[EL] Montana/Danielczyk

[Steve Hoersting]

Ah, Rick, you might prefer to look at this way:  Judge Cacheris was just
"taking Justice Kennedy at his word" (government may not discriminate
against speakers on the basis of their identity, including their corporate
identity) and "Occupy[ing
*Beaumont]*."<http://www.slate.com/articles/news_and_politics/politics/2012/02/justice_ruth_bader_ginsburg_is_ready_to_speak_out_on_the_danger_of_super_pacs_.html?fb_ref=sm_fb_plugin_activity>

There's something for everyone to appreciate in the Montana and
*Danielczyk*cases.

Steve


On Wed, Feb 22, 2012 at 5:29 PM, Rick Hasen <rhasen at law.uci.edu> wrote:

>  Fair point that this was not your direct argument--though it was the
> clear implication of it.  But I stand by my comment as to the district
> court's decision in Danielczyk.  It is illogical and perverse to give *
> greater* first amendment rights to for-profit corporations than to
> non-profits.
>
>
> On 2/22/2012 2:23 PM, Joe La Rue wrote:
>
> But our amicus did not assert that government should be able to limit
> for-profit corporate general fund contributions to candidates. That may be
> where the logic of the district court decision leads, but that was not the
> argument Jim and I made. Rather, we asserted that *Beaumont *was not
> controlling precedent because it addressed only the question of nonprofit
> corporate contributions, which was not the issue in *Danielczyk*.
> Therefore, we argued, the district court was free to follow the
> speech-vindicating logic of *Citizens United*: Government may not
> discriminate against speakers on the basis of their identity, including
> their corporate identity.
>
> Again, your link is addressing the district court's ruling. It is not
> addressing the arguments that Jim and I raised.
>
> Joe
> ___________________
> *Joseph E. La Rue, Esq.*
>  cell: 513.509.6494
> email: joseph.e.larue at gmail.com
>
>
> CONFIDENTIALITY NOTICE:  This e-mail message, including any attachments,
> is for the sole use of the intended recipient(s) and may contain
> confidential and privileged information or otherwise be protected by law.
> Any unauthorized review, use, disclosure or distribution is prohibited. If
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>
>
>
> On Wed, Feb 22, 2012 at 5:19 PM, Rick Hasen <rhasen at law.uci.edu> wrote:
>
>>  I linked to my post below explaining why it is perverse, but perhaps
>> you did not click on it (or choose to respond to it):
>>
>>  The Perverse Holding of Danielczyk <http://electionlawblog.org/?p=18888>
>> Posted on June 8, 2011 7:43 am <http://electionlawblog.org/?p=18888> by Rick
>> Hasen <http://electionlawblog.org/?author=3>
>>
>> In response to my query in this post<http://electionlawblog.org/?p=18851>,
>> a few readers have said that the opinion means it is unconstitutional to
>> limit the direct contributions of *for-profit* corporations to
>> candidates, but it remains constitutional under the controlling authority
>> of *Beaumont* to limit the direct contributions of *ideological,
>> non-profit* corporations.
>>
>> Of course, as my readers point out, if this is what it means, it is a
>> perverse holding: those groups which should be entitled to the *most *First
>> Amendment protections (even under *Austin* and before *Citizens United, *such
>> groups could spend their treasury funds independently on candidate
>> campaigns) get the *least* protection.
>>
>>
>> On 2/22/2012 2:16 PM, Joe La Rue wrote:
>>
>> Rick, I had the privilege of assisting Jim with the amicus he filed in
>> Danielczyk. I would hardly call our argument "perverse." We simply pointed
>> out the narrow nature of the holding, which has been overlooked by nearly
>> everyone else. The only question presented in Beaumont was whether the
>> First Amendment requires that issue advocacy corporations be exempted from
>> generally-applicable bans on corporate speech. The speech ban itself was
>> never at issue, as the Court recognized in its opinion. Rather, the
>> question was very narrow, and so the holding was very narrow, too.
>>
>> Pointing that out, and explaining that Beaumont did not actually uphold
>> the federal ban on corporate general-fund speech, hardly seems "perverse."
>>
>> Joe
>> ___________________
>> *Joseph E. La Rue, Esq.*
>>  cell: 513.509.6494
>> email: joseph.e.larue at gmail.com
>>
>>
>> CONFIDENTIALITY NOTICE:  This e-mail message, including any attachments,
>> is for the sole use of the intended recipient(s) and may contain
>> confidential and privileged information or otherwise be protected by law.
>> Any unauthorized review, use, disclosure or distribution is prohibited. If
>> you are not the intended recipient, please contact the sender by reply
>> e-mail and destroy all copies of the original message.
>>
>>
>>
>> On Wed, Feb 22, 2012 at 5:11 PM, Rick Hasen <rhasen at law.uci.edu> wrote:
>>
>>>  And then it should have been the same in Danielczyk, but you argued to
>>> the contrary, trying to distinguish the case in a way that was perverse<http://electionlawblog.org/?p=18888>to the reasoning of the underlying
>>> *Beaumont* case.
>>>
>>> Rick
>>>
>>> On 2/22/2012 2:05 PM, JBoppjr at aol.com wrote:
>>>
>>>  Oh, double please!
>>>  Montana Supreme Court Campaign finance Decision Affront to the “Rule
>>> of Law”? <http://electionlawblog.org/?p=30349>
>>> Posted on February 22, 2012 11:06 am<http://electionlawblog.org/?p=30349>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> That’s Allen Dickerson’s claim <http://bit.ly/yKlU2z>.  Oh please.  The
>>> Montana Supreme Court took Justice Kennedy at his word
>>> <http://www.slate.com/articles/news_and_politics/jurisprudence/2012/01/montana_supreme_court_citizens_united_can_montana_get_away_with_defying_the_supreme_court_.html>and
>>> looked at the state’s evidence of corruption to justify its law.  That
>>> might be wrong—but it is not defying the rule of law.
>>>
>>> Even Justice Ginsburg and Breyer voted to stay the Montana Supreme Court
>>> decision "Because lower courts are bound to follow this Court’s decisions
>>> until they are withdrawn or modified," So the Montana Supreme Court was
>>> bound to strike the statute under *CU* and they refused.  This is an
>>> affront to the rule of law.  Jim Bopp
>>>   In a message dated 2/22/2012 4:33:27 P.M. Eastern Standard Time,
>>> rhasen at law.uci.edu writes:
>>>
>>>  “Michigan Democratic Party encourages crossover voting in GOP
>>> presidential primary” <http://electionlawblog.org/?p=30361>
>>> Posted on February 22, 2012 1:31 pm<http://electionlawblog.org/?p=30361>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> The Fix<http://www.washingtonpost.com/blogs/the-fix/post/michigan-democratic-party-encourages-crossover-voting-in-gop-presidential-primary/2012/02/22/gIQA1qjoTR_blog.html>:
>>> “Operation Chaos in Michigan? Again? The Michigan Democratic Party sent an
>>> e-mail to supporters Wednesday encouraging them to take part in the state’s
>>> Republican presidential primary on Tuesday.”
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30361&title=“Michigan
>>> Democratic Party encourages crossover voting in GOP presidential primaryâ€
>>> &description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30361&title=%E2%80%9CMichigan%20Democratic%20Party%20encourages%20crossover%20voting%20in%20GOP%20presidential%20primary%E2%80%9D&description=>
>>>  Posted in chicanery <http://electionlawblog.org/?cat=12>, political
>>> parties <http://electionlawblog.org/?cat=25>, primaries<http://electionlawblog.org/?cat=32>
>>> | Comments Off
>>>  “Federal Appeals Court Rules That N.M. Violated Federal Law, Failing
>>> to Provide Voter Registration Applications to Public Assistance Clients”<http://electionlawblog.org/?p=30358>
>>> Posted on February 22, 2012 1:28 pm<http://electionlawblog.org/?p=30358>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> See this press release<http://projectvote.org/newsreleases/798-federal-appeals-court-rules-that-nm-violated-federal-law-failing-to-provide-voter-registration-applications-to-public-assistance-clients.html>about this
>>> new opinion. <http://www.ca10.uscourts.gov/opinions/11/11-2063.pdf>
>>> From the release:, “The federal Tenth Circuit Court of Appeals ruled
>>> yesterday that the State of New Mexico Human Services Department (HSD)
>>> violated Section 7 of the National Voter Registration Act of 1993 (NVRA) by
>>> improperly withholding voter registration applications from certain public
>>> assistance clients. The decision came in a federal lawsuit brought against
>>> state officials by a coalition voting rights groups and attorneys,
>>> including the Lawyers’ Committee for Civil Rights Under Law, Project Vote,
>>> and Dēmos; the Albuquerque law firm of Freedman Boyd Hollander Goldberg
>>> Ives & Duncan, and the law firm of DLA Piper, on behalf of Albuquerque
>>> resident Shawna Allers. This major development concerned the HSD policy of
>>> providing a voter registration application to a public assistance client
>>> only if the client specifically requests an application. Section 7 requires
>>> New Mexico and most other states to offer voter registration to public
>>> assistance clients when they apply for benefits, periodically recertify
>>> their benefits eligibility, or submit a change of address for receipt of
>>> benefits. Along with HSD officials, the New Mexico Secretary of State
>>> shares responsibility for ensuring that State agencies comply with the
>>> NVRA.”
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30358&title=“Federal
>>> Appeals Court Rules That N.M. Violated Federal Law, Failing to Provide
>>> Voter Registration Applications to Public Assistance Clientsâ€
>>> &description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30358&title=%E2%80%9CFederal%20Appeals%20Court%20Rules%20That%20N.M.%20Violated%20Federal%20Law%2C%20Failing%20to%20Provide%20Voter%20Registration%20Applications%20to%20Public%20Assistance%20Clients%E2%80%9D&description=>
>>>  Posted in election administration <http://electionlawblog.org/?cat=18>,
>>> NVRA (motor voter) <http://electionlawblog.org/?cat=33>, voter
>>> registration <http://electionlawblog.org/?cat=37> | Comments Off
>>>  “88% of Obama’s Itemized Donors in January Were Repeaters; 40% of
>>> Romney’s Donors Have Maxed Out; Santorum, Gingrich, Paul, and Obama Strong
>>> with Small Donors” <http://electionlawblog.org/?p=30355>
>>> Posted on February 22, 2012 1:19 pm<http://electionlawblog.org/?p=30355>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> Must-read<http://cfinst.org/Press/PReleases/12-02-22/88_of_Obama%E2%80%99s_Itemized_Donors_in_January_Were_Repeaters_40_of_Romney%E2%80%99s_Donors_Have_Maxed_Out.aspx>CFI press release.
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30355&title=“88%
>>> of Obama’s Itemized Donors in January Were Repeaters; 40% of Romney’s
>>> Donors Have Maxed Out; Santorum, Gingrich, Paul, and Obama Strong with
>>> Small Donors†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30355&title=%E2%80%9C88%25%20of%20Obama%E2%80%99s%20Itemized%20Donors%20in%20January%20Were%20Repeaters%3B%2040%25%20of%20Romney%E2%80%99s%20Donors%20Have%20Maxed%20Out%3B%20Santorum%2C%20Gingrich%2C%20Paul%2C%20and%20Obama%20Strong%20with%20Small%20Donors%E2%80%9D&description=>
>>>  Posted in campaign finance <http://electionlawblog.org/?cat=10> | Comments
>>> Off
>>>  “Does Money Corrupt the Political Process?”<http://electionlawblog.org/?p=30352>
>>> Posted on February 22, 2012 11:36 am<http://electionlawblog.org/?p=30352>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> Kevin Drum blogs<http://motherjones.com/kevin-drum/2012/02/does-money-corrupt-political-process>
>>> .
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30352&title=“Does
>>> Money Corrupt the Political Process?†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30352&title=%E2%80%9CDoes%20Money%20Corrupt%20the%20Political%20Process%3F%E2%80%9D&description=>
>>>  Posted in campaign finance <http://electionlawblog.org/?cat=10> | Comments
>>> Off
>>>  Montana Supreme Court Campaign finance Decision Affront to the “Rule
>>> of Law”? <http://electionlawblog.org/?p=30349>
>>> Posted on February 22, 2012 11:06 am<http://electionlawblog.org/?p=30349>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> That’s Allen Dickerson’s claim <http://bit.ly/yKlU2z>.  Oh please.  The
>>> Montana Supreme Court took Justice Kennedy at his word
>>> <http://www.slate.com/articles/news_and_politics/jurisprudence/2012/01/montana_supreme_court_citizens_united_can_montana_get_away_with_defying_the_supreme_court_.html>and
>>> looked at the state’s evidence of corruption to justify its law.  That
>>> might be wrong—but it is not defying the rule of law.
>>>
>>> Want to talk about defying the rule of law?  Look at the district court
>>> decision <http://electionlawblog.org/?p=18848> in the *Danielczyk* case
>>> (now on appeal to the 4th Circuit), defying Supreme Court precedent on the
>>> constitutionality of limits on corporate contributions to candidates.  (
>>> Here <http://electionlawblog.org/?p=26906>‘s the 2d Circuit on that
>>> opinion: The Court is aware of United States v. Danielczyk, No. 1:11cr85
>>> (JCC), 2011 WL 2161794 (E.D. Va. May 26, 2011), which struck down a ban on
>>> corporate contributions, based on what it called an ‘inescapable’ expansion
>>> of Citizen United’s logic. Id. at *18; Danielczyk, 2011 WL 2268063 (E.D.
>>> Va. June 7, 2011) (denying reconsideration)*. The role of an appellate
>>> court is to apply to law as it exists. Since the Supreme Court reaffirmed
>>> the validity of the 100-year old corporate ban just 8 years ago, Beaumont,
>>> 539 U.S. at 154-55, and declined to overrule this holding in Citizens
>>> United, this Court will not do so here*. Indeed, Citizens United
>>> confirms that the anti-corruption interest is a legitimate justification
>>> for campaign contribution restrictions. Citizens United also does not
>>> disturb the validity of the anti-circumvention interest. See Thalheimer v.
>>> City of San Diego, Nos. 10-55322, 10-55324, 10-55434, 2011 WL 2400779, at
>>> *13 (9th Cir. Jun. 9, 2011) (concluding that ‘nothing in the explicit
>>> holdings or broad reasoning’ of Citizens United invalidates the
>>> anti-circumvention interest in the context of contribution limits)”)
>>>
>>> In the end, it will be up to the Supreme Court to weigh in in both the
>>> Montana case and the question in *Danielczyk*.
>>>
>>> [Disclosure: I am an attorney for the City of San Diego in the *Thalheimer
>>> *case, where the corporate contribution issue is presented.]
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30349&title=Montana
>>> Supreme Court Campaign finance Decision Affront to the “Rule of Lawâ€
>>> ?&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30349&title=Montana%20Supreme%20Court%20Campaign%20finance%20Decision%20Affront%20to%20the%20%E2%80%9CRule%20of%20Law%E2%80%9D%3F&description=>
>>>  Posted in Uncategorized <http://electionlawblog.org/?cat=1> | Comments
>>> Off
>>>  “Election law changes are ‘in really uncharted territory’”<http://electionlawblog.org/?p=30344>
>>> Posted on February 22, 2012 7:58 am<http://electionlawblog.org/?p=30344>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> The latest <http://www.the-daily-record.com/news/article/5159744> from
>>> the voting wars in Ohio.  MORE<http://www.alternet.org/story/154190/backfired%21_4_ways_the_ohio_gop_tilts_voting_rules_but_ends_up_helping_democrats/>from Jennifer Brunner at AlterNet.
>>>
>>>
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30344&title=“Election
>>> law changes are ‘in really uncharted territory’†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30344&title=%E2%80%9CElection%20law%20changes%20are%20%E2%80%98in%20really%20uncharted%20territory%E2%80%99%E2%80%9D&description=>
>>>  Posted in election administration <http://electionlawblog.org/?cat=18>,
>>> The Voting Wars <http://electionlawblog.org/?cat=60> | Comments Off
>>>  Murphy and von Spakovsky Debate Voter ID at National Press Club<http://electionlawblog.org/?p=30341>
>>> Posted on February 22, 2012 7:39 am<http://electionlawblog.org/?p=30341>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> Laura Murphy of the ACLU debates<http://www.press.org/events/status-and-impact-new-state-voter-id-laws>Hans von Spakovsky of the Heritage Foundation at the National Press Club
>>> tomorrow.  [No webcast.]
>>>
>>> I tell some amusing stories about Hans von Spakovsky’s research and
>>> scholarship in this area in the “Fraudulent Fraud Squad” sneak preview<http://www.amazon.com/Fraudulent-Fraud-Squad-Understanding-ebook/dp/B00795X5XI/ref=zg_bs_157417011_9>chapter of my forthcoming book,
>>> *The Voting Wars*<http://www.amazon.com/Voting-Wars-Florida-Election-Meltdown/dp/0300182031/ref=sr_1_cc_2?s=aps&ie=UTF8&qid=1329286945&sr=1-2-catcorr>.
>>> You can also take a trip down memory lane with other members of the squad,
>>> including Thor Hearne, John Fund, Matthew Vadum, Dick Armey, Michelle
>>> Malkin, and Bradley Schlozman.
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30341&title=Murphy
>>> and von Spakovsky Debate Voter ID at National Press Club&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30341&title=Murphy%20and%20von%20Spakovsky%20Debate%20Voter%20ID%20at%20National%20Press%20Club&description=>
>>>  Posted in chicanery <http://electionlawblog.org/?cat=12>, 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
>>>  “The Supreme Court and Citizens United II”<http://electionlawblog.org/?p=30339>
>>> Posted on February 22, 2012 7:35 am<http://electionlawblog.org/?p=30339>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> An NYT editorial.<http://www.nytimes.com/2012/02/22/opinion/the-supreme-court-and-citizens-united-take-2.html?_r=1>
>>> My Slate piece<http://www.slate.com/articles/news_and_politics/politics/2012/02/justice_ruth_bader_ginsburg_is_ready_to_speak_out_on_the_danger_of_super_pacs_.html?fb_ref=sm_fb_plugin_activity>
>>> (which now has 1,000 “likes” on Facebook [I don't think that's happened
>>> before])  expresses similar sentiments about the Montana case.
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30339&title=“The
>>> Supreme Court and Citizens United II†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30339&title=%E2%80%9CThe%20Supreme%20Court%20and%20Citizens%20United%20II%E2%80%9D&description=>
>>>  Posted in campaign finance <http://electionlawblog.org/?cat=10> | Comments
>>> Off
>>>  “Only sensible campaign reform: Real-time reporting”<http://electionlawblog.org/?p=30337>
>>> Posted on February 22, 2012 7:29 am<http://electionlawblog.org/?p=30337>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> Jon Ralson has written this column<http://www.lasvegassun.com/news/2012/feb/22/only-sensible-campaign-reform-real-time-reporting/?hpp>.
>>> If only those people <http://mcconnell.senate.gov/public/>who used to
>>> say<http://thinkprogress.org/politics/2010/08/03/111030/mcconnell-disclose/>they supported full, instant disclosure and no limits would not have
>>> abandoned their position after *Citizens United*, we might be able to
>>> fix the disclosure problem.
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30337&title=“Only
>>> sensible campaign reform: Real-time reporting†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30337&title=%E2%80%9COnly%20sensible%20campaign%20reform%3A%20Real-time%20reporting%E2%80%9D&description=>
>>>  Posted in campaign finance <http://electionlawblog.org/?cat=10> | Comments
>>> Off
>>>  “Super PAC Money Getting More Scrutiny, Complaints”<http://electionlawblog.org/?p=30334>
>>> Posted on February 22, 2012 7:25 am<http://electionlawblog.org/?p=30334>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> Eliza Newlin Carney reports<http://www.rollcall.com/news/super_pac_money_getting_more_scrutiny_complaints_rick_santorum-212571-1.html?pos=htmbtxt>for
>>> *Roll Call*.
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30334&title=“Super
>>> PAC Money Getting More Scrutiny, Complaints†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30334&title=%E2%80%9CSuper%20PAC%20Money%20Getting%20More%20Scrutiny%2C%20Complaints%E2%80%9D&description=>
>>>  Posted in campaign finance <http://electionlawblog.org/?cat=10> | Comments
>>> Off
>>>  “Postal cutbacks and the voting process”<http://electionlawblog.org/?p=30332>
>>> Posted on February 22, 2012 7:24 am<http://electionlawblog.org/?p=30332>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> The *SF Chronicle *reports<http://www.sfgate.com/cgi-bin/article.cgi?f=/c/a/2012/02/18/INLN1MNT7G.DTL>
>>> .
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30332&title=“Postal
>>> cutbacks and the voting process†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30332&title=%E2%80%9CPostal%20cutbacks%20and%20the%20voting%20process%E2%80%9D&description=>
>>>  Posted in election administration <http://electionlawblog.org/?cat=18>
>>> | Comments Off
>>>  “Secretary of State Mark Ritchie offers Voter ID alternative:
>>> electronic poll books” <http://electionlawblog.org/?p=30330>
>>> Posted on February 22, 2012 7:23 am<http://electionlawblog.org/?p=30330>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> MinnPost reports.<http://www.minnpost.com/political-agenda/2012/02/secretary-state-mark-ritchie-offers-voter-id-alternative-electronic-poll-bo>
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30330&title=“Secretary
>>> of State Mark Ritchie offers Voter ID alternative: electronic poll booksâ€
>>> &description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30330&title=%E2%80%9CSecretary%20of%20State%20Mark%20Ritchie%20offers%20Voter%20ID%20alternative%3A%20electronic%20poll%20books%E2%80%9D&description=>
>>>  Posted in election administration <http://electionlawblog.org/?cat=18>,
>>> voter id <http://electionlawblog.org/?cat=9> | Comments Off
>>>  “Justice Kennedy Unlikely to Budge on ‘Citizens United’”<http://electionlawblog.org/?p=30328>
>>> Posted on February 22, 2012 7:22 am<http://electionlawblog.org/?p=30328>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> Matt Taylor reports<http://nationalmemo.com/article/justice-kennedy-unlikely-budge-citizens-united>for the National Memo.
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30328&title=“Justice
>>> Kennedy Unlikely to Budge on ‘Citizens United’†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30328&title=%E2%80%9CJustice%20Kennedy%20Unlikely%20to%20Budge%20on%20%E2%80%98Citizens%20United%E2%80%99%E2%80%9D&description=>
>>>  Posted in campaign finance <http://electionlawblog.org/?cat=10> | Comments
>>> Off
>>>  “The Electoral College Explained” <http://electionlawblog.org/?p=30325>
>>> Posted on February 22, 2012 7:20 am<http://electionlawblog.org/?p=30325>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> ABC News reports<http://abcnews.go.com/Politics/video/electoral-college-is-explained-by-author-kenneth-c-davis-15482102>
>>> .
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30325&title=“The
>>> Electoral College Explained†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30325&title=%E2%80%9CThe%20Electoral%20College%20Explained%E2%80%9D&description=>
>>>  Posted in electoral college <http://electionlawblog.org/?cat=44> | Comments
>>> Off
>>>  “Juvenile judge race goes back to court”<http://electionlawblog.org/?p=30323>
>>> Posted on February 22, 2012 7:19 am<http://electionlawblog.org/?p=30323>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> The *Hunter* case <http://electionlawblog.org/?s=hunter>, a significant
>>> *Bush v. Gore* sequel, heads back<http://news.cincinnati.com/apps/pbcs.dll/article?AID=/201202211849/NEWS0106/302210150>to the Sixth Circuit, thanks to a partisan tie broken by Ohio SOS Jon
>>> Husted.
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30323&title=“Juvenile
>>> judge race goes back to court†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30323&title=%E2%80%9CJuvenile%20judge%20race%20goes%20back%20to%20court%E2%80%9D&description=>
>>>  Posted in election administration <http://electionlawblog.org/?cat=18>
>>> | Comments Off
>>>  “Campaign Finance in the 2012 Elections: The Rise of Super PACs”<http://electionlawblog.org/?p=30320>
>>> Posted on February 22, 2012 7:16 am<http://electionlawblog.org/?p=30320>
>>> by Rick Hasen <http://electionlawblog.org/?author=3>
>>>
>>> Brookings is holding this event<http://www.brookings.edu/events/2012/0301_super_pacs.aspx>March 1 with Tom Mann, Tony Corrado, and Trevor Potter.  It will be webcast
>>> as well.
>>>  [image:
>>> http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=30320&title=“Campaign
>>> Finance in the 2012 Elections: The Rise of Super PACs†&description=]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D30320&title=%E2%80%9CCampaign%20Finance%20in%20the%202012%20Elections%3A%20The%20Rise%20of%20Super%20PACs%E2%80%9D&description=>
>>>  Posted in campaign finance <http://electionlawblog.org/?cat=10> | 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 - office
>>> 949.824.0495 - fax
>>> rhasen at law.uci.edu
>>> http://law.uci.edu/faculty/page1_r_hasen.html
>>> http://electionlawblog.org
>>>
>>>
>>> _______________________________________________
>>> Law-election mailing list
>>> Law-election at department-lists.uci.edu
>>> http://department-lists.uci.edu/mailman/listinfo/law-election
>>>
>>>
>>> --
>>> 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 - office
>>> 949.824.0495 - fax
>>> rhasen at law.uci.edu
>>> http://law.uci.edu/faculty/page1_r_hasen.html
>>> http://electionlawblog.org
>>>
>>> _______________________________________________
>>> Law-election mailing list
>>> Law-election at department-lists.uci.edu
>>> http://department-lists.uci.edu/mailman/listinfo/law-election
>>>
>>
>>
>> --
>> 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 - office
>> 949.824.0495 - fax
>> rhasen at law.uci.edu
>> http://law.uci.edu/faculty/page1_r_hasen.html
>> http://electionlawblog.org
>>
>
>
> --
> 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 - office
> 949.824.0495 - fax
> rhasen at law.uci.edu
> http://law.uci.edu/faculty/page1_r_hasen.html
> http://electionlawblog.org
>
> _______________________________________________
> Law-election mailing list
> Law-election at department-lists.uci.edu
> http://department-lists.uci.edu/mailman/listinfo/law-election
>



-- 
Stephen M. Hoersting
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