable—the *Sykes* dissent is a Scalia
> classic: pithy, full of colorful phrases, and entertainingly blunt. But
> there is more to the opinion than just a few memorable Congress-bashing
> quotes. Indeed, there seem to me to be at least two related statutory
> interpretation techniques, or methodological biases, at work in Justice
> Scalia’s dissent. The first is an intolerance for imprecise statutory
> constructions that leave courts to engage in messy, case-by-case
> applications of a statute down the line. The second is a limited,
> black-and-white view of the reasons why Congress might end up enacting a
> statute that calls for just such messy, case-by-case judicial judgments in
> the implementation of a given statute.
>
> I have argued elsewhere<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1800082>that the Supreme Court sometimes employs an “anti-messiness” principle in
> interpreting statutes—meaning that it deliberately rejects statutory
> constructions that require case-by-case factual inquiries or judicial
> judgments that will prove “messy”/complicated/confusing for implementing
> courts to administer. Justice Scalia is a strong proponent of this
> interpretive principle and his *Sykes* dissent very much reflects his
> commitment to such messiness avoidance. For example, his dissent criticizes
> the majority opinion on the grounds that “instead of producing a
> clarification of the Delphic residual clause, [it] produces a fourth ad hoc
> judgment that will sow further confusion.” In a bit of an I-told-you-so
> moment, his dissent also points to his opinion in *James v. United States<http://www.supremecourt.gov/opinions/06pdf/05-9264.pdf>
> *, an earlier case interpreting the ACCA’s residual clause, which warned
> that the Court’s interpretation “permit[ted] an unintelligible criminal
> statute to survive uncorrected, unguided, and unexplained.” The intervening
> years, Justice Scalia’s *Sykes *dissent scolds, have proved that warning
> correct. In Justice Scalia’s view, one of the Supreme Court’s roles as
> statutory interpreter is to give statutes a clear, predictable meaning that
> can be implemented almost automatically, without the need for further
> judicial line-drawing or clarification. If such line-drawing or
> clarification become necessary, then the Court’s initial interpretation was
> by definition inadequate. Hence his admonition in *Sykes* that “Four
> times is enough” and his sarcastic observation that “We try to include an
> ACCA residual-clause case in about every second or third volume of the
> United States Reports.”
>
> Justice Scalia’s *Sykes *dissent also criticizes the Court, in terms
> reminiscent of formalist Judge Keen in the Legal Process classic theSpeluncean Explorers<http://www.nullapoena.de/stud/explorers.htm>,
> for teaching Congress bad habits by tolerating such hopelessly imprecise
> statutes. “[O]ur indulgence of imprecisions that violate the Constitution
> encourages imprecisions that violate the Constitution,” he complains. But
> it is worth noting that Justice Scalia’s fair-notice-based constitutional
> argument is weak in cases involving sentencing provisions, as opposed to
> cases involving the definition or elements of a criminal offense. There is
> no uncertainty as to the illegality of the defendant’s conduct in ACCA
> residual clause cases; what is at issue is the application of a sentencing
> enhancement to the defendant’s punishment. The fair notice argument carries
> significantly less weight in this context than in the context of determining
> what underlying conduct is prohibited.
>
> Notably, Justice Scalia saves his sharpest criticism for Congress itself,
> and this part of his *Sykes* dissent has garnered most of the attention in
> the blogosphere. “Fuzzy, leave-the-details-to-be-sorted-out-by-the-courts
> legislation,” Justice Scalia accuses, “is attractive to the Congressman who
> wants credit for addressing a national problem but does not have the time
> (or perhaps the votes) to grapple with the nitty-gritty.” This harangue
> against Congress seems to assume that the ACCA’s residual clause
> intentionally was left vague by a Congress that was shirking its duty. The
> problem with this argument is not that Congress never behaves in this
> fashion; it surely does in some cases. But Justice Scalia’s dissent paints
> with a broad brush stroke and ignores the very real possibility that
> Congress may have had other, less objectionable, reasons for not providing
> an exhaustive list of the crimes that count for purposes of the ACCA’s
> residual clause. Perhaps given the large universe of state crimes that
> present a “serious potential risk of physical injury to another,” Congress
> was loath to provide a lengthy list within the statute—on the theory that
> its list almost certainly would leave out some crimes that should be
> included and that those crimes then would be automatically *excluded*under an
> *expressio unius* argument. Or perhaps Congress genuinely failed to
> anticipate the confusion that the ACCA’s residual clause would cause for
> implementing courts. Alternatively, Congress may have made a judgment that
> courts, which are experienced in evaluating the elements of a crime, are
> better suited to drawing fine distinctions between specific offenses than is
> the legislature and may accordingly have left the sorting out of such crimes
> to judges in the implementation stage. It also is possible that Congress,
> unlike Justice Scalia, has agreed with—or at least had no significant
> problems with—the manner in which the Court has applied the residual clause
> thus far; that is, perhaps Congress is satisfied with the Court’s ad-hoc
> judgments in *James*, *Begay<http://www.supremecourt.gov/opinions/07pdf/06-11543.pdf>
> *, and *Chambers <http://www.supremecourt.gov/opinions/08pdf/06-11206.pdf>
> *and has chosen to spend its resources legislating on other matters that
> it deems more pressing.
>
> Justice Scalia seems to dismiss such possibilities with a glib flip of the
> hand, claiming that “Congress can quickly add what it wishes” to the
> statute. But as Justice Scalia undoubtedly is aware, few things happen
> quickly or easily in Congress. His *Sykes* dissent thus presents an
> interesting take on the Court-Congress dialogue: He seems to be advocating
> that the Court should reject statutory language that requires messy,
> case-by-case judicial implementation and should seek—through a “void for
> vagueness” ruling—to force Congress to rework statutes that produce undue
> messiness in the application (“undue” as defined by Justice Scalia, since no
> other Justice joined his dissent)—and that it should do so irrespective of
> how satisfied Congress itself might be with the judiciary’s current
> implementation of such statutes.
>
> Anita Krishnakumar
>
> St. John’s University School of Law
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19167&title=Krishnakumar%3A%20More%20Than%20Meets%20the%20Eye%20in%20Justice%20Scalia%E2%80%99s%20Sykes%20Dissent%3F&description=>
> Posted in statutory interpretation <http://electionlawblog.org/?cat=21>
> | Comments Off
> “Lori Sturdevant: Bill Moyers on ranked voting”<http://electionlawblog.org/?p=19164>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19164> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> See here <http://www.startribune.com/opinion/123825984.html>.
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19164&title=%E2%80%9CLori%20Sturdevant%3A%20Bill%20Moyers%20on%20ranked%20voting%E2%80%9D&description=>
> Posted in Uncategorized <http://electionlawblog.org/?cat=1> | Comments
> Off
> “Redistricting’s Bottom Line Might Surprise You”<http://electionlawblog.org/?p=19161>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19161> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> Stuart Rothenberg has written this *Roll Call* column<http://www.rollcall.com/issues/56_138/Redistricting-Bottom-Line-Might-Surprise-You-206422-1.html>
> .
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19161&title=%E2%80%9CRedistricting%E2%80%99s%20Bottom%20Line%20Might%20Surprise%20You%E2%80%9D&description=>
> Posted in Uncategorized <http://electionlawblog.org/?cat=1> | Comments
> Off
> Brudney: The Boeing Complaint in Congress: Oversight or Overreach?<http://electionlawblog.org/?p=19157>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19157> by Guest
> Blogger <http://electionlawblog.org/?author=9>
>
> The following is a guest post from Jim Brudney<http://moritzlaw.osu.edu/faculty/bios.php?ID=8>
> .
>
> Today, an Administrative Law Judge begins hearing argument and evidence in
> a complaint brought against the Boeing Company under the National Labor
> Relations Act. The complaint was filed less than two months ago, and the
> trial process is just starting. Yet, I cannot recall any case that has
> attracted such intense and sustained congressional attention at such an
> early stage.
>
> Ten Republican senators wrote to the Board’s acting General Counsel, Lafe
> Solomon, suggesting that his confirmation prospects would be linked to his
> position on the Boeing case. Nineteen Republican senators wrote to President
> Obama urging him to withdraw immediately Solomon’s nomination because of the
> Boeing complaint. Thirty-five Republican senators have cosponsored a bill to
> block the Boeing case by amending the law to immunize Boeing’s allegedly
> unlawful conduct. Last week, a Republican senator submitted a Freedom of
> Information Act request that Solomon turn over all documents (including
> email, call logs, memoranda, or meeting notes) generated by Labor Board
> members or staff that were used to support the filing of the Boeing
> complaint.
>
> In the House, two separate committees demanded that Solomon produce all
> internal agency documents addressing the Boeing complaint and all documents
> referring or relating in any way to the agency’s investigation of Boeing—and
> do so in advance of the June 14 hearing. Solomon declined these document
> requests. He cited the confidential nature of affidavit testimony obtained
> from possible witnesses and the threat to a fair litigation process if
> strategic litigation plans were disclosed before trial. One committee
> chairman expressed extreme disappointment and promised to discuss the
> request further with Solomon. The other chairman requested that Solomon
> testify at an oversight hearing three days after the ALJ trial commences,
> and effectively compelled him to testify by threatening him with a subpoena.
> Solomon is scheduled to appear “voluntarily” this Friday before Congress as
> the trial process unfolds without him
>
> Why all the fuss?
>
> The complaint alleges that Boeing unlawfully established a second assembly
> line of aircraft production at a nonunion plant in South Carolina in
> retaliation against union workers at its main Seattle plant who had engaged
> in lawful strikes during prior collective bargaining negotiations. Boeing
> denies the allegations. It argues that its decision was motivated by lawful
> considerations of economic cost, not unlawful anti-union animus. A major
> source of concern among Republican members of Congress is part of the
> requested remedy: if the company’s movement of work is deemed unlawful, the
> government seeks an order that Boeing’s second line be produced in Seattle
> and not South Carolina.
>
> The complaint invokes five separate statements made by top Boeing
> executives and managers, suggesting that a desire to avoid lawful union
> activity may well have played a part in Boeing’s decision. Whether it was
> the motivating factor is what the trial and subsequent appeals are there to
> resolve. It will be up to the ALJ to assess the allegations and defenses, to
> consider the nature of the relief sought, and to decide the case on its
> merits. That is how our system of due process works for adjudications—or at
> least how it should work.
>
> My concern here is not with the merits of the complaint but with the threat
> to basic fairness resulting from the avalanche of congressional pressure.
>
> Congress has an important constitutional role to investigate executive
> branch activities and conduct. This broad oversight power is more limited,
> however, when Congress investigates a pending adjudicatory proceeding. Such
> a proceeding resembles a court action. When agencies conduct adjudications,
> they are acting similarly to federal prosecutors and judges.
>
> Federal appellate courts have expressed concern over congressional pressure
> focused intensely and extensively on the decisional processes of key agency
> officials in a case that is pending before the agency. A leading Fifth
> Circuit decision invalidated an agency adjudication, holding that
> congressional interrogation impermissibly tainted the agency’s decisional
> process.
>
> More broadly, a central premise of the Administrative Procedure Act is that
> agency adjudicatory decisions be made exclusively on the record presented to
> the judge, and that the decision be based entirely on factors specified by
> the governing statute—in this case the NLRA.
>
> Congress’s own ethics rules reiterate these abiding principles. The House
> Ethics Manual recognizes there are judicial opinions that discourage
> “inordinate pressure” on officials charged with responsibility for making
> agency decisions. It emphasizes that “a Member should *not *directly or
> indirectly threaten reprisal” against an agency official.
>
> In the Boeing case, Congress has engaged in a relentless month-long series
> of public and often high-profile attacks, directed at the acting General
> Counsel for prosecuting the complaint. Congress needs to take a step back.
> The adjudicative process will ultimately yield a decision after the facts
> have been presented, arguments heard, remedial options reviewed, and appeals
> exhausted. Congress will be able to alter the law going forward if it
> disagrees with the decision reached. That is the appropriate way for
> legislators to take issue with an adjudicative result—as Congress has often
> done in the past.
>
> I hope that the interrogations and threats do not ultimately intimidate
> acting General Counsel Solomon, who is not a politician but a career civil
> servant. But there is reason to fear that Congress’s ongoing course of
> conduct may undermine neutral analysis and chill independent judgment by any
> reasonably attentive ALJ hearing this case.
>
> Ironically, if the case ends up being decided in Boeing’s favor, a
> reviewing court might well overturn the result. A judge could infer that
> the agency decided against the government’s position in response not to the
> facts or legal arguments, but rather to the browbeating from both House and
> Senate Republicans.
>
> For members of Congress, as for all Americans, maintaining the integrity of
> the government’s decision-making process should matter no less than the
> outcome of any particular case.
>
> James J. Brudney
>
> Newton D. Baker-Baker & Hostetler Chair in Law
>
> The Ohio State University Moritz College of Law
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19157&title=Brudney%3A%20The%20Boeing%20Complaint%20in%20Congress%3A%20%20Oversight%20or%20Overreach%3F&description=>
> Posted in Uncategorized <http://electionlawblog.org/?cat=1> | Comments
> Off
> “Newt Gingrich Charity Paid Cash To Gingrich For-Profit Business”<http://electionlawblog.org/?p=19152>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19152> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> ABC News offers this must-read report<http://abcnews.go.com/Blotter/newt-gingrich-charity-paid-cash-gingrich-profit-business/story?id=13804431>
> .
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19152&title=%E2%80%9CNewt%20Gingrich%20Charity%20Paid%20Cash%20To%20Gingrich%20For-Profit%20Business%E2%80%9D&description=>
> Posted in tax law and election law <http://electionlawblog.org/?cat=22>
> | Comments Off
> “Judgeship Push May Head to Court” <http://electionlawblog.org/?p=19149>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19149> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> See this report<http://www.houmatoday.com/article/20110612/ARTICLES/110619902>from Houma, Louisiana.
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19149&title=%E2%80%9CJudgeship%20Push%20May%20Head%20to%20Court%E2%80%9D&description=>
> Posted in judicial elections <http://electionlawblog.org/?cat=19> | Comments
> Off
> “High Court Upholds Nevada’s Ethic’s Law”<http://electionlawblog.org/?p=19144>
> Posted on June 14, 2011 <http://electionlawblog.org/?p=19144> by Rick
> Hasen <http://electionlawblog.org/?author=3>
>
> This report
> <http://www.npr.org/2011/06/14/137168490/high-court-upholds-nevada-ethics-law>appears
> on NPR’s Morning Edition. MORE: Mike Dorf writes<http://www.dorfonlaw.org/2011/06/campaign-finance-issue-lurking-in.html>“The Campaign Finance Issue Lurking in Nevada Comm’n on Ethics v. Carrigan.”
> [image: Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D19144&title=%E2%80%9CHigh%20Court%20Upholds%20Nevada%E2%80%99s%20Ethic%E2%80%99s%20Law%E2%80%9D&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>, conflict
> of interest laws <http://electionlawblog.org/?cat=20>, Uncategorized<http://electionlawblog.org/?cat=1>
> | Comments Off
> --
> Rick Hasen
> Visiting Professor
> UC Irvine School of Law
> 401 E. Peltason Dr., Suite 1000
> Irvine, CA 92697-8000
> 949.824.3072 - office
> 949.824.0495 - fax
> rhasen at law.uci.edu
> http://law.uci.edu/faculty/page1_r_hasen.html
>
> William H. Hannon Distinguished Professor of Law
> Loyola Law School
> http://www.lls.edu/academics/faculty/hasen.html
> http://electionlawblog.org
>
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>
--
Steve Hoersting
CENTER FOR COMPETITIVE POLITICS
124 West Street South
Suite 201
Alexandria, Virginia 22314
SHoersting at campaignfreedom.org
www.campaignfreedom.org
(703) 894-6800 phone
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