[EL] Adelson

Thu Apr 12 06:07:21 PDT 2012

Perhaps a good illustration of this point is that it would result in Soros as a billionaire whose freedom to speak can be restricted by the government to prevent him from dominating the electoral process, while Rupert Murdoch is a billionaire whose freedom to dominate the same electoral process cannot be invaded.

D. Eric Lycan
Steptoe & Johnson PLLC
One Paragon Centre
2525 Harrodsburg Road, Suite 300
Lexington, KY 40504
O: 859-219-8213 F: 304-933-8715 C: 859-621-8888

Eric.Lycan at Steptoe-Johnson.com
www.steptoe-johnson.com

From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Volokh, Eugene
Sent: Wednesday, April 11, 2012 5:57 PM
To: law-election at uci.edu
Subject: Re: [EL] Adelson

                Exactly right:  If we want to prevent the very rich from having disproportionate influence on the electoral process, we do have to invade the freedom of the press, because the freedom of the press is precisely the way the very rich often do have disproportionate influence on the electoral process.

       Indeed, I think that when Adelson spends his money to buy pro-Gingrich ads, he is exercising the freedom of the press (see http://www.law.ucla.edu/volokh/press.pdf).  But even if you take the view that the “freedom of the press” belongs only to the institutional media (as opposed to all users of the press-as-technology), certainly when the owners of newspapers, magazines, cable networks, and the like exercise their freedom of the press, they often do have disproportionate influence on the electoral process.

                Eugene

From: John Tanner [mailto:john.k.tanner at gmail.com]
Sent: Wednesday, April 11, 2012 1:59 PM
To: Frank Askin
Cc: Volokh, Eugene; law-election at uci.edu
Subject: Re: [EL] Adelson

Are the groups mutually exclusive?
On Wed, Apr 11, 2012 at 4:52 PM, Frank Askin <faskin at kinoy.rutgers.edu> wrote:
Does this mean that we should throw out the baby with the bathwater.
That if we want to prevent billionaires from dominating the electoral
process, we have to invade the freedom of the press provided in the
First Amendment?      FRANK

Prof. Frank Askin
Distinguished Professor of Law       and Director
Constitutional Litigation Clinic
Rutgers Law School/Newark
(973) 353-5687>>> "Volokh, Eugene" <VOLOKH at law.ucla.edu> 4/11/2012 4:40
PM >>>
I don’t mean to be a broken record, but I just want to add to the
hypo:  Imagine Jack Treehorn’s brother, Jack Bushhorn, who happens to
own the one newspaper in town, and who throws his weight around the same
way; what should we think about him?  And note that the hypo is probably
more realistic:  There will probably be more than one politically minded
businessman in each town, but there is often only one newspaper (or only
a very few), and especially in the past such newspapers have been
tremendously influential in local campaigns.

               Eugene

From: Jack Cushman [mailto:jcushman at gmail.com]
Sent: Wednesday, April 11, 2012 1:37 PM
To: Volokh, Eugene
Cc: law-election at uci.edu
Subject: Re: [EL] Adelson

It suggests we are a free country ...

But that is not all it suggests. Let's not stop the conversation
there.

I mean, we're going to keep having to talk about what, if anything, we
should do about highly-concentrated political spending, where a tiny
minority of private citizens direct the majority of paid speech. That's
the question of the day. There's rhetorical power to the answer: "We can
and should do nothing, because this is a free country." But that binds
together two positions that need to be separated if this interminable
conversation is going to go anywhere interesting.

Position One: We cannot do anything, because no government can be
trusted to distinguish between good and bad speech.
Position Two: We don't need to do anything, because no activity
characterized as speech can be seriously harmful.

To make the difference clear, consider the hypo of Jackie Treehorn -- a
wealthy businessman in a small town. No one else with any money is much
interested in politics in this town, so if you want to be a mayor,
alderman, sheriff, or judge, your best bet is to make friends with
Treehorn at the country club, and he'll make sure your name shows up on
every yard in town. And by the same token, if Treehorn stops liking you,
he'll back someone else the next time around and you'll have a tough
time getting one yard sign up for every 10 of your opponent's. The
people Treehorn backs are mostly pretty good at their jobs. But if one
of Treehorn's friends is in legal trouble, there's a tendency for
charges to be dropped or dismissed. And if someone is in legal trouble
for messing with Treehorn's friends, they'll be prosecuted to the full
extent of the law. Likewise, Treehorn's friends have a much easier time
getting things through the board of aldermen than his competitors.

So in this hypo, Treehorn is unequivocally engaging in free speech. But
we can also infer that he's impairing freedom in the town. It would be
impossible to point to any particular action by any particular official
-- but the net effect is for officials to exercise their discretion in
Treehorn's favor more than they otherwise would. That's a basic
violation of the 14th Amendment on the officials' part, and impairs the
life, liberty, and property rights of the citizens of the town. It's an
infringement of core freedoms.

Position One says: government lacks the power to do anything about
Treehorn's actions. The only solution is for voters to overcome
Treehorn's influence, or for the law to somehow detect and prevent the
unequal treatment directly.
Position Two says: there's no problem here. This hypo describes a
healthy democracy.

These positions are important to distinguish, because they control what
kind of conversation we can have. If you're taking Position One, then
the useful questions are, how much evidence do we need that the spending
at issue actually changes the way anyone in government acts, before we
think there's a problem? And if we reach that point, what's the best
solution we can come up with to safeguard speech and equal protection
rights as much as possible? If you're taking Position Two, then the
useful question is, what's our definition of freedom? What kind of town,
or nation, are we trying to create?

Both of those could be productive debates. It would be great to
seriously work on the problem of evaluating influence and protecting
both free speech and equal protection. For people who agree that the
Treehorn hypo describes an unhealthy democracy, there should be a lot of
common ground to work on solutions even if we disagree on the precise
bounds of the First Amendment. On the other hand, for people who
disagree about the hypo, it would also be great to explore what kinds of
freedom are at stake here, and be explicit about why we prefer the ones
we prefer.

So to come back (finally) to the article, the claim is that someone
under federal investigation is spending $100 million supporting a
candidate who would control the investigation. If that doesn't trouble
you, I think the first step is to distinguish between "there's no reason
to believe this spending will influence his treatment before the law"
and "there's nothing to be done about the potential for undue influence
here, because the importance of speech outweighs the harm of the
influence" and "the potential for a wealthy person to influence his
treatment before the law is healthy for our democracy." The answer "we
are a free country" assumes, I think, one of those three things, but it
doesn't stake out a real position.

(The other reason to distinguish carefully here is, I suspect that
passionate defenders of free speech sometimes give short shrift to the
problem of undue influence because it strengthens the rhetorical force
of their argument. "This is a free country" rings louder if there are no
freedoms on the other side of the scale. So let me invite everyone to
decouple the importance of free speech from the unimportance of
concentrated political influence, rather than carelessly picking the
same side in both debates.)

Best,
Jack

On Wed, Apr 11, 2012 at 1:56 PM, Volokh, Eugene
<VOLOKH at law.ucla.edu<mailto:VOLOKH at law.ucla.edu>> wrote:
Likewise, what does it suggest when a newspaper that’s under federal,
state, or local government investigation (e.g., for alleged antitrust or
employment law or environment law violations) – or a newspaper
publisher who’s under government investigation (for any of his
business ventures) – can use its tremendous influence with readers to
elect people with authority over the agencies conducting those
investigations?  Same as Bill says:  It suggests we are a free country
that doesn’t restrict political speech, by newspapers or by others.

Eugene

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 Bill Maurer
Sent: Wednesday, April 11, 2012 10:52 AM
To: Rick Hasen; law-election at uci.edu<mailto:law-election at uci.edu>
Subject: Re: [EL] Adelson

“What does it suggest when a man under three federal investigations
can plan on spending up to $100 million dollars to elect the man with
authority over the agencies conducting those investigations?”
How about, “It suggests we are a free country that does not restrict
political speech and accords those accused of crimes the presumption of
innocence before we strip them of their civil rights.”?

Bill

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] On Behalf Of Rick
Hasen
Sent: Tuesday, April 10, 2012 9:17 PM
To: law-election at uci.edu<mailto:law-election at uci.edu>
Subject: [EL] ELB News and Commentary 4/11/12

“Excess McCain 2008 presidential funds went to charity, not 2012
race”<http://electionlawblog.org/?p=32846>
Posted on April 10, 2012 9:06 pm<http://electionlawblog.org/?p=32846>
by Rick Hasen<http://electionlawblog.org/?author=3>

Interesting Washington Times
report.<http://www.washingtontimes.com/news/2012/apr/10/excess-mccain-2008-presidential-funds-went-charity/>
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32846&title=%E2%80%9CExcess%20McCain%202008%20presidential%20funds%20went%20to%20charity%2C%20not%202012%20race%E2%80%9D&description=>
Posted in campaign finance<http://electionlawblog.org/?cat=10> |
Comments Off
“Major corporations drop support of ‘stand your ground’
group”<http://electionlawblog.org/?p=32843>
Posted on April 10, 2012 9:00 pm<http://electionlawblog.org/?p=32843>
by Rick Hasen<http://electionlawblog.org/?author=3>

Cox reports<http://seattletimes.nwsource.com/text/2017951679.html>.
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32843&title=%E2%80%9CMajor%20corporations%20drop%20support%20of%20%E2%80%98stand%20your%20ground%E2%80%99%20group%E2%80%9D&description=>
Posted in Uncategorized<http://electionlawblog.org/?cat=1> | Comments
Off
“Activist’s Undercover Videos on Rules for Voter IDs Lead to an
Investigation”<http://electionlawblog.org/?p=32841>
Posted on April 10, 2012 8:59 pm<http://electionlawblog.org/?p=32841>
by Rick Hasen<http://electionlawblog.org/?author=3>

AP
reports<http://www.nytimes.com/2012/04/11/us/activists-undercover-videos-on-rules-for-voter-ids-lead-to-an-investigation.html>.

MORE<http://dcist.com/2012/04/dc_elections_board_unimpressed_by_j.php>
from the DCist.
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32841&title=%E2%80%9CActivist%E2%80%99s%20Undercover%20Videos%20on%20Rules%20for%20Voter%20IDs%20Lead%20to%20an%20Investigation%E2%80%9D&description=>
Posted in chicanery<http://electionlawblog.org/?cat=12>, fraudulent
fraud squad<http://electionlawblog.org/?cat=8>, The Voting
Wars<http://electionlawblog.org/?cat=60>, voter
id<http://electionlawblog.org/?cat=9> | Comments Off
“Justice Dept.: S.C. voter ID law violates Voting Rights
Act”<http://electionlawblog.org/?p=32839>
Posted on April 10, 2012 8:48 pm<http://electionlawblog.org/?p=32839>
by Rick Hasen<http://electionlawblog.org/?author=3>

USA Today
reports<http://www.usatoday.com/news/washington/judicial/story/2012-04-10/south-carolina-voter-id/54159078/1>.
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32839&title=%E2%80%9CJustice%20Dept.%3A%20S.C.%20voter%20ID%20law%20violates%20Voting%20Rights%20Act%E2%80%9D&description=>
Posted in voter id<http://electionlawblog.org/?cat=9>, Voting Rights
Act<http://electionlawblog.org/?cat=15> | Comments Off
“NY’s Redistricting Process Continues in Legal
Purgatory”<http://electionlawblog.org/?p=32836>
Posted on April 10, 2012 8:42 pm<http://electionlawblog.org/?p=32836>
by Rick Hasen<http://electionlawblog.org/?author=3>

WNYC<http://www.wnyc.org/blogs/empire/2012/apr/10/nys-redistricting-process-continues-legal-purgatory/>:
“Like a sequel to a horror movie most people never saw in the first
place, New York’s redistricting saga continues to play out in court
rooms and administrative offices from Washington, DC and Albany.”
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32836&title=%E2%80%9CNY%E2%80%99s%20Redistricting%20Process%20Continues%20in%20Legal%20Purgatory%E2%80%9D&description=>
Posted in redistricting<http://electionlawblog.org/?cat=6> | Comments
Off
Quote of the Day<http://electionlawblog.org/?p=32833>
Posted on April 10, 2012 11:50 am<http://electionlawblog.org/?p=32833>
by Rick Hasen<http://electionlawblog.org/?author=3>

“What does it suggest when a man under three federal investigations
can plan on spending up to $100 million dollars to elect the man with
authority over the agencies conducting those investigations?
–Rick
Perlstein<http://www.rollingstone.com/politics/blogs/national-affairs/why-gop-mega-donor-sheldon-adelson-is-mad-bad-and-a-danger-to-the-republic-20120410#ixzz1rfG4XXeS>,
in Rolling Stone article on Sheldon Adelson
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32833&title=Quote%20of%20the%20Day&description=>
Posted in campaign finance<http://electionlawblog.org/?cat=10>,
chicanery<http://electionlawblog.org/?cat=12> | Comments Off
Does Mark McKinnon Want a Roemer-Lessig AE
Ticket?<http://electionlawblog.org/?p=32830>
Posted on April 10, 2012 11:43 am<http://electionlawblog.org/?p=32830>
by Rick Hasen<http://electionlawblog.org/?author=3>

Check it
out<http://irregulartimes.com/index.php/archives/2012/04/10/americans-elect-leaders-cant-stop-themselves-from-weighing-in-on-the-presidential-race/>
(near bottom of post).
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32830&title=Does%20Mark%20McKinnon%20Want%20a%20Roemer-Lessig%20AE%20Ticket%3F&description=>
Posted in third parties<http://electionlawblog.org/?cat=47> | Comments
Off
Major Computer Crime Case Turns on Meaning of
“So”<http://electionlawblog.org/?p=32828>
Posted on April 10, 2012 11:12 am<http://electionlawblog.org/?p=32828>
by Rick Hasen<http://electionlawblog.org/?author=3>

U.S. v.
Nosal<http://www.ca9.uscourts.gov/datastore/opinions/2012/04/10/10-10038.pdf>,
en banc Ninth Circuit Kozinski opinion:

In its reply brief and at oral argument, the government focuses on the
word “so” in the same phrase. See 18 U.S.C. § 1030(e)(6)
(“accesser is not entitled so to obtain or alter” (emphasis
added)). The government reads “so” to mean “in that manner,”
which it claims must refer to use restrictions. In the government’s
view, reading the definition narrowly would render “so”
superfluous.

The government’s interpretation would transform the CFAA from an
anti-hacking statute into an expansive misappropriation statute. This
places a great deal of weight on a two-letter word that is essentially a
conjunction. If Congress meant to expand the scope of criminal liability
to everyone who uses a computer in violation of computer use
restrictions —which may well include everyone who uses a computer—
we would expect it to use language better suited to that purpose.3 Under
the presumption that Congress acts interstitially, we construe a statute
as displacing a substantial portion of the common law only where
Congress has clearly indicated its intent to do so.

Another snippet:

Minds have wandered since the beginning of time and the computer gives
employees new ways to procrastinate, by gchatting with friends, playing
games, shopping or watching sports highlights. Such activities are
routinely prohibited by many computer-use policies, although employees
are seldom disciplined for occasional use of work computers for personal
purposes. Nevertheless, under the broad interpretation of the CFAA, such
minor dalliances would become federal crimes. While it’s unlikely that
you’ll be prosecuted for watching Reason.TV on your work computer, you
could be. Employers wanting to rid themselves of troublesome employees
without following proper procedures could threaten to report them to the
FBI unless they quit.6 Ubiquitous, seldom-prosecuted crimes invite
arbitrary and discriminatory enforcement.7

From the dissent:

This case has nothing to do with playing sudoku, checking email,
fibbing on dating sites, or any of the other activities that the
majority rightly values. It has everything to do with stealing an
employer’s valuable information to set up a competing business with
the purloined data, siphoned away from the victim, knowing such access
and use were prohibited in the defendants’ employment contracts. The
indictment here charged that Nosal and his co-conspirators knowingly
exceeded the access to a protected company computer they were given by
an executive search firm that employed them; that they did so with the
intent to defraud; and further, that
they stole the victim’s valuable proprietary information by means of
that fraudulent conduct in order to profit from using it. In ridiculing
scenarios not remotely presented by this case, the majority does a good
job of knocking down straw men —far-fetched hypotheticals involving
neither theft nor intentional fraudulent conduct, but innocuous
violations of office policy.

The majority also takes a plainly written statute and parses it in a
hyper-complicated way that distorts the obvious intent of Congress. No
other circuit that has considered this statute finds the problems that
the majority does.

Did someone say “SCOTUS”?
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32828&title=Major%20Computer%20Crime%20Case%20Turns%20on%20Meaning%20of%20%E2%80%9CSo%E2%80%9D&description=>
Posted in statutory interpretation<http://electionlawblog.org/?cat=21>,
Supreme Court<http://electionlawblog.org/?cat=29> | Comments Off
“ReCoding Good: Part 4″<http://electionlawblog.org/?p=32825>
Posted on April 10, 2012 9:20 am<http://electionlawblog.org/?p=32825>
by Rick Hasen<http://electionlawblog.org/?author=3>

Stanford Social Innovation
Review:<http://www.ssireview.org/blog/entry/recoding_good_part_4>

On March 20, two-dozen scholars, practitioners, and policymakers met
for a discussion around the theme “Are Nonprofits People, Too?
Citizens United and the Future of the Social Sector.” Responding to
the expanded roles that certain nonprofit organizations—501(c)(4)
social welfare organizations, in particular—are now playing in
electoral politics, the group discussed the potential effects of
Citizens United on the philanthropic and nonprofit sector as a whole,
beyond the particular actions now allowed by law.

We opened a presentation by Professor Rick
Hasen<http://www.ssireview.org/pdf/hasen-stanfordpacs-2.pdf> of UC
Irvine, who studies election law and created the Election Law
Blog<http://electionlawblog.org/>. He explained how the legal and
political landscape has shifted for 501(c)(4) and (c)(6) nonprofit
organizations since January 2010, emphasizing the role they can now play
in making electioneering expenditures. From the perspective of campaign
finance, 501(c)(4) and (c)(6) nonprofits offer donors a distinctive
loophole (or, perhaps, advantage) over other organizations such as
political action committees, political parties, and Super PACs: These
nonprofits do not need to publicly disclose donors’ identities. Data
comparing campaign finance expenditure reports from 2012 to previous
presidential election years show a clear shift in dollars from PACs and
other 527 groups<http://en.wikipedia.org/wiki/527_organization> that do
require donor disclosure to (c)(4) and (c)(6) nonprofits. Using data
from the Center for Responsive Politics<http://www.opensecrets.org/>,
Hasen found that outside spending in the 2012 presidential election
through February was 264 percent greater than the same time in 2008 and
more than 600 percent greater than in 2004.

Adam Bonica of the Stanford Political Science Department questioned the
degree to which electioneering spending equals
influence.<http://www.ssireview.org/pdf/bonica_cu_data.pdf> His
research looks at the many ways commercial corporations seek to
influence political decision making—including lobbying, federal
election spending, involvement on state ballot measures, and the
“revolving door” of relationships between private sector and
elected officials and their staff. One notable finding: Nonprofit and
commercial corporations spend significantly less on elections than they
do on lobbying.

These opening remarks led the group to reach a general consensus that
policing one organization structure—say, by imposing disclosure
requirements on 501(c)(4) social welfare organizations—would have
limited impact on campaign finance per se. Changing the rules for
certain nonprofits would be like playing “whack-a-mole” with the
money; it would simply pop up somewhere else.

The discussion then branched out in several directions:…
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32825&title=%E2%80%9CReCoding%20Good%3A%20Part%204%E2%80%B3&description=>
Posted in campaign finance<http://electionlawblog.org/?cat=10>, tax law
and election law<http://electionlawblog.org/?cat=22> | Comments Off
“The Breitbart ‘Voter Fraud’ Video Proves Absolutely
Nothing”<http://electionlawblog.org/?p=32822>
Posted on April 10, 2012 9:18 am<http://electionlawblog.org/?p=32822>
by Rick Hasen<http://electionlawblog.org/?author=3>

The Business Insider
reports<http://articles.businessinsider.com/2012-04-09/politics/31311600_1_voter-fraud-voter-identification-voter-id-laws>.
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32822&title=%E2%80%9CThe%20Breitbart%20%E2%80%98Voter%20Fraud%E2%80%99%20Video%20Proves%20Absolutely%20Nothing%E2%80%9D&description=>
Posted in election administration<http://electionlawblog.org/?cat=18>,
fraudulent fraud squad<http://electionlawblog.org/?cat=8>, The Voting
Wars<http://electionlawblog.org/?cat=60>, voter
id<http://electionlawblog.org/?cat=9> | Comments Off
“Americans Elect sheds staff, delays voting till
May”<http://electionlawblog.org/?p=32819>
Posted on April 10, 2012 8:23 am<http://electionlawblog.org/?p=32819>
by Rick Hasen<http://electionlawblog.org/?author=3>

Politico
reports<http://www.politico.com/blogs/burns-haberman/2012/04/americans-elect-sheds-staff-delays-voting-till-may-120016.html>.
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32819&title=%E2%80%9CAmericans%20Elect%20sheds%20staff%2C%20delays%20voting%20till%20May%E2%80%9D&description=>
Posted in ballot access<http://electionlawblog.org/?cat=46>, third
parties<http://electionlawblog.org/?cat=47> | Comments Off
“The History of the Recall in
Wisconsin”<http://electionlawblog.org/?p=32816>
Posted on April 10, 2012 8:11 am<http://electionlawblog.org/?p=32816>
by Rick Hasen<http://electionlawblog.org/?author=3>

Christian Schneider writes this extensive
review<http://www.wpri.org/Reports/Volume25/Vol25No3/Vol25No3.html>.
[cid:image001.png at 01CD17E8.AA06B430]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D32816&title=%E2%80%9CThe%20History%20of%20the%20Recall%20in%20Wisconsin%E2%80%9D&description=>
Posted in recall elections<http://electionlawblog.org/?cat=11> |
Comments Off
--
Rick Hasen
Chancellor's Professor of Law and Political Science
UC Irvine School of Law
401 E. Peltason Dr., Suite 1000
Irvine, CA 92697-8000
949.824.3072<tel:949.824.3072> - office
949.824.0495<tel:949.824.0495> - fax
rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>
http://law.uci.edu/faculty/page1_r_hasen.html
http://electionlawblog.org

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