[EL] Treating expenditures as campaign contributions (Re: ELB News and Commentary 11/8/11
David A. Holtzman
David at HoltzmanLaw.com
Mon Nov 14 01:00:42 PST 2011
One problem with treating any expenditures "as contributions rather than
expenditures" (424 U.S. 1, 46) is that unlike ordinary monetary
contributions, a candidate can't be forced to return them if they exceed
a dollar-amount threshold.You can't unspend.You can't unbroadcast a
commercial, retract impressions from ears or eyeballs, or depublish
anything other than a court opinion.
This whole area of law has an "Alice in Wonderland" feel.(You can't
limit spending, but if you don't call it spending then you can.)
Even if a candidate (or agent or committee of the candidate) does not
provide "cooperation" or "consent" for (or "request" or "authorize") an
expenditure, she's in all likelihood going to find out about the
expenditure, and presumably feel grateful, and thereby be influenced.If
excessive candidate gratitude is a problem, then all excessive spending
that helps a candidate is a problem.To stop it, I think it would be most
effective - and more fair to candidates - to focus on the spenders
rather than the candidates.
Nevertheless, if someone else's spending should sometimes and only
sometimes expose a candidate to legal jeopardy, why isn't the legal test
for charging the spending to a candidate simply whether she knows about
the expenditure in advance and does not protest (or disclaim) right away
and publicly? There could be a standard mechanism for such protest;
maybe electronic filing.Then commentators could go on and on about how
'the woman doth protest too much.'
-dah
p.s. I've contributed a lot of my time to political campaigns ... or did
I "spend" that time?Either way, I really wish I would have gotten
monetized credit for it on official reports. Time has value.(Right,
lawyers?I trust none of you has ever discounted your rate for a candidate.)
p.p.s. And speaking of content standards, I hope I can still make a
major donation to the Juvenile Geriatric Foundation in honor of last
year's dinner speaker, Martha Klein, and tweet/blog/crow about it in the
feel-good radio ads for my business (that's not express advocacy,
right?), even when Martha's on the ballot, and even if she's on the
foundation board and voted to accept the donation.
On 11/10/2011 11:21 AM, Smith, Brad wrote:
>
> True, the court does not suggest that contributions are limited to
> "express advocacy," but it does define "expenditures" as limited to
> express advocacy, and expenditures by someone other than a candidate
> are not expenditures by the candidate.
>
> Beyond that, I won't go back into all these arguments here. The point
> I was making is that many regulatory advocates seem unable to
> recognize that there is an argument for content standards in the
> context of coordination. Paul here does recognize that, and puts forth
> a counterargument (which I think is wrong, but we'll not rehash that).
> But too often -- as in Trevor's earlier post or Colbert's TV bits -
> that argument, and the reasons behind it, are either ignored or not
> recognized at all, the implication being that therefore the law is
> ridiculous. But it's not ridiculous if you grasp what is really going on.
>
> Here, the small picture is that not all coordinated speech is
> regulated under the FECA (Senator McConnell and I have a "Cardinal
> blast" party for close friends in my back yard to watch the Louisville
> Cards football game -- I print up a banner saying "Go Cards!" -- is my
> expenditure regulated by FECA?; The Brennan Center for Justice has an
> event at which Senator McCain is the honoreer; the Brennan Center
> spends a sizeable sum on the event; is that expenditure regulated by
> FECA because it was "coordinated" with Senator McCain?; The Sierra
> Club meets with Senator Reid to discuss strategy for passing
> environmental regulation, then, at Senator Reid's suggestion, runs
> television ads highlighting the legislation; is that regulated by FECA
> because it was coordinated with Senator Reid?), and bright line
> context tests serve the same purposes in avoiding vagueness that is
> served in the context of independent expenditures. Indeed, because
> coordinated "expenditures" are treated as "contributions," the content
> issue is even more important.
>
> The bigger picture is that the Court often adopts rules or standards
> that allow regulation of only a narrow category of speech or permit
> regulation only in narrow circumstances. It recognizes that this will
> lead to relatively little enforcement. That does not mean that the
> rules are silly. It means that they are intended to serve a purpose
> other than promoting enforcement to the extent that some would like.
>
> /Bradley A. Smith/
>
> /Josiah H. Blackmore II/Shirley M. Nault /
>
> / Designated Professor of Law/
>
> /Capital University Law School/
>
> /303 East Broad Street/
>
> /Columbus, OH 43215/
>
> /(614) 236-6317/
>
> /bsmith at law.capital.edu <mailto:bsmith at law.capital.edu>/
>
> /http://www.law.capital.edu/faculty/bios/bsmith.asp/
>
> *From:*Paul Ryan [mailto:PRyan at campaignlegalcenter.org]
> *Sent:* Thursday, November 10, 2011 12:12 PM
> *To:* Steve Hoersting; Trevor Potter
> *Cc:* law-election at uci.edu; Smith, Brad
> *Subject:* RE: [EL] ELB News and Commentary 11/8/11
>
> I agree with Steve that an appeal to /Buckley/ is well placed---but
> for a very different reason and outcome. Far from Steve's claim that
> /Buckley/ said the term "expenditure" must be limited to "express
> advocacy" when it comes to expenditures coordinated with candidates,
> /Buckley/ stands for the opposite proposition.
>
> The /Buckley /Court recognized the importance of candidate
> contribution limits to preventing corruption and made clear that
> "expenditures controlled by or coordinated with the candidate and his
> campaign might well have virtually the same value to the candidate as
> a contribution and would pose similar dangers of abuse." 424 U.S. 1,
> 46. For this reason, "such controlled or coordinated expenditures are
> _treated as contributions rather than expenditures_ under the Act."
> /Id./ (emphasis added). The Court explained that FECA's contribution
> limits, rather than the independent expenditure limit invalidated by
> the Court, "prevent attempts to circumvent the Act through prearranged
> or coordinated expenditures amounting to disguised contributions."
> /Id./ at 46-47.
>
> /Buckley/firmly established that "expenditures controlled by or
> coordinated with candidates" must be treated as contributions, in
> order to prevent circumvention of the candidate contribution limits.
> And nowhere does /Buckley/ suggest that the definition of
> "contribution" should be limited to "express advocacy."
>
> And further, with respect to "expenditures" by candidates and
> political committees (construed as groups under the control of
> candidates or with the major purpose of nominating or electing
> candidates), the /Buckley /Court explicitly held that FECA's "for the
> purpose of influencing" definition of "expenditure" is wholly
> permissible because "expenditures" by candidates and political
> committees "fall within the core area sought to be addressed by
> Congress" and "are, by definition, campaign related." /Id. /at 78-79.
>
> The "express advocacy" standard was only employed by the /Buckley/
> Court in the context of "independent expenditures" by non-"major
> purpose" groups, /id. /at 43-44, 79-80, and has no application with
> respect to coordinated expenditures, generally, or to any expenditures
> by "political committees" like American Crossroads and the Colbert
> Super PAC.
>
> Paul Seamus Ryan
>
> FEC Program Director & Associate Legal Counsel
>
> The Campaign Legal Center
>
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>
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>
> Ph. (202) 736-2200 ext. 14
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> *From:*law-election-bounces at department-lists.uci.edu
> [mailto:law-election-bounces at department-lists.uci.edu] *On Behalf Of
> *Steve Hoersting
> *Sent:* Thursday, November 10, 2011 7:34 AM
> *To:* Trevor Potter
> *Cc:* law-election at uci.edu; Smith, Brad
> *Subject:* Re: [EL] ELB News and Commentary 11/8/11
>
> No, Trevor, the appeal to /Buckley/ is well placed. Coordinated
> /expenditures/ are treated as contributions under the Act (and, these
> days, coordinated "electioneering communications").
>
> But what did the /Buckley/ Court say about the scope of "expenditure,"
> and the vagueness of its critical phrase, "made for the purpose of
> influencing an election"? That's right: "Expenditure" must be limited
> to express advocacy.
>
> The terms "expenditure" and "electioneering communication" are not
> catch-alls. They carry specific definitions (or should)... to protect
> speech -- even when plugged into the statute that prohibits unlimited
> coordination.
>
> Steve Hoersting
>
> On Thu, Nov 10, 2011 at 1:28 AM, Trevor Potter <tpotter at capdale.com
> <mailto:tpotter at capdale.com>> wrote:
>
> The appeal to Buckley here is surely ironic: it was Buckley that
> defined "independent communication" as "wholly uncoordinated with a
> candidate"--the very standard that is not met with these ads.
> Trevor Potter
>
>
> Sent by Good Messaging (www.good.com <http://www.good.com>)
>
>
> -----Original Message-----
> From: Smith, Brad [mailto:BSmith at law.capital.edu
> <mailto:BSmith at law.capital.edu>]
>
> Sent: Wednesday, November 09, 2011 11:46 PM Eastern Standard Time
> To: Trevor Potter; Rick Hasen
> Cc: law-election at uci.edu <mailto:law-election at uci.edu>
> Subject: RE: Re: [EL] ELB News and Commentary 11/8/11
>
> Many members of the reform community, like Mr. Colbert, have long had
> difficulty understanding the limits on coordinated communication,
> especially content limits to trigger the coordination analysis. Of
> course, this starts with the fact that they don't agree fundamentally
> with the level of protection the Supreme Court has given to political
> speech. But that battle was lost in Buckley, and the ground partially
> reclaimed by the low quality opinions in Austin and McConnell has not
> been held.
>
>
>
> What I find many reformers struggle with - and it's evident in
> Trevor's comments below, about "coordinated uncoordinated" ads and so
> on - is that the Court's Buckley decision is intended to be highly
> protective of speech. These reformers can't understand why, if the
> Court allowed some regulation of contributions to protect against
> corruption or its appearance, it can then stand by and declare
> constitutionally protected activity that, they believe, has the same
> or greater corrupting possibility and appearance.
>
>
>
> But one reason the Court struck down limits on independent
> expenditures is that, having held that "expenditure" had to be
> narrowly defined as "explicit advocacy of election or defeat," it
> realized that expenditure limits would be easily evaded by issue ads.
> In short, the opinion predicts, and prohibits regulation of, exactly
> the type of thing that certain reformers suggest justifies more regulation
>
>
>
> What this illustrates is that many speech rules allow regulation in
> theory, but very little in actual practice. They restrict regulation
> to a set of extreme (and often somewhat arbitrary) situations in order
> to protect most speech. Thus, in theory public figures can sue for
> libel - in practice, such suits are very hard to win. In theory,
> Brandenburg allows speech to be regulated that incites to riot - in
> practice, prosecutors rarely try. In theory, porn can be banned - in
> practice, other than child porn, it's pretty hard to imagine anything
> that is banned. In theory, Chaplinsky upholds the validity of
> prosecutions for "fighting words" - in practice, no prosecutor tries
> to bring such suits because he will lose.
>
>
>
> In other words, the Court frequently allows regulation of types of
> speech only at their most extreme. Such was the case in Buckley,
> allowing limits only on direct contributions to candidates and
> parties. People who claim that this makes these various speech
> doctrines into jokes, or riddled with "loopholes," or nonsensical,
> simply don't understand the what the Court is doing. The Court is not
> so stupid as Mr. Colbert and Mr. Potter think. Reformers such as Mr.
> Potter and Mr. Colbert take as a given the very thing they have failed
> to convince the Court of - namely, that more regulation of political
> speech would be, on balance, a good thing, or at least a
> constitutional thing.
>
>
>
> Like the core doctrine of express advocacy, content requirements
> before coordinated communications can be limited are intended to
> protect most political speech. Frankly, then, the Colbert/Potter
> argument against content rules simply fails to come to grips with
> reason for them. This is unfortunate, because as a result people are
> not being educated in why the law is as it is. Good satire
> illuminates. Unfortunately, Mr. Colbert's bits, while reasonably
> humorous, do not.
>
>
>
> Brad Smith
>
> ________________________________________
> From: Trevor Potter [tpotter at capdale.com <mailto:tpotter at capdale.com>]
> Sent: Wednesday, November 09, 2011 2:28 PM
> To: Rick Hasen
> Cc: Smith, Brad; law-election at uci.edu <mailto:law-election at uci.edu>
> Subject: RE: Re: [EL] ELB News and Commentary 11/8/11
>
> Well, actually what we "go to the FEC with" is the American Crossroads
> AOR-swhich has the facts as I described them: an advertisement "fully
> coordinated" with a candidate as to message, filmed with the
> candidate, focusing on themes the candidate is emphasizing in his/her
> campaign, and run outside the FEC's coordination "window". So we will
> see what the Commission does with that request by American. Crossroads
> to approve coordinated uncoordinated candidate advertising... Comment
> letters are uselful in illuminating the issues, as this discussion on
> the list serve has been, but not central to the legal outcome, which
> is why I was suggesting that we "assume the facts" as Crossroads has
> presented them for purposes of focusing on the issue before the FEC.
> Trevor
>
> Sent by Good Messaging (www.good.com <http://www.good.com>)
>
>
> -----Original Message-----
> From: Rick Hasen [mailto:rhasen at law.uci.edu <mailto:rhasen at law.uci.edu>]
> Sent: Wednesday, November 09, 2011 01:27 PM Eastern Standard Time
> To: Trevor Potter
> Cc: Smith, Brad; law-election at uci.edu <mailto:law-election at uci.edu>
> Subject: Re: [EL] ELB News and Commentary 11/8/11
>
> Your assumption (assume his lips were covered and the phrase fully
> bleeped) reminds me of the joke
> <http://economics.about.com/od/termsbeginningwith1/g/assume_a_can_opener.htm>
> about the economist on the desert island who "assumes" a can opener.
> (It also reminds me of a Yiddish expression which is not suitable for
> the listserv.)
>
> We have to go to the FEC with the facts that we have, not the facts
> that we wish them to be.
>
> On 11/9/2011 10:07 AM, Trevor Potter wrote:
>
> I agree with Brad and Rick that ads containing words of express
> advocacy (vote for me or smith for president) have always been held by
> the FEC to consitute express advocacy, even when the context might
> suggest otherwise. I am out of the US and cannot access the draft ad
> as submitted by the Colbert SuperPAC to the FEC, but the intention was
> to "bleep" the phrase "vote for me.".
>
> Rick and Brad have further noted that lip readers could
> decifer the message even with a full bleep. Accordingly, for election
> law purposes let's assume that the ad proposed to be run bleeps the
> whole phrase, AND covers his lips at the relevant moment! (certainly
> technilogically possible)
>
> This would place the ad where the Nelson ad is in Nebraska-and
> where American Crossroads says they want to be: an ad about a
> candidate, using film of the candidate, coordinated with the
> candidate, and featuring messages central to the candidate's campaign,
> but without words of express advocacy .
>
> That is the Nelson ad, the American Crossroads AOR, and the
> point of the Colbert comments.
>
> Best
> Trevor
>
> Sent by Good Messaging (www.good.com <http://www.good.com>)
>
>
> -----Original Message-----
> From: Smith, Brad [mailto:BSmith at law.capital.edu
> <mailto:BSmith at law.capital.edu>]
> Sent: Wednesday, November 09, 2011 08:52 AM Eastern Standard Time
> To: Trevor Potter
> Cc: law-election at uci.edu <mailto:law-election at uci.edu>
> Subject: RE: Re: [EL] ELB News and Commentary 11/8/11
>
> Trevor, I just watched the ad again on the link directly taken
> from Colbert's comments, and I'm afraid it says "V*** for me." What am
> I missing? This is the link I followed from the comments submitted to
> the FEC: http://www.colbertsuperpac.com/undaunted-non-coordination/.
> Is there supposed to be some other link?
>
> Even if all three words are clearly bleeped out in some other
> version, I think it fails (or passes) the express advocacy test, as
> anybody watching the ad can clearly read Roemer's lips. This is not
> the subjective pre-WRTL test, but rather the objective post-WRTL test.
> The viewer is not left to infer the meaning of the statement; the
> statement is clear in and of itself.
>
> In another post responding to interesting examples made by Tom
> Cares, I noted that the FEC has long struggled with the content
> element of a coordinated communication. As Tom notes, the absence of
> any content element would make little sense - certainly as little as
> the express advocacy standard sometimes does, but without the added
> virtue of providing a bright line test for speakers.
>
> Brad Smith
>
> ________________________________________
> From: Trevor Potter [tpotter at capdale.com
> <mailto:tpotter at capdale.com>]
> Sent: Wednesday, November 09, 2011 8:16 AM
> To: Smith, Brad
> Cc: law-election at uci.edu <mailto:law-election at uci.edu>
> Subject: RE: Re: [EL] ELB News and Commentary 11/8/11
>
> Except it doesn't say "V**e for Buddy Roemer"--it says "****
> *** ****".. So Brad must be using the famous "subpart B" of the FEC
> express advocacy regulations disavowed by recent GOP Commissioners-an
> ad "capable of no other interpretation"...
>
> Sent by Good Messaging (www.good.com <http://www.good.com>)
>
>
> -----Original Message-----
> From: Smith, Brad [mailto:BSmith at law.capital.edu
> <mailto:BSmith at law.capital.edu>]
> Sent: Wednesday, November 09, 2011 08:01 AM Eastern Standard Time
> To: Trevor Potter
> Cc: law-election at uci.edu <mailto:law-election at uci.edu>
> Subject: RE: Re: [EL] ELB News and Commentary 11/8/11
>
> No, and I had taken those facts into acount. The words "vote
> for me" are unmistakeable to any voter, as much as if a written
> communication said "V**e for Buddy Roemer." Indeed, the little bleep
> effort probably just makes it a knowing and willful violation.
>
> - Brad Smith
>
>
> ________________________________________
> From: Trevor Potter [tpotter at capdale.com
> <mailto:tpotter at capdale.com>]
> Sent: Wednesday, November 09, 2011 3:59 AM
> To: Rick Hasen
> Cc: Smith, Brad; law-election at uci.edu <mailto:law-election at uci.edu>
> Subject: RE: Re: [EL] ELB News and Commentary 11/8/11
>
> The ad Mr. Colbert has said he would run if the American
> Crossroads AOR is approved is the one he submitted to the FEC in his
> comments. As Rick notes, that ad does not contain express words of
> advocacy. Where those were in the ad he showed his studio audience
> there is now a bleep. So viewers of the ad as broadcast to advertisers
> not not include any express words. None of this is a secret--the ad
> he has submitted ti the FEC clearly contains the bleep. Does that
> fact change your views, Brad and Rick?
> Best
> Trevor
>
> Sent by Good Messaging (www.good.com <http://www.good.com>)
>
>
> -----Original Message-----
> From: Rick Hasen [mailto:rhasen at law.uci.edu
> <mailto:rhasen at law.uci.edu>]
> Sent: Tuesday, November 08, 2011 05:26 PM Eastern Standard Time
> To: Trevor Potter
> Cc: Smith, Brad; law-election at uci.edu
> <mailto:law-election at uci.edu>
> Subject: Re: [EL] ELB News and Commentary 11/8/11
>
> How about Roemer saying "Vote for me"? Don't go all WRTL on
> me, Trevor.
>
> Here's a transcript of the ad which I made by listening. On
> the version on the web, the word "vote" is bleeped out, but it was not
> bleeped last night when I saw it on television:
>
> Roemer: "Hi. I'm Buddy Roemer. God I wish I weren't in this
> ad. See I didn't pay for it. Colbert Super-PAC did. And Super-Pacs
> are not supposed to coordinate with candidates like me. But because
> this is an 'issue ad' about Super-PACs not coordinating with
> candidates I can be in it as long as I don't say [Roemer pauses and
> faces the camera]: 'Vote for me." [On screen are then flashed the
> words 'Not an endorsement'.]. I say that argument is just a fig leaf
> so super-pacs can justify doing whatever they want. And they have a
> lot of money folks. They built this fake set, with fake books, filled
> with real money. Hell, they even bought Colbert a unicorn."
>
> Colbert: "All perfectly legal, Rainbow."
>
> Roemer: "I'm Buddy Roemer and I approve this message. Did you?"
>
> Colbert: "To Narnia."
>
> Announcer: "This issue ad paid for by Americans for Tomorrow,
> Tommorow and approved by Buddy Roemer. No money was harmed in the
> making of this ad."
>
>
>
>
> On 11/8/2011 12:47 PM, Trevor Potter wrote:
>
> It would be enlightening to know why each of you
> reached that conclusion.Are there express words of advocacy? Is it the
> identification of Gov. Roemer as a candidate? is the ad capable of no
> other interpretation (even though the Governor identifies the "issue"
> of campaign finance policy as the reason for the ad?). What is the
> legal rational for your inclusions, Brad and Rick-for the education of
> the list serve?
>
> Best
> Trevor
>
> Sent from my iPad
>
> On Nov 8, 2011, at 9:05 PM, "Rick Hasen"
> <rhasen at law.uci.edu <mailto:rhasen at law.uci.edu>>
> <mailto:rhasen at law.uci.edu <mailto:rhasen at law.uci.edu>> wrote:
>
>
>
> It is not every day that Brad Smith and I would
> vote the same way on an issue before the FEC.
>
> On 11/8/2011 11:22 AM, Smith, Brad wrote:
>
> If I were still an FEC Commissioner,
> based on what I know, I would find that the Colbert/Roemer ad was a
> coordinated communication containing express advocacy and thus could
> not be paid for by Colbert's PAC.
>
>
>
> Bradley A. Smith
>
> Josiah H. Blackmore II/Shirley M. Nault
>
> Designated Professor of Law
>
> Capital University Law School
>
> 303 East Broad Street
>
> Columbus, OH 43215
>
> (614) 236-6317 <tel:%28614%29%20236-6317>
>
> bsmith at law.capital.edu <mailto:bsmith at law.capital.edu>
> <mailto:bsmith at law.capital.edu <mailto:bsmith at law.capital.edu>>
> <mailto:bsmith at law.capital.edu <mailto:bsmith at law.capital.edu>>
>
> http://www.law.capital.edu/faculty/bios/bsmith.asp
> <http://www.law.capital.edu/faculty/bios/bsmith.asp>
> <http://www.law.capital.edu/faculty/bios/bsmith.asp>
>
>
>
> From:
> law-election-bounces at department-lists.uci.edu
> <mailto:law-election-bounces at department-lists.uci.edu>
> [mailto:law-election-bounces at department-lists.uci.edu
> <mailto:law-election-bounces at department-lists.uci.edu>] On Behalf Of
> Rick Hasen
> Sent: Tuesday, November 08, 2011 11:22 AM
> To: law-election at uci.edu
> <mailto:law-election at uci.edu>
> Subject: [EL] ELB News and Commentary
> 11/8/11
>
>
>
>
> Must-Watch Colbert Segments on Super
> PACs and Coordination with Candidates
> <http://electionlawblog.org/?p=25160>
> <http://electionlawblog.org/?p=25160>
>
>
> Posted on November 8, 2011 9:10 am
> <http://electionlawblog.org/?p=25160>
> <http://electionlawblog.org/?p=25160> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> It is not easy to make the complex
> world of campaign finance comprehensible, much less entertaining. One
> unanswered question in the current campaign finance world is whether
> Super PACs may feature candidates in their ads if they do so far
> enough out before the election. For background on the issue, see this
> post <http://electionlawblog.org/?p=24164>
> <http://electionlawblog.org/?p=24164> linking to this NYT report
> <http://www.nytimes.com/2011/10/13/us/politics/ben-nelsons-campaign-ads-may-break-new-ground.html?hp>
> <http://www.nytimes.com/2011/10/13/us/politics/ben-nelsons-campaign-ads-may-break-new-ground.html?hp>
> on Ben Nelson and this <http://electionlawblog.org/?p=24143>
> <http://electionlawblog.org/?p=24143> WaPo report <http:/
> /electionlawblog.org/?p=24143
> <http://electionlawblog.org/?p=24143>>
> <http://electionlawblog.org/?p=24143> on American Crossroads seeking
> to emulate and expand on the Nelson strategy. The American Crossroads
> request for an advisory opinion with the FEC is here
> <http://saos.nictusa.com/aodocs/1188794.pdf>
> <http://saos.nictusa.com/aodocs/1188794.pdf> .
>
> Stephen Colbert took this issue on last
> night, with some help from Trevor Potter, and it was brilliant
> performance art. Not only did Colbert feature a segment explaining
> <http://www.colbertnation.com/the-colbert-report-videos/401673/november-07-2011/colbert-super-pac---issue-ads>
> <http://www.colbertnation.com/the-colbert-report-videos/401673/november-07-2011/colbert-super-pac---issue-ads>
> the issue. He followed it up with a segment with
> <http://www.colbertnation.com/the-colbert-report-videos/401674/november-07-2011/colbert-super-pac---issue-ads---trevor-potter>
> <http://www.colbertnation.com/the-colbert-report-videos/401674/november-07-2011/colbert-super-pac---issue-ads---trevor-potter>
> Trevor Potter explaining that Colbert's Super PAC is submitting
> comments on the American Crossroads AO request, and an actual ad
> <http://www.colbertnation.com/the-colbert-report-videos/401632/november-07-2011/colbert-super-pac-ad---undaunted-non-coordination
> > coordinated with presidential candidate Buddy Roemer (who not
> coincidentally has made campaign finance reform his signature issue).
>
> I criticized Colbert for playing with
> fire
> <http://marketplace.publicradio.org/display/web/2011/08/11/pm-first-moves-from-colbert-super-pac/>
> <http://marketplace.publicradio.org/display/web/2011/08/11/pm-first-moves-from-colbert-super-pac/>
> with the "Rick Parry" issue, and maybe this is playing with fire too.
> But he's done more to educate the general public about the
> troublesome nature of super PACs than anyone else in the media or
> academia.
>
> Below the fold I've reprinted the
> Colbert comment on the American Crossroads AO.
>
>
>
> Continue reading ?
> <http://electionlawblog.org/?p=25160#more-25160>
> <http://electionlawblog.org/?p=25160#more-25160>
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25160&title=Must-Watch%20Colbert%20Segments%20on%20Super%20PACs%20and%20Coordination%20with%20Candidates&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25160&title=Must-Watch%20Colbert%20Segments%20on%20Super%20PACs%20and%20Coordination%20with%20Candidates&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25160&title=Must-Watch%20Colbert%20Segments%20on%20Super%20PACs%20and%20Coordination%20with%20Candidates&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25160&title=Must-Watch%20Colbert%20Segments%20on%20Super%20PACs%20and%20Coordination%20with%20Candidates&description=>>
>
> Posted in campaign finance
> <http://electionlawblog.org/?cat=10>
> <http://electionlawblog.org/?cat=10> , election law "humor"
> <http://electionlawblog.org/?cat=52>
> <http://electionlawblog.org/?cat=52> | Comments Off
>
>
> "Fairfax County braces for election
> confusion after voter database glitches"
> <http://electionlawblog.org/?p=25157>
> <http://electionlawblog.org/?p=25157>
>
>
> Posted on November 8, 2011 8:53 am
> <http://electionlawblog.org/?p=25157>
> <http://electionlawblog.org/?p=25157> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> WaPo reports
> <http://www.washingtonpost.com/local/dc-politics/fairfax-county-braces-for-election-confusion-after-voter-database-glitches/2011/11/07/gIQAOCVlwM_story.html>
> <http://www.washingtonpost.com/local/dc-politics/fairfax-county-braces-for-election-confusion-after-voter-database-glitches/2011/11/07/gIQAOCVlwM_story.html>
> .
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25157&title=%E2%80%9CFairfax%20County%20braces%20for%20election%20confusion%20after%20voter%20database%20glitches%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25157&title=%E2%80%9CFairfax%20County%20braces%20for%20election%20confusion%20after%20voter%20database%20glitches%E2%80%9D&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25157&title=%E2%80%9CFairfax%20County%20braces%20for%20election%20confusion%20after%20voter%20database%20glitches%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25157&title=%E2%80%9CFairfax%20County%20braces%20for%20election%20confusion%20after%20voter%20database%20glitches%E2%80%9D&description=>>
>
> Posted in election administration
> <http://electionlawblog.org/?cat=18>
> <http://electionlawblog.org/?cat=18> | Comments Off
>
>
> "Lawmakers Struggling Through
> Pennsylvania Redraw" <http://electionlawblog.org/?p=25154>
> <http://electionlawblog.org/?p=25154>
>
>
> Posted on November 8, 2011 8:49 am
> <http://electionlawblog.org/?p=25154>
> <http://electionlawblog.org/?p=25154> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> Roll Call reports
> <http://roll.cl/uWHKin> <http://roll.cl/uWHKin> .
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25154&title=%E2%80%9CLawmakers%20Struggling%20Through%20Pennsylvania%20Redraw%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25154&title=%E2%80%9CLawmakers%20Struggling%20Through%20Pennsylvania%20Redraw%E2%80%9D&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25154&title=%E2%80%9CLawmakers%20Struggling%20Through%20Pennsylvania%20Redraw%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25154&title=%E2%80%9CLawmakers%20Struggling%20Through%20Pennsylvania%20Redraw%E2%80%9D&description=>>
>
> Posted in redistricting
> <http://electionlawblog.org/?cat=6>
> <http://electionlawblog.org/?cat=6> | Comments Off
>
>
> " Who can vote? Maine and Mississippi
> consider opposite directions" <http://electionlawblog.org/?p=25151>
> <http://electionlawblog.org/?p=25151>
>
>
> Posted on November 8, 2011 8:46 am
> <http://electionlawblog.org/?p=25151>
> <http://electionlawblog.org/?p=25151> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> The Christian Science Monitor reports
> <http://www.csmonitor.com/USA/Elections/2011/1108/Who-can-vote-Maine-and-Mississippi-consider-opposite-directions>
> <http://www.csmonitor.com/USA/Elections/2011/1108/Who-can-vote-Maine-and-Mississippi-consider-opposite-directions>
> . TPM offers Maine GOP Ad: The Gays Are Trying To Impose Same Day
> Voter Registration
> <http://tpmmuckraker.talkingpointsmemo.com/2011/11/maine_gop_ad_the_gays_are_trying_to_impose_same_day_voter_registration.php>
> <http://tpmmuckraker.talkingpointsmemo.com/2011/11/maine_gop_ad_the_gays_are_trying_to_impose_same_day_voter_registration.php>
> .
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25151&title=%E2%80%9D%20Who%20can%20vote%3F%20Maine%20and%20Mississippi%20consider%20opposite%20directions%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25151&title=%E2%80%9D%20Who%20can%20vote%3F%20Maine%20and%20Mississippi%20consider%20opposite%20directions%E2%80%9D&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25151&title=%E2%80%9D%20Who%20can%20vote%3F%20Maine%20and%20Mississippi%20consider%20opposite%20directions%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25151&title=%E2%80%9D%20Who%20can%20vote%3F%20Maine%20and%20Mississippi%20consider%20opposite%20directions%E2%80%9D&description=>>
>
> Posted in election administration
> <http://electionlawblog.org/?cat=18>
> <http://electionlawblog.org/?cat=18> , The Voting Wars
> <http://electionlawblog.org/?cat=60>
> <http://electionlawblog.org/?cat=60> | Comments Off
>
>
> Colbert on OWS
> <http://electionlawblog.org/?p=25148>
> <http://electionlawblog.org/?p=25148>
>
>
> Posted on November 7, 2011 8:40 pm
> <http://electionlawblog.org/?p=25148>
> <http://electionlawblog.org/?p=25148> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> Don't miss Parts I
> <http://www.colbertnation.com/the-colbert-report-videos/401092/october-31-2011/colbert-super-pac---occupy-wall-street-co-optportunity---stephen-on-location>
> <http://www.colbertnation.com/the-colbert-report-videos/401092/october-31-2011/colbert-super-pac---occupy-wall-street-co-optportunity---stephen-on-location>
> and II
> <http://www.colbertnation.com/the-colbert-report-videos/401261/november-01-2011/colbert-super-pac---stephen-colbert-occupies-occupy-wall-street-pt--2>
> <http://www.colbertnation.com/the-colbert-report-videos/401261/november-01-2011/colbert-super-pac---stephen-colbert-occupies-occupy-wall-street-pt--2>
> (especially Part II discussing Citizens United and whether
> corporations are people). Hilarious!
>
>
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25148&title=Colbert%20on%20OWS&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25148&title=Colbert%20on%20OWS&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25148&title=Colbert%20on%20OWS&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25148&title=Colbert%20on%20OWS&description=>>
>
> Posted in election law "humor"
> <http://electionlawblog.org/?cat=52>
> <http://electionlawblog.org/?cat=52> | Comments Off
>
>
> "Mitt Romney Winning Fundraising
> Contest For Bush, McCain Bundlers"
> <http://electionlawblog.org/?p=25145>
> <http://electionlawblog.org/?p=25145>
>
>
> Posted on November 7, 2011 4:15 pm
> <http://electionlawblog.org/?p=25145>
> <http://electionlawblog.org/?p=25145> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> HuffPo reports
> <http://www.huffingtonpost.com/2011/11/07/mitt-romney-fundraising-bush-mccain-bundlers_n_1080245.html?ref=politics>
> <http://www.huffingtonpost.com/2011/11/07/mitt-romney-fundraising-bush-mccain-bundlers_n_1080245.html?ref=politics>
> .
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25145&title=%E2%80%9CMitt%20Romney%20Winning%20Fundraising%20Contest%20For%20Bush%2C%20McCain%20Bundlers%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25145&title=%E2%80%9CMitt%20Romney%20Winning%20Fundraising%20Contest%20For%20Bush%2C%20McCain%20Bundlers%E2%80%9D&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25145&title=%E2%80%9CMitt%20Romney%20Winning%20Fundraising%20Contest%20For%20Bush%2C%20McCain%20Bundlers%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25145&title=%E2%80%9CMitt%20Romney%20Winning%20Fundraising%20Contest%20For%20Bush%2C%20McCain%20Bundlers%E2%80%9D&description=>>
>
> Posted in campaign finance
> <http://electionlawblog.org/?cat=10>
> <http://electionlawblog.org/?cat=10> | Comments Off
>
>
> "iPad Voting Rolls Out For Some
> Oregonians" <http://electionlawblog.org/?p=25142>
> <http://electionlawblog.org/?p=25142>
>
>
> Posted on November 7, 2011 4:09 pm
> <http://electionlawblog.org/?p=25142>
> <http://electionlawblog.org/?p=25142> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> Helping voters with disabilities
> <http://www.huffingtonpost.com/2011/11/07/ipad-voting-oregon_n_1080691.html?ref=technology>
> <http://www.huffingtonpost.com/2011/11/07/ipad-voting-oregon_n_1080691.html?ref=technology>
> (not Internet voting).
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25142&title=%E2%80%9CiPad%20Voting%20Rolls%20Out%20For%20Some%20Oregonians%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25142&title=%E2%80%9CiPad%20Voting%20Rolls%20Out%20For%20Some%20Oregonians%E2%80%9D&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25142&title=%E2%80%9CiPad%20Voting%20Rolls%20Out%20For%20Some%20Oregonians%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25142&title=%E2%80%9CiPad%20Voting%20Rolls%20Out%20For%20Some%20Oregonians%E2%80%9D&description=>>
>
> Posted in election administration
> <http://electionlawblog.org/?cat=18>
> <http://electionlawblog.org/?cat=18> | Comments Off
>
>
> "Voter Fraud: Does It Happen?"
> <http://electionlawblog.org/?p=25139>
> <http://electionlawblog.org/?p=25139>
>
>
> Posted on November 7, 2011 3:42 pm
> <http://electionlawblog.org/?p=25139>
> <http://electionlawblog.org/?p=25139> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> Andrew Rosenthal blogs
> <http://loyalopposition.blogs.nytimes.com/2011/11/07/voter-fraud-does-it-happen/?src=tp>
> <http://loyalopposition.blogs.nytimes.com/2011/11/07/voter-fraud-does-it-happen/?src=tp>
> at the NYT oped page's "Loyal Opposition" blog.
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25139&title=%E2%80%9CVoter%20Fraud%3A%20Does%20It%20Happen%3F%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25139&title=%E2%80%9CVoter%20Fraud%3A%20Does%20It%20Happen%3F%E2%80%9D&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25139&title=%E2%80%9CVoter%20Fraud%3A%20Does%20It%20Happen%3F%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25139&title=%E2%80%9CVoter%20Fraud%3A%20Does%20It%20Happen%3F%E2%80%9D&description=>>
>
> Posted in election administration
> <http://electionlawblog.org/?cat=18>
> <http://electionlawblog.org/?cat=18> , The Voting Wars
> <http://electionlawblog.org/?cat=60>
> <http://electionlawblog.org/?cat=60> , voter id
> <http://electionlawblog.org/?cat=9>
> <http://electionlawblog.org/?cat=9> | Comments Off
>
>
> Raskin and Richie on Gerrymandering in
> Maryland and Beyond <http://electionlawblog.org/?p=25136>
> <http://electionlawblog.org/?p=25136>
>
>
> Posted on November 7, 2011 2:55 pm
> <http://electionlawblog.org/?p=25136>
> <http://electionlawblog.org/?p=25136> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> Here
> <http://www.baltimoresun.com/news/opinion/oped/bs-ed-voting-districts-20111107,0,3418353.story>
> <http://www.baltimoresun.com/news/opinion/oped/bs-ed-voting-districts-20111107,0,3418353.story>
> , in the Baltimore Sun.
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25136&title=Raskin%20and%20Richie%20on%20Gerrymandering%20in%20Maryland%20and%20Beyond&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25136&title=Raskin%20and%20Richie%20on%20Gerrymandering%20in%20Maryland%20and%20Beyond&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25136&title=Raskin%20and%20Richie%20on%20Gerrymandering%20in%20Maryland%20and%20Beyond&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25136&title=Raskin%20and%20Richie%20on%20Gerrymandering%20in%20Maryland%20and%20Beyond&description=>>
>
> Posted in redistricting
> <http://electionlawblog.org/?cat=6>
> <http://electionlawblog.org/?cat=6> | Comments Off
>
>
> "As Political Groups Push Envelope, FEC
> Gridlock Gives 'De Facto Green Light'"
> <http://electionlawblog.org/?p=25134>
> <http://electionlawblog.org/?p=25134>
>
>
> Posted on November 7, 2011 2:54 pm
> <http://electionlawblog.org/?p=25134>
> <http://electionlawblog.org/?p=25134> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> ProPublica reports
> <http://www.propublica.org/article/as-political-donors-push-envelope-fec-gridlock-gives-de-facto-green-light>
> <http://www.propublica.org/article/as-political-donors-push-envelope-fec-gridlock-gives-de-facto-green-light>
> . As I've written in @Slate, the FEC is as good as dead.
> <http://www.slate.com/articles/news_and_politics/jurisprudence/2011/01/the_fec_is_as_good_as_dead.html>
> <http://www.slate.com/articles/news_and_politics/jurisprudence/2011/01/the_fec_is_as_good_as_dead.html>
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25134&title=%E2%80%9CAs%20Political%20Groups%20Push%20Envelope%2C%20FEC%20Gridlock%20Gives%20%E2%80%98De%20Facto%20Green%20Light%E2%80%99%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25134&title=%E2%80%9CAs%20Political%20Groups%20Push%20Envelope%2C%20FEC%20Gridlock%20Gives%20%E2%80%98De%20Facto%20Green%20Light%E2%80%99%E2%80%9D&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25134&title=%E2%80%9CAs%20Political%20Groups%20Push%20Envelope%2C%20FEC%20Gridlock%20Gives%20%E2%80%98De%20Facto%20Green%20Light%E2%80%99%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25134&title=%E2%80%9CAs%20Political%20Groups%20Push%20Envelope%2C%20FEC%20Gridlock%20Gives%20%E2%80%98De%20Facto%20Green%20Light%E2%80%99%E2%80%9D&description=>>
>
> Posted in Uncategorized
> <http://electionlawblog.org/?cat=1>
> <http://electionlawblog.org/?cat=1> | Comments Off
>
>
> Watch the Jack Abramoff Interview on
> "60 Minutes" <http://electionlawblog.org/?p=25131>
> <http://electionlawblog.org/?p=25131>
>
>
> Posted on November 7, 2011 12:40 pm
> <http://electionlawblog.org/?p=25131>
> <http://electionlawblog.org/?p=25131> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> Here
> <http://www.cbsnews.com/video/watch/?id=7387331n&tag=contentMain;cbsCarousel
> <http://www.cbsnews.com/video/watch/?id=7387331n&tag=contentMain;cbsCarousel>>
> <http://www.cbsnews.com/video/watch/?id=7387331n&tag=contentMain;cbsCarousel
> <http://www.cbsnews.com/video/watch/?id=7387331n&tag=contentMain;cbsCarousel>>
> .
>
> <mime-attachment.png>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25131&title=Watch%20the%20Jack%20Abramoff%20Interview%20on%20%E2%80%9C60%20Minutes%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25131&title=Watch%20the%20Jack%20Abramoff%20Interview%20on%20%E2%80%9C60%20Minutes%E2%80%9D&description=>>
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25131&title=Watch%20the%20Jack%20Abramoff%20Interview%20on%20%E2%80%9C60%20Minutes%E2%80%9D&description=
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D25131&title=Watch%20the%20Jack%20Abramoff%20Interview%20on%20%E2%80%9C60%20Minutes%E2%80%9D&description=>>
>
> Posted in chicanery
> <http://electionlawblog.org/?cat=12>
> <http://electionlawblog.org/?cat=12> , legislation and legislatures
> <http://electionlawblog.org/?cat=27>
> <http://electionlawblog.org/?cat=27> , lobbying
> <http://electionlawblog.org/?cat=28>
> <http://electionlawblog.org/?cat=28> | Comments Off
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>
> 26 Recalls on Ballot Tomorrow
> <http://electionlawblog.org/?p=25128>
> <http://electionlawblog.org/?p=25128>
>
>
> Posted on November 7, 2011 10:25 am
> <http://electionlawblog.org/?p=25128>
> <http://electionlawblog.org/?p=25128> by Rick Hasen
> <http://electionlawblog.org/?author=3>
> <http://electionlawblog.org/?author=3>
>
> Wow
> <http://recallelections.blogspot.com/2011/11/26-recalls-on-tuesday-recall-elections.html>
> <http://recallelections.blogspot.com/2011/11/26-recalls-on-tuesday-recall-elections.html>
> .
>
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> Posted in recall elections
> <http://electionlawblog.org/?cat=11>
> <http://electionlawblog.org/?cat=11> | Comments Off
>
> --
> Rick Hasen
> Professor of Law and Political Science
> UC Irvine School of Law
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> --
> Rick Hasen
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