[EL] ELB News and Commentary 10/12/12

Rick Hasen rhasen at law.uci.edu
Fri Oct 12 09:56:13 PDT 2012


    About Those Wrong Precinct Provisional Ballots at Issue in Sixth
    Circuit Case... <http://electionlawblog.org/?p=41540>

Posted on October 12, 2012 9:53 am <http://electionlawblog.org/?p=41540> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Yesterday's Sixth Circuit ruling <http://electionlawblog.org/?p=41452>, 
requiring the counting of provisional ballots cast by voters at the 
right location but at the wrong precinct, is a big deal 
<http://www.dispatch.com/content/stories/local/2012/10/12/ruling-a-victory-for-counting-provisional-ballots.html>.  
But the provisional ballot issue is not entirely resolved.  We still 
don't know if OH AG DeWine will appeal on this issue to the Sixth 
Circuit en banc or to the Supreme Court (SOS Husted did not appeal this 
aspect of the case, and actually won 
<http://www.sos.state.oh.us/SOS/mediaCenter/2012/2012-10-11a.aspx> on 
the issue he appealed on).

But putting that aside, a knowledgeable reader points out another 
issue:  many wrongly cast provisional ballots are not covered by this 
order, because this covers only those cast at the right polling 
location. The reader writes:

    You said in your Slate piec
    <http://www.slate.com/articles/news_and_politics/jurisprudence/2012/10/ohio_voter_laws_the_battle_over_disenfranchisement_you_haven_t_heard_about_.html>e:
    "This 'right church, wrong pew' problem with precinct ballots was a
    big problem in 2008, when over 14,000 such ballots were cast."

    The 14,000+ number is/all/ wrong precinct ballots, not just those in
    the right church.  It's possible that only about 35% of all wrong
    precinct ballots will now be counted because of this decision.  In
    2008, 34% of Cuyahoga County's wrong precinct ballots were cast in
    the right polling place while 32% were cast in the right polling
    place in Hamilton County.  Source: Final Report
    <http://brennan.3cdn.net/9ccb57cb5de1711173_nkm6bqc3y.pdf#page=54>
    2008 -- 2009 Ohio Election Summit and Conference, Brennan Center.

    The 6th Circuit's decision today only ensures that right church
    ballots are counted and leaves open a window for wrong church
    ballots to be counted (but they say in Footnote 6 that that issue
    wasn't before them this time).

I appreciate the clarification.  It will be interesting to see if SEIU 
now asks for a broader order covering additional wrong precinct 
ballots.  Here's what fn. 6 of yesterday's opinion says: "Our ruling 
does not preclude the SEIU appellees or others from seeking broader 
relief for pollworker-induced wrong-place/wrong-precinct provisional 
ballots upon a showing that Ohio's law unconstitutionally burdens those 
voters' rights. As those issues are not before us, we express no view on 
their merits."

It will be important to get clarification on this issue /before/ 
Election Day, suggesting the case may not be over.

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
provisional ballots <http://electionlawblog.org/?cat=67>, The Voting 
Wars <http://electionlawblog.org/?cat=60> | Comments Off


    "New Report Says 2012 Presidential Primary Turnout Down; Should
    Election Geeks Worry?" <http://electionlawblog.org/?p=41537>

Posted on October 12, 2012 9:33 am <http://electionlawblog.org/?p=41537> 
by Rick Hasen <http://electionlawblog.org/?author=3>

A ChapinBlog 
<http://blog.lib.umn.edu/cspg/electionacademy/2012/10/new_report_says_2012_primary_t.php?utm_source=feedburner&utm_medium=twitter&utm_campaign=Feed%3A+HHHElections+%28The+Election+Aacdemy%29>.

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
voting <http://electionlawblog.org/?cat=31> | Comments Off


    "Video: Unions Fine Members Who Don't Show Support for Elizabeth
    Warren" <http://electionlawblog.org/?p=41534>

Posted on October 12, 2012 9:20 am <http://electionlawblog.org/?p=41534> 
by Rick Hasen <http://electionlawblog.org/?author=3>

The Weekly Standard reports. 
<http://www.weeklystandard.com/blogs/are-unions-fining-members-who-dont-support-warren_654203.html>

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Posted in campaigns <http://electionlawblog.org/?cat=59> | Comments Off


    "Brown-Warren Pact Undone as Outside Groups See Loopholes"
    <http://electionlawblog.org/?p=41531>

Posted on October 12, 2012 9:17 am <http://electionlawblog.org/?p=41531> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Bloomberg reports 
<http://www.bloomberg.com/news/2012-10-12/brown-warren-pact-undone-as-outside-groups-see-loopholes.html?alcmpid=politics>.

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Posted in campaign finance <http://electionlawblog.org/?cat=10> | 
Comments Off


    "Supreme Court Delays Until After Election Response Deadline in
    Major Disclosure Case" <http://electionlawblog.org/?p=41529>

Posted on October 12, 2012 9:17 am <http://electionlawblog.org/?p=41529> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Bloomberg BNA 
<http://news.bna.com/mpdm/MPDMWB/split_display.adp?fedfid=28370859&vname=mpebulallissues&jd=a0d4z1g7j0&split=0>: 
"The Supreme Court has put off until after the Nov. 6 election deciding 
whether to review the constitutionality of campaign finance disclosure 
rules for an organization that says it is focused on policy issues, not 
political campaigns. In an Oct. 11 order, the court extended an Oct. 12 
deadline for the government to respond to a challenge of Federal 
Election Commission disclosure requirements. The new deadline for a 
response is Nov. 13. The challenge comes in a long-running case brought 
by an anti-abortion organization called Real Truth About Abortion 
(RTAA), which wanted to sponsor political ads in 2008 targeting 
President Obama (Real Truth About Abortion v. FEC, U.S., No. 12-311, 
cert. petition filed 9/10/12; 3352 Money & Politics Report, 9/20/12 
<http://news.bna.com/mpdm/display/link_res.adp?fedfid=28370859&fname=a0d4r8q0v6&vname=mpebulallissues>)."

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Posted in Uncategorized <http://electionlawblog.org/?cat=1> | Comments Off


    "Confusion Sown in Pennsylvania by Lingering Voter-ID Ads"
    <http://electionlawblog.org/?p=41526>

Posted on October 12, 2012 9:14 am <http://electionlawblog.org/?p=41526> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Bloomberg reports. 
<http://www.bloomberg.com/news/2012-10-12/confusion-sown-in-pennsylvania-by-lingering-voter-id-ads.html?alcmpid=politics>

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
The Voting Wars <http://electionlawblog.org/?cat=60>, voter id 
<http://electionlawblog.org/?cat=9> | Comments Off


    Once More: On Election Crimes, Voter Fraud, Registration Fraud, and
    the Need for Voter ID <http://electionlawblog.org/?p=41523>

Posted on October 12, 2012 9:07 am <http://electionlawblog.org/?p=41523> 
by Rick Hasen <http://electionlawblog.org/?author=3>

In light of the O'Keefe circus, which no doubt will produce more hapless 
staffers apparently going along with O'Keefe operatives' suggestions of 
fake crimes, I thought this quick reminder/primer would be in order 
(much more detail on all of this in /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>/):

Here's what we know about in-person, impersonation fraud. Almost all the 
fraud that occurs in relation to election falls into three categories: 
election crimes committed by election officials (Cudahy 
<http://latimesblogs.latimes.com/lanow/2012/07/cudahy-corruption-election-fraud.html> 
is a recent colorful example), voter registration fraud (a la ACORN 
workers and now apparently Sproul workers---though there is still an 
investigation of those), and absentee ballot fraud. This usually occurs 
through vote buying and there are examples of such fraud in every 
election.  See Adam Liptak's recent piece 
<http://www.nytimes.com/2012/10/07/us/politics/as-more-vote-by-mail-faulty-ballots-could-impact-elections.html>.  
The Justice Dept. under Bush spent five years going after election 
crimes and voter fraud, and almost all the cases it found (I believe it 
was reported first as 86 and then as 120) fell into these categories. 
There were /no cases/ of in person, impersonation fraud---the primary 
type of fraud which a state voter id law can prevent.

For my book, I tried to find a single example of impersonation fraud at 
the polls, done without the cooperation of election officials (because a 
voter id law would not prevent that), in the last generation, where the 
results could arguably have been called into question by such fraud.  I 
could not find one.  Nor can those who tout the voter fraud claims find 
one.  Von Spakovsky pointed to what he called "extensive impersonation 
fraud" in a Heritage report (and related FOX News oped) based upon a 
1984 grand jury report <http://electionlawblog.org/?p=23572> from 
Brooklyn.  He stonewalled on giving me the report and when UCI 
librarians tracked it down it did not support his claim: the crimes were 
almost all by election officials and party officials.  (Note that crimes 
committed in the 1970s are particularly relevant to what is going on 
today in any case....).

News21 
<http://openchannel.nbcnews.com/_news/2012/08/11/13236464-new-database-of-us-voter-fraud-finds-no-evidence-that-photo-id-laws-are-needed>did 
a recent comprehensive study of all reports by prosecutors of election 
crimes since 2000.  They found only 10 prosecutions for impersonation 
fraud across the country (leading to what looks like 7 convictions), 
with none of them tied to any kind of conspiracy to steal the vote.  
This compares to 491 cases of absentee ballot fraud and 400 cases of 
registration fraud.  There is no reason to believe that impersonation 
fraud would be /harder/ to detect than these other kinds of fraud.  
Instead, because it would involve a conspiracy among a number of 
individuals going to the polls and claiming to be someone else listed on 
the polls (someone out of the area, or dead, or false 
registered---though we don't see case of that), it should be easier to 
detect.  The reason this kind of fraud doesn't happen except in very 
rare circumstances is that it is an exceedingly dumb way to steal an 
election.  Election official fraud and absentee ballot fraud are easier 
and therefore more prevalent.

There are cases of double voting across states, but state id laws are 
not the best way to catch that.  The best way is with a national id, 
which is something I'd support if it were coupled with universal voter 
registration done by the federal government.

I've written too about how it is very hard for plaintiffs in the voter 
id challenges (putting aside Pa., which did not have its act together in 
time) to find real eligible voters who (1) lack id; (2) would have 
trouble getting the id; and (3) want to vote.  There are some, and the 
question is one of cost and benefits: state voter id laws inconvenience 
a lot of people without much anti-fraud payoff.  And compare that to 
cutting back on absentee ballots to prevent that kind of fraud.   As I 
recently wrote 
<http://campaignstops.blogs.nytimes.com/2012/08/05/a-dtente-before-the-election/?ref=opinion>:

    Recently, officials
    <http://latimesblogs.latimes.com/lanow/2012/07/cudahy-corruption-election-fraud.html>
    in Cudahy, Calif., admitted intercepting absentee ballots and
    throwing out ballots not cast for incumbents. Every year we see
    convictions for absentee ballot fraud. Not a lot, but enough to know
    it's a problem.

    So you might think that Republicans, newly obsessed with voter
    fraud, would call for eliminating absentee ballots, or at least
    requiring that voters who use them show some need, like a medical
    condition. But Republicans don't talk much about reining in absentee
    ballots. Eliminating them would inconvenience some voters and would
    likely cut back on voting by loyal Republican voters, especially
    elderly and military voters.

    If only Republicans would apply that same logic to
    voter-identification laws. The only kind of fraud such ID laws
    prevent is impersonation: a person registered under a false name or
    claiming to be someone else on the voter rolls.

    I have not found a single election over the last few decades in
    which impersonation fraud had the slightest chance of changing an
    election outcome --- unlike absentee-ballot fraud, which changes
    election outcomes regularly. (Let's face it: impersonation fraud is
    an exceedingly dumb way <http://electionlawblog.org/?p=23053> to try
    to steal an election.)

    Pointing to a few isolated cases
    <http://electionlawblog.org/?p=33751> of impersonation fraud does
    not prove that a state identification requirement makes sense. As
    with restrictions on absentee ballots, we need to weigh the costs of
    imposing barriers on the right to vote against the benefits of fraud
    protection.

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
The Voting Wars <http://electionlawblog.org/?cat=60> | Comments Off


    ""Right Church, Wrong Pew" Ballots Must Count: a Cause for
    Celebration" <http://electionlawblog.org/?p=41521>

Posted on October 12, 2012 9:02 am <http://electionlawblog.org/?p=41521> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Ned Foley blogs 
<http://moritzlaw.osu.edu/electionlaw/freefair/index.php?ID=9859> on 
yesterday's Sixth Circuit decision.

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
provisional ballots <http://electionlawblog.org/?cat=67>, The Voting 
Wars <http://electionlawblog.org/?cat=60> | Comments Off


    Sherman-Berman May Be the Ugliest Congressional Race in America
    <http://electionlawblog.org/?p=41518>

Posted on October 12, 2012 9:00 am <http://electionlawblog.org/?p=41518> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Watch the video. 
<http://politicalwire.com/archives/2012/10/12/candidates_nearly_get_in_fight.html#050817a>

Talk about negativity as demobilizing.  I'm ready to not vote for either 
of these clowns in my district.

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Posted in campaigns <http://electionlawblog.org/?cat=59> | Comments Off


    "Why Can't You Vote Online?" <http://electionlawblog.org/?p=41515>

Posted on October 11, 2012 3:21 pm <http://electionlawblog.org/?p=41515> 
by Rick Hasen <http://electionlawblog.org/?author=3>

/The Verge/ reports 
<http://www.theverge.com/2012/10/11/3479170/why-cant-you-vote-online-elections-us>.

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internet voting <http://electionlawblog.org/?cat=49>, voting technology 
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    "Localist Statutory Interpretation"
    <http://electionlawblog.org/?p=41511>

Posted on October 11, 2012 2:34 pm <http://electionlawblog.org/?p=41511> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Ethan Leib has posted this draft 
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2159704> on SSRN 
(forthcoming, /U Pa. L. Rev./). Here is the abstract:

    This paper argues for more attention to citizens' point of contact
    with our legal system within local courts -- and makes an effort to
    conceptualize local judges as parts of local governments. Once the
    paper highlights the role of local courts within the constellation
    of local government, it offers an argument for why certain forms of
    "localist judging" are appropriate postures for local judges to take
    when confronted with hard cases of statutory interpretation. The
    paper explores the virtues of a type of "intrastate judicial
    federalism."

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Posted in statutory interpretation <http://electionlawblog.org/?cat=21> 
| Comments Off


    "Voter ID-Law Supporters Accuse Opponents Of Wanting Illegal Votes"
    <http://electionlawblog.org/?p=41508>

Posted on October 11, 2012 2:24 pm <http://electionlawblog.org/?p=41508> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Froomkin reports 
<http://www.huffingtonpost.com/2012/10/11/voter-id-supporters_n_1958935.html>.

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
The Voting Wars <http://electionlawblog.org/?cat=60> | Comments Off


    "Court rejects Ohio voting law on tossing ballots filed in wrong
    precincts" <http://electionlawblog.org/?p=41505>

Posted on October 11, 2012 2:04 pm <http://electionlawblog.org/?p=41505> 
by Rick Hasen <http://electionlawblog.org/?author=3>

CBS News reports. 
<http://www.cbsnews.com/8301-250_162-57530829/court-rejects-ohio-voting-law-on-tossing-ballots-filed-in-wrong-precincts/>

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
provisional ballots <http://electionlawblog.org/?cat=67>, The Voting 
Wars <http://electionlawblog.org/?cat=60> | Comments Off


    "LULAC Files Action Against Harris County, Texas to Stop
    Discriminatory Practices Aimed at Preventing Minorities From Voting"
    <http://electionlawblog.org/?p=41502>

Posted on October 11, 2012 2:02 pm <http://electionlawblog.org/?p=41502> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Seethis press release 
<http://www.campaignlegalcenter.org/index.php?option=com_content&view=article&id=1923:october-11-2012-lulac-files-action-against-harris-county-texas-to-stop-discriminatory-practices-aimed-at-preventing-minorities-from-voting&catid=63:legal-center-press-releases&Itemid=61>.

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Posted in The Voting Wars <http://electionlawblog.org/?cat=60>, voting 
<http://electionlawblog.org/?cat=31>, Voting Rights Act 
<http://electionlawblog.org/?cat=15> | Comments Off


    "Ohio Must Count Ballots Cast in Wrong Precinct"
    <http://electionlawblog.org/?p=41500>

Posted on October 11, 2012 1:54 pm <http://electionlawblog.org/?p=41500> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Roll Call reports 
<http://www.rollcall.com/news/ohio_must_count_ballots_cast_in_wrong_precinct-218155-1.html>.

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
provisional ballots <http://electionlawblog.org/?cat=67>, The Voting 
Wars <http://electionlawblog.org/?cat=60> | Comments Off


    Speaking About "The Voting Wars" at UCLA October 17
    <http://electionlawblog.org/?p=41497>

Posted on October 11, 2012 1:47 pm <http://electionlawblog.org/?p=41497> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Details here 
<http://www.acslaw.org/events/2012-10-17/the-voting-wars-from-florida-2000-to-the-next-election-meltdown>.

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Posted in The Voting Wars <http://electionlawblog.org/?cat=60> | 
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    "Politics to the Extreme: American Political Institutions in the
    21st Century" <http://electionlawblog.org/?p=41494>

Posted on October 11, 2012 1:44 pm <http://electionlawblog.org/?p=41494> 
by Rick Hasen <http://electionlawblog.org/?author=3>

I'll be commenting on a paper at this great event 
<http://polsci.csuci.edu/politicstotheextreme.htm> at CSU Channel 
Islands on Tuesday.  Looking forward to seeing my friends Norm Ornstein 
and Tom Mann, along with many others.  Here's the schedule 
<http://polsci.csuci.edu/documents/schedulev3.pdf>.

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Posted in political polarization <http://electionlawblog.org/?cat=68> | 
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    "Parties Prepare for Post-Election Legal Battles"
    <http://electionlawblog.org/?p=41491>

Posted on October 11, 2012 1:27 pm <http://electionlawblog.org/?p=41491> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Yes, in case you were wondering journalists, it is time for the armies 
of lawyers stories 
<http://www.rollcall.com/issues/58_28/Parties-Prepare-for-Post-Election-Legal-Battles-218128-1.html?pos=htmbtxt>.

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
The Voting Wars <http://electionlawblog.org/?cat=60> | Comments Off


    Ramesh Ponnuru on Fact Checking <http://electionlawblog.org/?p=41488>

Posted on October 11, 2012 1:24 pm <http://electionlawblog.org/?p=41488> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Interesting piece 
<http://www.nationalreview.com/articles/329964/he-lies-they-commanded-ramesh-ponnuru> 
(via Jonathan Adler 
<http://www.volokh.com/2012/10/11/the-fact-checkers-conceit/>).

I've been reading a lot of this stuff since I've been working on my 
campaign lies and the First Amendment paper 
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2151618>, and the 
debate over fact checking is fascinating!

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Posted in campaigns <http://electionlawblog.org/?cat=59> | Comments Off


    CNN Has a "Racial Voting Bloc Calculator" on Its Website
    <http://electionlawblog.org/?p=41485>

Posted on October 11, 2012 1:11 pm <http://electionlawblog.org/?p=41485> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Wonder what others will think of this. 
<http://www.cnn.com/interactive/2012/10/politics/voting-bloc-calculator/index.html?hpt=hp_t2>

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Posted in Uncategorized <http://electionlawblog.org/?cat=1> | Comments Off


    Is True the Vote More Bark Than Bite?
    <http://electionlawblog.org/?p=41482>

Posted on October 11, 2012 1:10 pm <http://electionlawblog.org/?p=41482> 
by Rick Hasen <http://electionlawblog.org/?author=3>

This piece is very important 
<http://prospect.org/article/whats-truth-about-true-vote>and strikes me 
as exactly right.  In fact, I was toying with writing a piece called 
"Who's Afraid of True the Vote?" but this beat me to it.

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Posted in The Voting Wars <http://electionlawblog.org/?cat=60> | 
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    "Washington group asks for Clear Channel to remove voter fraud
    billboards" <http://electionlawblog.org/?p=41479>

Posted on October 11, 2012 1:02 pm <http://electionlawblog.org/?p=41479> 
by Rick Hasen <http://electionlawblog.org/?author=3>

The /Plain Dealer/ reports. 
<http://www.cleveland.com/metro/index.ssf/2012/10/washington_group_asks_for_clea.html>

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Posted in The Voting Wars <http://electionlawblog.org/?cat=60> | 
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    "Ohio elections chief Jon Husted restricts methods to notify voters
    of absentee ballot errors" <http://electionlawblog.org/?p=41477>

Posted on October 11, 2012 1:00 pm <http://electionlawblog.org/?p=41477> 
by Rick Hasen <http://electionlawblog.org/?author=3>

Jon Husted 
<http://www.cleveland.com/open/index.ssf/2012/10/ohio_elections_chief_restricts.html> 
is starting 
<http://www.plunderbund.com/2012/10/08/jon-husted-forbids-boards-of-election-from-callingemailing-voters-about-absentee-ballot-mistakes/> 
to look a lot more like Ken Blackwell and Jennifer Brunner than I had 
hoped (h/t Maddowblog 
<http://maddowblog.msnbc.com/_news/2012/10/11/14372246-ohios-husted-loses-another-round-still-working-to-make-voting-harder?lite>).

And he's got more decisions to make as counties start deadlocking 
<http://www.toledoblade.com/Politics/2012/10/10/Husted-to-decide-last-3-days-early-vote-hours-in-Lucas-County.html> 
on early voting for those last three days, as ordered by the Sixth Circuit.

How about some uniformity there too?

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Posted in absentee ballots <http://electionlawblog.org/?cat=53>, 
election administration <http://electionlawblog.org/?cat=18>, The Voting 
Wars <http://electionlawblog.org/?cat=60> | Comments Off


    "States Roll Out and Expand Online Voter Registration, Increase
    Efficiencies" <http://electionlawblog.org/?p=41474>

Posted on October 11, 2012 12:00 pm 
<http://electionlawblog.org/?p=41474> by Rick Hasen 
<http://electionlawblog.org/?author=3>

Pew data dispatch 
<http://www.pewstates.org/research/analysis/states-roll-out-and-expand-online-voter-registration-increase-efficiencies-85899422920>.

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
voter registration <http://electionlawblog.org/?cat=37>, voting 
technology <http://electionlawblog.org/?cat=40> | Comments Off


    "Fightback on Voting Rights" <http://electionlawblog.org/?p=41471>

Posted on October 11, 2012 11:58 am 
<http://electionlawblog.org/?p=41471> by Rick Hasen 
<http://electionlawblog.org/?author=3>

Ari Berman writes 
<http://www.thenation.com/article/170493/fightback-voting-rights#> for 
/The Nation./

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
The Voting Wars <http://electionlawblog.org/?cat=60>, voting 
<http://electionlawblog.org/?cat=31>, Voting Rights Act 
<http://electionlawblog.org/?cat=15> | Comments Off


    "DNC Fires Employee Featured In James O'Keefe Video"
    <http://electionlawblog.org/?p=41468>

Posted on October 11, 2012 11:55 am 
<http://electionlawblog.org/?p=41468> by Rick Hasen 
<http://electionlawblog.org/?author=3>

TPM 
<http://tpmmuckraker.talkingpointsmemo.com/2012/10/dnc_fires_employee_james_okeefe_video.php?ref=fpnewsfeed>: 
"The Democratic National Committee on Wednesday fired a Texas staffer 
who appeared to offer to help someone figure out how to vote 
simultaneously in two states in undercover video released by 
conservative activist James O'Keefe."

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Posted in chicanery <http://electionlawblog.org/?cat=12>, The Voting 
Wars <http://electionlawblog.org/?cat=60> | Comments Off


    "In a super PAC world, Democrats win using small donors"
    <http://electionlawblog.org/?p=41465>

Posted on October 11, 2012 11:36 am 
<http://electionlawblog.org/?p=41465> by Rick Hasen 
<http://electionlawblog.org/?author=3>

The Fix reports 
<http://www.washingtonpost.com/blogs/the-fix/wp/2012/10/11/in-a-super-pac-world-democrats-win-using-small-donors/>.

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Posted in campaign finance <http://electionlawblog.org/?cat=10> | 
Comments Off


    In the Ohio Early Voting Case, Is it Better for SCOTUS to Be
    Unanimous Than Right? <http://electionlawblog.org/?p=41462>

Posted on October 11, 2012 11:26 am 
<http://electionlawblog.org/?p=41462> by Rick Hasen 
<http://electionlawblog.org/?author=3>

Ned Foley makes the case 
<http://moritzlaw.osu.edu/electionlaw/freefair/index.php?ID=9855>.

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
The Voting Wars <http://electionlawblog.org/?cat=60>, voting 
<http://electionlawblog.org/?cat=31> | Comments Off


    "Tribal members sue for voting access"
    <http://electionlawblog.org/?p=41459>

Posted on October 11, 2012 11:23 am 
<http://electionlawblog.org/?p=41459> by Rick Hasen 
<http://electionlawblog.org/?author=3>

News 
<http://missoulian.com/news/state-and-regional/tribal-members-sue-for-voting-access/article_5c0576e8-13b1-11e2-bdfd-001a4bcf887a.html#> 
from Montana: "A group of American Indians from the Crow, Northern 
Cheyenne and Fort Belknap reservations sued state and county election 
officials in federal court on Wednesday, seeking equal access to voting 
through satellite offices."

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<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D41459&title=%E2%80%9CTribal%20members%20sue%20for%20voting%20access%E2%80%9D&description=About%20Those%20Wrong%20Precinct%20Provisional%20Ballots%20at%20Issue%20in%20Sixth%20Circuit%20Case%E2%80%A6%0APosted%20on%20October%2012%2C%202012%209%3A53%20am%20by%20Rick%20Hasen%0A%0AYesterday%E2%80%99s%20Sixth%20Circuit%20ruling%2C%20requiring%20the%20counting%20of%20provisional%20ballots%20cast%20by%20voters%20at%20the%20right%20location%20but%20at%20the%20wrong%20precinct%2C%20is%20a%20big%20deal.%20%20But%20the%20provisional%20ballot%20issue%20is%20not%20entirely%20resolved.%20%20We%20still%20don%E2%80%99t%20know%20if%20OH%20AG%20DeWine%20will%20appeal%20on%20this%20issue%20to%20the%20Sixth%20Circuit%20en%20banc%20or%20to%20the%20S>
Posted in election administration <http://electionlawblog.org/?cat=18>, 
voting <http://electionlawblog.org/?cat=31>, Voting Rights Act 
<http://electionlawblog.org/?cat=15> | Comments Off


    "Election administration issues on ballot in several states"
    <http://electionlawblog.org/?p=41456>

Posted on October 11, 2012 11:19 am 
<http://electionlawblog.org/?p=41456> by Rick Hasen 
<http://electionlawblog.org/?author=3>

That's the lead story in this week's Electionline Weekly. 
<http://www.electionline.org/index.php/electionline-weekly>

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<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D41456&title=%E2%80%9CElection%20administration%20issues%20on%20ballot%20in%20several%20states%E2%80%9D&description=About%20Those%20Wrong%20Precinct%20Provisional%20Ballots%20at%20Issue%20in%20Sixth%20Circuit%20Case%E2%80%A6%0APosted%20on%20October%2012%2C%202012%209%3A53%20am%20by%20Rick%20Hasen%0A%0AYesterday%E2%80%99s%20Sixth%20Circuit%20ruling%2C%20requiring%20the%20counting%20of%20provisional%20ballots%20cast%20by%20voters%20at%20the%20right%20location%20but%20at%20the%20wrong%20precinct%2C%20is%20a%20big%20deal.%20%20But%20the%20provisional%20ballot%20issue%20is%20not%20entirely%20resolved.%20%20We%20still%20don%E2%80%99t%20know%20if%20OH%20AG%20DeWine%20will%20appeal%20on%20this%20issue%20to%20the%20Sixth%20Circuit%20en%20banc%20or%20to%20the%20S>
Posted in election administration <http://electionlawblog.org/?cat=18> | 
Comments Off


    Breaking News: Sixth Circuit Decides Provisional Ballot Cases, Finds
    Constitutional Violation in Not Counting Certain Wrong Precinct
    Ballots <http://electionlawblog.org/?p=41452>

Posted on October 11, 2012 9:32 am <http://electionlawblog.org/?p=41452> 
by Rick Hasen <http://electionlawblog.org/?author=3>

The Sixth Circuit has decided /SEIU v. Husted 
<http://www.ca6.uscourts.gov/opinions.pdf/12a0359p-06.pdf>/ and /NEOCH 
v. Husted/ in a single opinion.

This is the most important decision in this election cycle, and it 
represents a major victory for voters' rights, regardless of party.  It 
is especially important because this was a very conservative Sixth 
Circuit panel, and it affirms the idea that /Bush v. Gore/ and Sixth 
Circuit precedent requires some degree of uniformity and fairness in the 
counting of ballots.  My worst fears about this case, expressed in this 
/Slate /piece 
<http://www.slate.com/articles/news_and_politics/jurisprudence/2012/10/ohio_voter_laws_the_battle_over_disenfranchisement_you_haven_t_heard_about_.html>, 
have fortunately not been realized.

The procedural history and issues in this case are complicated, and one 
aspect of the opinion is being sent back to the lower court for 
clarification and to make sure an earlier remedy does not create its own 
"Bush v. Gore problem" (in the 6th Circuit's words), but the main point 
is this: it violates the Constitution (equal protection and due process) 
for the state of Ohio to fail to count ballots cast in the right 
location but in the wrong precinct solely because of poll worker error.  
As I stated in my Slate piece: "This is crazy. Amid all the fights over 
voter ID laws 
<http://www.post-gazette.com/stories/local/state/appeals-judge-set-to-rule-on-legitimacy-of-pas-new-voter-id-law-655226/>, 
purging noncitizens 
<http://articles.chicagotribune.com/2012-09-27/news/sns-rt-us-usa-campaign-voting-floridabre88q1qo-20120927_1_integrity-of-florida-elections-voter-rolls-state-ken-detzner> 
from voter rolls, and early 
<http://www.businessweek.com/news/2012-09-24/florida-needn-t-expand-early-voting-hours-judge-rules> 
voting 
<http://www.businessweek.com/news/2012-08-31/ohio-early-voting-days-must-be-equal-for-all-u-dot-s-dot-judge-rules>, 
we should at least be able to agree, across partisan lines, on one 
thing: No one should lose the right to vote because a poll worker can't 
tell an odd from an even number."

Today the panel agreed.  Two excerpts:

    The application of Ohio Rev. Code §§ 3505.183(B)(4)(a)(ii) and
    (B)(4)(b)(ii) to right-place/wrong-precinct ballots caused by
    poll-worker error effectively requires voters to have a greater
    knowledge of their precinct, precinct ballot, and polling place than
    poll workers. Absent such omniscience, the State will permanently
    reject their ballots without an opportunity to cure the situation.
    The mere fact that these voters cast provisional ballots does not
    justify this additional burden; as the district court explained,
    Ohio law now requires thirteen different categories of voters to
    cast provisional ballots, ranging from individuals who do not have
    an acceptable form of identification to those who requested an
    absentee ballot or whose signature was deemed by the precinct
    official not to match the name on the registration forms....

    Nor has the State shown abuse in the district court's fashioning of
    injunctive relief tailored to the identified harm. The State would
    disqualify thousands of rightplace/wrong-precinct provisional
    ballots, where the voter's only mistake was relying on the
    poll-worker's precinct guidance. That path unjustifiably burdens
    these voters' fundamental right to vote. Recognizing that a
    prospective remedy could not undo all of the harm occasioned by
    poll-worker error, the district court crafted a narrow remedy that
    preserves as much of a miscast ballot as possible.

The state could now try to go to the en banc Sixth Circuit or to the 
Supreme Court.  But this ruling has got to be right, and I hope the 
state leaves this alone and does not go further.  I also think this 
opinion can be very important as precedent in future cases in stopping 
the most egregious poor treatment of voters going forward.

Share 
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Posted in election administration <http://electionlawblog.org/?cat=18>, 
provisional ballots <http://electionlawblog.org/?cat=67>, The Voting 
Wars <http://electionlawblog.org/?cat=60> | 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
Now available: The Voting Wars: http://amzn.to/y22ZTv

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