[EL] Check out F.D.A. Surveillance of Scientists Spread to Outside Critic...
Rick Hasen
rhasen at law.uci.edu
Mon Jul 16 08:31:04 PDT 2012
Enough already of the unsupported claims of massive harassment. These
were tested in Court. Here's the relevant portion of the trial court's
decision granting summary judgment against Jim's clients on this
issue. I've put in bold some of the more relevant findings.
ProtectMarriage.com v. Bowen
830 F.Supp.2d 914
E.D.Cal.,2011.
November 04, 2011 (Approx. 34 pages)
Moreover, while Plaintiffs are quite correct that under /Buckley/
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evidence of harassment "from either Government officials or private
parties" could suffice to establish the requisite proof of reprisals,
the facts of subsequent cases evidence not only the existence of some
governmental hostility, but quite pervasive governmental hostility at
that. /Buckley,/ 424 U.S. at 74, 96 S.Ct. 612
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(emphasis added); /see also //McArthur,/ 716 F.Supp. at 594
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("[H]arassment, reprisals or threats from private persons are sufficient
to allow [the] court to enforce the plaintiff's first amendment rights
by cloaking the contributors and recipients' names in secrecy.").
Indeed, the /Brown/
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Court was confronted with countless acts of government harassment and
retribution against members of the SWP, which are detailed above.
Furthermore, in /Hall--Tyner,/
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the Second Circuit stated, "[t]he evidence relied on by the district
judge included the extensive body of state and federal legislation
subjecting Communist Party members to civil disability and criminal
liability, reports and affidavits documenting the history of
governmental surveillance and harassment of Communist Party members, as
well as affidavits indicating the desire of contributors to the
Committee to remain anonymous." 678 F.2d at 419
<http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=350&rs=WLW12.04&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2026501938&serialnum=1982123204&vr=2.0&fn=_top&sv=Split&tf=-1&referencepositiontype=S&pbc=154255A8&referenceposition=419&utid=1>.
*Plaintiffs do not, indeed cannot, allege that the movement to recognize
marriage in California as existing only between a man and a woman is
vulnerable to the same threats as were socialist and communist groups,
or, for that matter, the NAACP. Proposition 8 supporters *932 promoted a
concept entirely devoid of governmental hostility. Plaintiffs' belief in
the traditional concept of marriage, to disagreement, have not
historically invited animosity. The Court is at a loss to find any
principled analogy between two such greatly diverging sets of
circumstances.*
*Finally, Plaintiffs' exemption argument appears to be premised, in
large part, on the concept that individuals should be free from even
legal consequences of their speech. That is simply not the nature of
their right.*
Just as contributors to Proposition 8 are free to speak in favor of the
initiative, so are opponents free to express their disagreement through
proper legal means.
**17 *While the Court is cognizant of the deplorable nature of many of
acts alleged by Plaintiffs, the Court also must reiterate that the
legality or morality of any specific acts is not before it. Thus, as
much as the Court strongly condemns the behavior of those who resort to
violence, and/or other illegal behavior, the Court need not, indeed
cannot, evaluate the proper legal consequences of those actions today.*
By the same token, nothing in the Court's decision immunizes or excuses
those who have engaged in illegal acts from the consequences of their
conduct. Those responsible for threatening the lives of supporters of
Proposition 8 are subject to criminal liability. See Troupis Decl., Exh.
C (noting that the Fresno chief of police stated the department was
"close to making an arrest" in the case of the death threats delivered
to the mayor and a local pastor.) Those choosing to vandalize the
property of individuals or the public are likewise liable. Those mailing
white powder to organizations are subject to federal prosecution. In
each case, there are appropriate legal channels through which to rectify
and deter the reoccurrence of such reprehensible behavior.
As much *as those channels are available today, it is unlikely that
groups previously successful in seeking exemptions were privy to the
same opportunities. Again, Plaintiffs have shown no societal or
governmental hostility to their cause. Contrary to groups such as the
SWP, Plaintiffs can seek adequate relief from law enforcement and the
legal system. *Such was not the case for those thought to be supporting
the SWP or communist groups, those subject to actual criminal liability
based on their beliefs and their associations.
/ProtectMarriage.com,/ 599 F.Supp.2d at 1217--1218
<http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=4637&rs=WLW12.04&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2026501938&serialnum=2018198951&vr=2.0&fn=_top&sv=Split&tf=-1&referencepositiontype=S&pbc=154255A8&referenceposition=1217&utid=1>.
Despite Plaintiffs attempt now to put forth additional evidence of
threats, harassment and reprisals, the Court's findings remain the same.
More specifically, despite the additional declarations and exhibits that
are now before the Court, Plaintiffs still run into problems of
proportionality and magnitude.
*First, while Plaintiffs characterize their evidence as voluminous and
comprised of "virtually countless reports of threats, harassment, and
reprisals," Plaintiffs' Motion, 4:14--15, they have pointed to
relatively few incidents allegedly suffered by persons located across
the entire country who had somehow manifested their support for
traditional marriage. * In addition, while the evidence before this
Court indicates that at least 7 million voters showed up at the
California polls alone to support the passage of Proposition 8, this
number, though large, still deceptively underestimates the number of
supporters for Plaintiffs' cause. Indeed, this figure does not capture
all individuals supporting Proposition 8 on a national scale, nor does
it capture those individuals who may have no connection to California's
campaign, but *933 have supported the same cause in other regions.
Plaintiffs' evidence of harassment, nonetheless extends much farther
than California's borders and includes incidents that arose in other
states and that were directed at the much broader social issue of gay
marriage in general.
**18 Accordingly, even assuming Plaintiffs could, under some set of
circumstances, prove an entitlement to an exemption, they would need
evidence of thousands of acts of reprisals, threats or harassment,
spanning much more than the short period of time covering California's
ballot-initiative process to prove contributors to such a massive group
are entitled to anonymity of the type justified years ago for the
individuals in /Brown/
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and /NAACP./
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The declarations of 58 individuals signed in the months just following
the election, along with Plaintiffs' anecdotal evidence from the same
time period as documented in Exhibits 3 and 4, is simply insufficient on
the facts of this case to convince this Court an ordinary contributor to
Proposition 8 would have faced any backlash worthy of quashing the names
of all contributors.^FN9
<http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=Find&rp=%2fFind%2fdefault.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+5507204&rs=WLW12.04#B00992026501938>/See,
e.g., / /Doe v. Reed,/ 130 S.Ct. at 2829
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(taking the position exemptions may be permitted "in the rare
circumstance in which disclosure poses a reasonable probability of
serious and widespread harassment") (Sotomayor, J., concurring-joined by
Stevens and Ginsburg).
FN9.
<http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=Find&rp=%2fFind%2fdefault.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+5507204&rs=WLW12.04#F00992026501938>*Plaintiffs
even acknowledge in their papers that only a minority of individuals
on the other side of the campaign resorted to the complained of
tactics that are cause for concern. Plaintiffs' Motion, 1:10--12
("Some groups and individuals, /certainly a minority,/ have resorted
to advancing their cause, not by debating the merits of the issue,
but by discouraging participation in the democratic process through
acts calculated to intimidate.") (emphasis added).*
[2]
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Headnote Citing References
<http://web2.westlaw.com/KCNotes/default.wl?mt=LawSchoolPractitioner&locatestring=HD%28002%29%2cCL%28H%2cO%29%2cDC%28A%2cL%2cO%2cD%2cG%29%2cDT%28E%2cD%2cC%2cM%29&utid=1&n=1&rlt=CLID_FQRLT799262410167&service=Find&pbc=154255A8&rp=%2fKCNotes%2fdefault.wl&vr=2.0&rlti=1&sv=Split&fn=_top&serialnum=2026501938&rs=WLW12.04>*Moreover,
as the Court previously observed, notably absent from the record here
are any instances in which Plaintiffs have suffered any sort of
governmental backlash.* While, based on the language derived from
/Buckley,/
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governmental harassment is not necessarily a required showing, it is a
factor for this Court to consider. Indeed, some governmental animosity
has been present in all other cases in which an exemption has been
permitted. Perhaps recognizing this, Plaintiffs argue "[t]here can be no
question that in many areas in California, and around the country, views
against same-sex marriage ... are extremely unpopular" and "[e]ven our
courts of law have characterized those who fight against such laws as
advocates of hate and bigotry who act 'without reason.' " Plaintiffs'
Motion, 12:15--18. Nonetheless, any attempt by Plaintiffs to show
governmental animosity here is half-hearted at best. As described above,
parties entitled to an as-applied exemption (namely the NAACP and the
SWP) in the past had suffered from systematic governmental
discrimination, persecution and abuse. Those plaintiffs were not only
directly victimized by the government, they consequently lacked adequate
recourse to pursue means short of non-disclosure to protect against
private violence. In this case, Plaintiffs cannot assert that there is
some sort of governmental hostility to their cause, nor can they in good
conscience argue that law enforcement was or would be non-responsive to
any illegal acts directed at Plaintiffs contributors.^FN10
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FN1*0.*
<http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=Find&rp=%2fFind%2fdefault.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+5507204&rs=WLW12.04#F010102026501938>*Plaintiffs
do argue that their contributors were victimized despite existing
laws criminalizing the underlying conduct. Essentially, Plaintiffs
argue those laws did nothing to deter criminal behavior. However,
Plaintiffs have not alleged that any law enforcement response was
insufficient, that law enforcement has somehow turned a blind eye to
any criminal conduct, or that criminal sanctions will not be imposed
if appropriate. That is a critical distinction between the instant
case and past cases such as /Brown/
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and /NAACP./*
*934 To the contrary, Plaintiffs' own evidence indicates law enforcement
was not only responsive, but diligent in undertaking investigations into
some of the more heinous acts alleged here. This factor is critical in
light of the comments made by several concurring Justices in /Doe v.
Reed,/ indicating the ability of law enforcement to deal with threats,
harassment and reprisals would weigh heavily against a need for an
exemption. /See, e.g.,/ /Doe,/ 130 S.Ct. at 2829
<http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2026501938&serialnum=2022366335&vr=2.0&fn=_top&sv=Split&tf=-1&referencepositiontype=S&pbc=154255A8&referenceposition=2829&utid=1>
(exemption may be warranted "in the rare circumstance in which
disclosure poses a reasonable probability of serious and widespread
harassment that the State is unwilling or unable to control")
(Sotomayor, J., concurring, joined by Stevens and Ginsburg); /id./ at
2831
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("From time to time throughout history, persecuted groups have been able
to criticize oppressive practices and laws either anonymously or not at
all ... In my view, this is unlikely to occur in cases involving the
PRA. Any burden on speech that petitioners posit is speculative as well
as indirect. For an as-applied challenge to a law such as the PRA to
succeed, there would have to be a significant threat of harassment
directed at those who sign the petition that cannot be mitigated by law
enforcement measures.") (Stevens and Breyer, JJ., concurring); /id./ at
2837
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("There are laws against threats and intimidation; and harsh criticism,
short of unlawful action, is a price our people have traditionally been
willing to pay for self-governance.") (Scalia, J., concurring).
**19 I*n addition, the vast majority of the incidents cited by
Plaintiffs are arguably, as characterized by Defendants, typical of any
controversial campaign. For example, picketing, protesting, boycotting,
distributing flyers, destroying yard signs and voicing dissent do not
necessarily rise to the level of "harassment" or "reprisals," especially
in comparison to acts directed at groups in the past. Moreover, a good
portion of these actions are themselves forms of speech protected by the
United States Constitution.* Indeed this Court previously held that:
[T]he Court simply cannot ignore the fact that numerous of the acts
about which Plaintiffs complain are mechanisms relied upon, both
historically and lawfully, to voice dissent. The decision and ability to
patronize a particular establishment or business is an inherent right of
the American people, and the public has historically remained free to
choose where to, or not to, allocate its economic resources. As such,
individuals have repeatedly resorted to boycotts as a form of civil
protest intended to convey a powerful message without resort to
non-violent means. The Supreme Court has acknowledged these rights on
many an occasion:
In /Thornhill v. Alabama,/ 310 U.S. 88, 60 S.Ct. 736, 84 L.Ed. 1093
(1940)
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the Court held that peaceful picketing was entitled to constitutional
protection, even though, in that case, the purpose of the picketing "was
concededly to advise customers and prospective customers of the
relationship existing between the employer and its employees and thereby
to induce such customers not to patronize the employer." /Id./ at 99, 60
S.Ct. 736.
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/Cf. //Chauffeurs v. Newell,/ 356 U.S. 341, 78 S.Ct. 779, 2 L.Ed.2d 809
[ (1958) ]
<http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2026501938&serialnum=1958207756&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1>.
In /Edwards v. South Carolina,/ 372 U.S. 229, 83 S.Ct. 680, 9 L.Ed.2d
697 [ (1963) ],
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we held that a peaceful march and demonstration was protected by the
rights of free speech, free assembly, and freedom to petition for a
redress of grievances.
/NAACP v. Claiborne Hardware Co.,/ 458 U.S. 886, 909, 102 S.Ct. 3409, 73
L.Ed.2d 1215 (1982)
<http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2026501938&serialnum=1982130119&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1>.
Notably, "[s]peech does not lose its protected character ... simply
because it may embarrass others or *935 coerce them into action." /Id./
at 910, 102 S.Ct. 3409.
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/ProtectMarriage.com,/ 599 F.Supp.2d at 1218
<http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=4637&rs=WLW12.04&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2026501938&serialnum=2018198951&vr=2.0&fn=_top&sv=Split&tf=-1&referencepositiontype=S&pbc=154255A8&referenceposition=1218&utid=1>.
*As to Plaintiffs' allegations of "economic reprisals" in the form of
voluntary or forced resignations, as opposed to cases in which a
relatively high percentage of small groups seeking an exemption were
actually fired from their places of employment, Plaintiffs here have
documented no terminations. /See, e.g.,/ SWP. Rather, Plaintiffs point
only to instances of several individuals who allegedly resigned amidst
controversy over their contributions to or support of Proposition 8, but
even those individuals had their own supporters and nonetheless made the
affirmative and individual decision to resign.*
More troubling here are the few instances of violence or criminal
activity that do not fall within the realm of protected speech. The
Court does not take lightly the use of the mail to terrorize people with
counterfeit biological agents or to threaten the lives of individuals
taking a stand for their particular beliefs, nor does the Court condone
the use of force or the escalation of peaceful protests to violence to
make one's position known. ^FN11
<http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=Find&rp=%2fFind%2fdefault.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+5507204&rs=WLW12.04#B011112026501938>*However,
Plaintiffs have produced insufficient evidence that the more incendiary
events on which they rely were connected to Proposition 8 or to gay
marriage at all.* Rather, a number of these incidents were directed at
the Mormon church, which, though a backer of California's proposition,
may also have been a target for any of a number of other reasons. In
addition, as stated above, law enforcement appears to have responded
swiftly and adequately in each of the instances Plaintiffs allege,
rendering this case distinguishable from all cases in the past where
exemptions have been granted. And, perhaps more importantly, the Supreme
Court has never indicated that even a few acts of violence, when
directed at a target as massive as the groups supporting Plaintiffs,
would suffice to shield those groups from the scrutinizing light of the
political process.
FN11.
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To the contrary, those resorting to these sorts of tactics do more
to undermine their cause than to further any civilized and
productive discourse.
**20 [3]
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Headnote Citing References
<http://web2.westlaw.com/KCNotes/default.wl?mt=LawSchoolPractitioner&locatestring=HD%28003%29%2cCL%28H%2cO%29%2cDC%28A%2cL%2cO%2cD%2cG%29%2cDT%28E%2cD%2cC%2cM%29&utid=1&n=1&rlt=CLID_FQRLT799262410167&service=Find&pbc=154255A8&rp=%2fKCNotes%2fdefault.wl&vr=2.0&rlti=1&sv=Split&fn=_top&serialnum=2026501938&rs=WLW12.04>This
Court also observes that, even assuming there is no "strict" requirement
that Plaintiffs prove a chilling effect on anticipated speech, any such
effect is notably absent here. Plaintiffs appear to have had no problem
collecting contributions and those contributions continued to increase
even during the most heated portions of the Proposition 8 campaign.
Cassady Decl., ¶¶ 24--25. A few John Doe declarants mentioned they may
be wary of donating in the future, but those relatively few individual
statements are unpersuasive to the Court given Plaintiffs' enormous
multi-state backing. Plaintiffs have therefore simply not shown any real
chill, nor have they shown, as feared by /Buckley,/
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that Plaintiffs' movement was at all susceptible to a fall-off in
contributions or that, absent an exemption, the movement might not
survive. /Buckley,/ 424 U.S. at 71, 96 S.Ct. 612
<http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2026501938&serialnum=1976142308&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1>.
Finally, this case is unique because Plaintiffs' contributors' names
were actually disclosed years ago and yet Plaintiffs have produced
almost no evidence of any ramifications suffered in the almost three
years post-disclosure. While the evidence contained in Plaintiffs'
Exhibits 3 and 4 contain a few instances of vandalism that have occurred
more recently than during the height of the Proposition 8 campaign and
its aftermath, none of those articles draw any real connection between
the incidents alleged and the victims' support of traditional marriage.
/See, e.g.,/ Plaintiffs' Exhs. 4--89, 4--90, 4--91, 4--93. Even
Plaintiffs'*936 counsel at oral argument in 2011 admitted he was only
aware of one instance of harassment that had occurred post-election.
Accordingly, from a practical perspective, it makes no sense to buy in
to the argument that disclosure /may/ result in repercussions when there
is simply no real evidence in the record that such repercussions
actually /did/ occur in the past three years. Plaintiffs' evidence is,
quite simply, stale. /See //Doe v. Reed,/ 823 F.Supp.2d 1195, 1205 n. 3,
2011 WL 4943952 at *10 n. 3 (W.D.Wash.2011)
<http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=0000999&rs=WLW12.04&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2026501938&serialnum=2026358710&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1>.
Accordingly, while Plaintiffs can point to a relatively few unsavory
acts committed by extremists or criminals, these acts are so small in
number, and in some instances their connection to Plaintiffs' supporters
so attenuated, that they do not show a reasonable probability
Plaintiffs' contributors will suffer the same fate. Given the grand
scale of Plaintiffs' campaign and the massive (and national) support
they garnered for their cause, Plaintiffs' limited evidence is simply
insufficient to support a finding that disclosure of contributors' names
will lead to threats, harassment or reprisals.^FN12
<http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=Find&rp=%2fFind%2fdefault.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+5507204&rs=WLW12.04#B012122026501938>Plaintiffs'
Motion for Summary Judgment as to this claim is DENIED and Defendants'
Motion for Summary Judgment is GRANTED.
FN12.
<http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=Find&rp=%2fFind%2fdefault.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+5507204&rs=WLW12.04#F012122026501938>
It bears mention that if the Court were to find an exemption warranted
here, it is likely a similar exemption would prove warranted in any
election concerning a controversial ballot measure. As a result, those
issues in which the public shows the greatest interest would be subject
to the least transparency.
On 7/16/2012 6:34 AM, JBoppjr at aol.com wrote:
> Of course not, this involved scientific critics of the FDA. The point
> is that government officials will go after critics however they find
> out about them and using the methods they have available.
> Regarding campaign contribution, in Doe v. Reed and the Prop 8 case,
> we document over 250 incidents of harassment of supporters of Prop 8,
> many of which were only contributors who were map quested on the
> Internet. A campaign of harassment that occurred against them is
> unusual. Public officials that retaliate against critics are usually
> very careful to make sure that no one knows they are doing it. The
> FDA did not send out a press release on their actions against their
> scientific critics either. Jim Bopp
> In a message dated 7/15/2012 11:03:48 P.M. Eastern Daylight Time,
> rhasen at law.uci.edu writes:
>
> I didn't see any evidence in this article that anyone was being
> harassed for making campaign contributions, and as we've discussed
> on this list /ad nauseum/ (and as spelled out in more detail here
> <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1948313>), my
> view of the evidence from two recent cases involving allegations
> of harassment of campaign contributors is that there is no
> systemic evidence that harassment of campaign contributors is a
> problem. Rare instances of genuine threats of harassment may be
> dealt with through an "as applied" exemption to disclosure laws.
>
>
>
> On 7/15/12 8:06 AM, Joe La Rue wrote:
>> It is interesting that Van Hollen is upset about THIS disclosure.
>> Of course, he was number 14 on the list. I guess disclosure is
>> only good when it's somebody else's speech that is being disclosed.
>>
>> On Jul 15, 2012, at 6:28 AM, JBoppjr at aol.com
>> <mailto:JBoppjr at aol.com> wrote:
>>
>>> Click here: F.D.A. Surveillance of Scientists Spread to Outside
>>> Critics - NYTimes.com
>>> <http://www.nytimes.com/2012/07/15/us/fda-surveillance-of-scientists-spread-to-outside-critics.html?_r=2&pagewanted=all>
>>>
>>> Government going after critics, exactly the type of activity
>>> that can chill political speech and that makes disclosure a
>>> burden. Jim Bopp
>>> _______________________________________________
>>> Law-election mailing list
>>> Law-election at department-lists.uci.edu
>>> <mailto: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
> Pre-order /The Voting Wars/: http://amzn.to/y22ZTv
>
>
--
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
Pre-order The Voting Wars: http://amzn.to/y22ZTv
www.thevotingwars.com
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