[EL] ELB News and Commentary 8/9/13
Rick Hasen
rhasen at law.uci.edu
Wed Aug 7 21:34:00 PDT 2013
Texas Ups the Ante in Fight Over Voting Rights Act, Betting on An
Emboldened Conservative Supreme Court
<http://electionlawblog.org/?p=54118>
Posted on August 7, 2013 9:28 pm <http://electionlawblog.org/?p=54118>
by Rick Hasen <http://electionlawblog.org/?author=3>
I recently wrote
<http://www.law.com/jsp/nlj/PubArticleNLJ.jsp?id=1202613130666&thepage=1>in
/NLJ/ about AG Holder's Texas-sized gambit: to get Texas covered again
under a preclearance regime using section 3 of the Voting Rights Act.
It's a move that is risky both legally and politically, for reasons I
explain in the earlier piece and do not repeat here.
Still, I was struck by the boldness of the State of Texas filing
<http://electionlawblog.org/sblog.s3.amazonaws.com/wp-content/uploads/2013/08/Texas-reply-on-Sec.-3-of-VRA-8-5-13.pdf>
opposing bail in. Texas made the arguments I expected it to make: about
the burden on those seeking preclearance to prove intentional
discrimination being high, the inappropriateness of relying upon
findings of intentional discrimination in a different court
opinion---especially one that has been vacated, etc. (See Lyle
Denniston's summary
<http://www.scotusblog.com/2013/08/texas-fights-new-voting-supervision/#more-168201>of
Texas's filing.)
But Texas made a bigger argument too, and it one that may make it back
to the Supreme Court where, for reasons I will explain, the Court may
accept it.
In a nutshell, Texas argues that even if it is guilty of recent
intentional discrimination on the basis of race against minority voters
(a point which of course if vigorously denies), it cannot be bailed into
a preclearance regime under section 3. Texas argues that the Supreme
Court's recent opinion in /Shelby County/ bars the use of the
preclearance regime against it or any state unless the state has engaged
in conduct as bad as Southern states did in the 1960s before the Voting
Rights Act (e.g., racially discriminatory poll taxes, failure to stop
violence against African Americans at the polling place, etc.), such a
remedy would be an unconstitutional application of Congress's powers to
enforce the 14th or 15th Amendments. Texas says that /Shelby County/
requires that any remedy be "congruent and proportional"
<http://joshblackman.com/blog/2013/08/07/texas-argues-congruent-and-proportional-standard-applies-to-vra-section-3-bail-ins/>
to current racial discrimination, and that a preclearance remedy is too
strong even with evidence of current racism unless the racism is
"flagrant" and "pervasive."
To me, this is a clear overreading of /Shelby County/. Recall that in
/Shelby County/ the Court majority surprisingly and unjustifiably (given
its prominence in /NAMUDNO/) failed either to apply or reject the
"congruence and proportionality test" for Congressional power. I flagged
the curious omissionthe day the opinion issued
<http://www.scotusblog.com/2013/06/the-curious-disappearance-of-boerne-and-the-future-jurisprudence-of-voting-rights-and-race/>
and wrote about it more in my APSA paper
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2291612>. The Court
just sidestepped the issue. And the Court pointedly failed to strike
down the preclearance remedy as a whole, leaving Justice Thomas to
complain that the majority was delaying the inevitable. That left
Section 3 untouched as a legal matter. To say that /Shelby County/ bars
the use of preclearance under any circumstances absent proof of flagrant
pervasive discrimination is unsupported by any fair reading of the
decision itself. This is especially true because section 3 bail-in
requires proof of /current/ discrimination, the key point//upon which
/Shelby County /struck down the coverage formula of section 4, and it
further gives any court asked to approve bail-in the discretion to
fashion the /extent/ of the preclearance remedy to match the scope of
the state's violation.//
But despite Texas's overreach, Texas could well find a receptive
audience at the Supreme Court. Look at what happened this summer: the
Supreme Court struck down a key provision of the Voting Rights Act and
little happened. Sure, the Justices took a hit in public opinion among
African Americans and liberal voters. But there are no large protests in
the streets. There does not even seem to me to be the same general level
of public outrage that there was about the Supreme Court's /Citizens
United/ decision from 2010.
Now there are a number of reasons why we have not seen a public outcry.
The day after /Shelby County /came the gay rights decisions, which
pleased some liberals and diffused some of the anger at the Court. (Some
suggested that the Court issued its decisions in this order for this
reason.) Liberal whites seem less angered about this decision than one
about money in politics. The public may not be paying attention
yet---VRA preclearance is a pretty arcane issue, compared to pointing to
Sheldon Adelson or the Koch brothers as convenient poster children for
the /Citizens United /era.
Whatever the reason, the fact that the sky did not fall after /Shelby
County/ could lead Justice Kennedy and Chief Justice Roberts to feel
comfortable going further---maybe to get rid of preclearance all
together (or reject its application to Texas---and if not to Texas then
to whom?). And wait for affirmative action next term, and the coming
challenges to Section 2 of the Voting Rights Act, and part of the Civil
Rights Act. And once the Roberts Court feels its days are numbered,
things may move more quickly.
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Posted in Supreme Court <http://electionlawblog.org/?cat=29>, Voting
Rights Act <http://electionlawblog.org/?cat=15> | Comments Off
Only in America <http://electionlawblog.org/?p=54115>
Posted on August 7, 2013 8:44 pm <http://electionlawblog.org/?p=54115>
by Rick Hasen <http://electionlawblog.org/?author=3>
Texas defends itself
<http://electionlawblog.org/sblog.s3.amazonaws.com/wp-content/uploads/2013/08/Texas-reply-on-Sec.-3-of-VRA-8-5-13.pdf>against
claims it discriminated against minority voters by claiming it
discriminated against Democrats (p. 19):
DOJ's accusations of racial discrimination are baseless. In 2011,
both houses of the Texas Legislature were controlled by large
Republican majorities, and their redistricting decisions were
designed to increase the Republican Party's electoral prospects at
the expense of the Democrats. It is perfectly constitutional for a
Republican-controlled legislature to make partisan districting
decisions, even if there are incidental effects on minority voters
who support Democratic candidates.
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Posted in political parties <http://electionlawblog.org/?cat=25>,
political polarization <http://electionlawblog.org/?cat=68>, Voting
Rights Act <http://electionlawblog.org/?cat=15> | Comments Off
"Libertarian Party of Colorado sues Secretary Gessler to allow
nomination of Recall Successor Candidates"
<http://electionlawblog.org/?p=54110>
Posted on August 7, 2013 8:21 pm <http://electionlawblog.org/?p=54110>
by Rick Hasen <http://electionlawblog.org/?author=3>
The following press release arrived via email: [update: read the
complaint
<http://electionlawblog.org/wp-content/uploads/Recall-Complaint-Final.pdf>]
*Libertarian Party of Colorado sues Secretary Gessler to allow
nomination of Recall Successor Candidates*
Denver, Colorado --- The Libertarian Party of Colorado has filed
suit today for emergency relief in Denver District Court against
Colorado Secretary of State Scott Gessler for violating provisions
of the Colorado Constitution that provide fair access to the ballot
by all qualified candidates.
On July 22, Secretary Gessler issued an emergency rule concerning
recall successor candidates for Senate District 11 (Colorado
Springs) and Senate District 3 (Pueblo), requiring a 10 day deadline
for nominating petitions in a recall election. However, Article XXI
of the Colorado Constitution allows any qualified candidate the
right to submit completed nominating petitions up to 15 days in
advance of the election date.
"It is clear that this hasty rule by the Secretary of State
conflicts with the Constitution, and we have filed suit to ensure
that we have the full time granted by the people of Colorado," says
Libertarian Party State Chair, Jeff Orrok, adding, "We oppose any
attempt by the legislative or executive branches to deny our
candidates, our members, and the voters of Districts 3 and 11 their
fundamental rights and the ability to choose the best replacements
for these overreaching senators."
Co-plaintiffs in the suit include Richard Anglund of Pueblo and
Gordon Butt of Colorado Springs, but other potential candidates
stand to benefit as well. The Libertarian Party stands for equal
access to the ballot by all candidates regardless of affiliation.
"Unlike some in the two major parties who have sought to shut out
candidates from other parties --- and even some from within their
own ranks --- all we seek is a level playing field and adherence to
the Constitution, " remarked Orrok.
The Libertarian Party anticipates an immediate hearing and is
confident the court will rule in its favor, since there is a body of
case law that supports its position. If the judge rules in the
plaintiffs' favor, they expect the Secretary of State to be ordered
to accept nominating petitions through Monday, August 26 and the
county clerks to be ordered not to distribute ballots without the
inclusion of candidates who submit sufficient signatures by that date.
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Posted in ballot access <http://electionlawblog.org/?cat=46>, recall
elections <http://electionlawblog.org/?cat=11> | Comments Off
Quote of the Day <http://electionlawblog.org/?p=54107>
Posted on August 7, 2013 8:17 pm <http://electionlawblog.org/?p=54107>
by Rick Hasen <http://electionlawblog.org/?author=3>
"I had many people tell me after that ruling that they were so
depressed, they couldn't get out of bed...I told them to get up out the
bed."
---Barbara Arnwine, Lawyers Committee for Civil Rights Under Law,
speaking to Tony Mauro
<http://link.law.com/5162e78534b9b0a8048a3dce13pnj.1um/UgKyv8JSz041yhYFA7462>about
/Shelby County. /She blamed "the leadership of Chief Justice Roberts"
for the decision.
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Posted in Supreme Court <http://electionlawblog.org/?cat=29>, Voting
Rights Act <http://electionlawblog.org/?cat=15> | Comments Off
"Push for Satellite Voting Centers Intensifies"
<http://electionlawblog.org/?p=54103>
Posted on August 7, 2013 8:10 pm <http://electionlawblog.org/?p=54103>
by Rick Hasen <http://electionlawblog.org/?author=3>
/Rapid City Journal/
<http://rapidcityjournal.com/news/local/push-for-satellite-voting-centers-intensifies/article_4b3007a2-9868-5be1-aac1-5635687c10df.html>:
<http://rapidcityjournal.com/news/local/push-for-satellite-voting-centers-intensifies/article_4b3007a2-9868-5be1-aac1-5635687c10df.html>
Tribal-voting advocates are pressuring South Dakota Secretary of
State Jason Gant to approve the release of federal funds for
satellite voting centers to serve Native American voters in 2014.
Four Directions Inc., a Native American voting rights group based on
the Rosebud Sioux Reservation, asked the U.S. Department of Justice
on Tuesday to investigate Gant's refusal to release Help America
Vote Act funds for voting centers at Wanblee, Eagle Butte and Fort
Thompson. Four Directions also wants DOJ to investigate the recent
refusal to support the satellite requests by the state Board of
Elections on a 4-3 vote with Gant leading and voting with the
opposition.
I have posted the letter to AG Holder at this link
<http://electionlawblog.org/wp-content/uploads/Letter-to-AG.pdf>.
MORE
<http://indiancountrytodaymedianetwork.com/2013/08/07/four-directions-and-three-sioux-tribes-file-civil-rights-complaint-150778>
from /Indian Country Today./
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Posted in voting <http://electionlawblog.org/?cat=31> | Comments Off
"Moderates Nearly Extinct in U.S. House"
<http://electionlawblog.org/?p=54100>
Posted on August 7, 2013 7:56 pm <http://electionlawblog.org/?p=54100>
by Rick Hasen <http://electionlawblog.org/?author=3>
FairVote explains
<http://www.fairvote.org/moderates-nearly-extinct-in-the-u-s-house#.UgMIVFMd7h0>.
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Posted in alternative voting systems
<http://electionlawblog.org/?cat=63>, political parties
<http://electionlawblog.org/?cat=25>, political polarization
<http://electionlawblog.org/?cat=68> | Comments Off
"Colorado's Gun-Control Recall: The Canary in the Coal Mine for
Reformers?" <http://electionlawblog.org/?p=54097>
Posted on August 7, 2013 7:53 pm <http://electionlawblog.org/?p=54097>
by Rick Hasen <http://electionlawblog.org/?author=3>
Josh Spivak
<http://www.theatlantic.com/politics/archive/2013/08/colorado-s-gun-control-recall-the-canary-in-the-coal-mine-for-reformers/278422/>
writes for /The Atlantic./
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Posted in recall elections <http://electionlawblog.org/?cat=11> |
Comments Off
Thursday's Bauer-Ginsberg Commission Hearing in Denver to Be Webcast
<http://electionlawblog.org/?p=54095>
Posted on August 7, 2013 7:51 pm <http://electionlawblog.org/?p=54095>
by Rick Hasen <http://electionlawblog.org/?author=3>
You can watch here <http://www.supportthevoter.gov/>.
There is also the opportunity for public comment at these meetings and
for the submission of election-related materials to the Commission
through the Commission's website. <http://www.supportthevoter.gov/>
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Posted in election administration <http://electionlawblog.org/?cat=18> |
Comments Off
"The IRS Scandal's Inconsistencies"
<http://electionlawblog.org/?p=54092>
Posted on August 7, 2013 3:14 pm <http://electionlawblog.org/?p=54092>
by Rick Hasen <http://electionlawblog.org/?author=3>
Reps. Issa and Camp write this WaPo oped
<http://www.washingtonpost.com/opinions/darrell-issa-and-dave-camp-the-irs-scandals-inconsistencies/2013/08/06/d70d2b6a-fbc8-11e2-9bde-7ddaa186b751_story.html?wpisrc=nl_politics>.
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Posted in campaign finance <http://electionlawblog.org/?cat=10>, tax law
and election law <http://electionlawblog.org/?cat=22> | Comments Off
"Don't Rush to Judgment on IRS-FEC E-Mails, Practitioners Say"
<http://electionlawblog.org/?p=54089>
Posted on August 7, 2013 2:48 pm <http://electionlawblog.org/?p=54089>
by Rick Hasen <http://electionlawblog.org/?author=3>
Tax Analysts
<http://taxanalysts.com/www/features.nsf/Features/FD08E76D0B7640B785257BC000739947?OpenDocument>reports.
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Posted in campaign finance <http://electionlawblog.org/?cat=10>, tax law
and election law <http://electionlawblog.org/?cat=22> | Comments Off
FEC Chair Weintraub Asks FEC Inspector General to Investigate Any
Improper IRS-FEC Targeting of Conservatives
<http://electionlawblog.org/?p=54085>
Posted on August 7, 2013 2:00 pm <http://electionlawblog.org/?p=54085>
by Rick Hasen <http://electionlawblog.org/?author=3>
Read the letter <http://t.co/dxkxjHLwkZ>. Chair Weintraub adds that she
has seen no evidence of improper targeting.
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Posted in campaign finance <http://electionlawblog.org/?cat=10>, federal
election commission <http://electionlawblog.org/?cat=24>, Uncategorized
<http://electionlawblog.org/?cat=1> | Comments Off
Are Purely Partisan Election Laws Unconstitutional: Bans on Straight
Ticket Voting <http://electionlawblog.org/?p=54079>
Posted on August 7, 2013 12:32 pm <http://electionlawblog.org/?p=54079>
by Richard Pildes <http://electionlawblog.org/?author=7>
A question lurking over many constitutional issues concerning election
laws is how courts should address the "easiest," core case of a law that
can fairly be judged as purely partisan in purpose, without any
legitimate public-regarding justification. Unless courts know how to
resolve that core case, they will be even more uncertain about how to
judge the more common mixed-purpose cases, in which election laws might
be judged both to have partisan purposes but also to have potentially
legitimate, public purposes as well.
So far, the Supreme Court has held that voter-identification laws
present the latter case of mixed-purposes voting regulations: as the
Court said in /Crawford¸ /"it is fair to infer that partisan
considerations may have played a significant role in the decision to
enact" Indiana's voter ID law -- but that the law was nonetheless
constitutional on its face because there were also legitimate,
public-regarding purposes for such a law.
So what about cases of "purely" partisan laws? In /Crawford¸ /the Court
did go on to say that a law would be unconstitutional if partisan
considerations "provided the only justification" for a voting law. We
know that legislatures do engage in self-interested attempts to rig the
electoral process to favor their own partisan and incumbent interests.
But how often are "purely partisan" laws enacted? More to the point,
how easy is it for courts to identify such laws?
Bans on straight-ticketing voting (ST) seem to me one of the better
tests of these questions. I have often used this example in class. It
has become particularly timely again now because, as part of the package
of changes to its election laws the North Carolina legislature recently
enacted, one of the less noticed changes was precisely a new ban on
ST. Why would a legislature care about taking away from voters the
option -- which after all, is just an option -- to case an ST vote?
Because in states where this happens, the Democratic Party tends to do
better when the ST option exists.
Since 1997, ST has been banned in seven states: Illinois (1997),
Michigan (2001), Missouri (2006), New Hampshire (2007), South Dakota
(1996), Wisconsin (2011), and NC (2013)
<http://www.ncsl.org/legislatures-elections/elections/straight-ticket-voting.aspx>.
From quick initial research
<http://www.star-telegram.com/2013/03/16/4707459/no-compelling-reason-to-end-straight.html>,
it appears to me that these bans were all enacted in states
<http://www.wilsontimes.com/News/Feature/Story/18074897---Newton--Drop-straight-party-voting>
then
<http://www.michigandaily.com/content/senate-vote-proposal-eliminate-straight-ticket-voting>
under
<http://news.google.com/newspapers?nid=1893&dat=20050118&id=J6cfAAAAIBAJ&sjid=IdYEAAAAIBAJ&pg=5849,2414474>
Republican control <http://www.jsonline.com/blogs/news/121413453.html>.
Of course, there are "public regarding" justifications one can offer
even for laws that ban ST: such bans encourage "deliberation about the
merits of individual candidates." But this is about as thin a
"legitimate" purpose as you are likely ever to see for an election law.
If ever courts are willing to consider an election-law justification
pretextual, I would think that would the case here.
So if courts conclude "the only justification" for these ST bans is
partisan advantage seeking, should they take /Crawford /at its word and
strike them down? But then ST voting is only available right now, see
here
<http://www.ncsl.org/legislatures-elections/elections/straight-ticket-voting.aspx>,
in 15 states: Alabama, Indiana, Iowa, Kentucky, Michigan, New Jersey,
New Mexico, North Carolina, Oklahoma, Pennsylvania, Rhode Island, South
Carolina, Texas, Utah, West Virginia. So would it also be the case that
there is an affirmative constitutional right to be able to vote a ST
option and that states must then provide that option? And if not, can
constitutional doctrine make illegal the /elimination of an existing ST
option/, but permit states that have not had the option at all continue
not to have it?
The stakes in these questions -- so sharply brought to the surface by
bans on ST voting -- are high, because they go to the most basic
questions of how constitutional law should apply to the democratic
process. If even "purely partisan laws" are constitutional, then laws
that have any mix of partisan and plausible public purposes will be
constitutional. And perhaps all this suggests that it's simply not
going to be feasible for courts to base doctrine on whether the "only"
or "primary" purpose for a voting law is partisan advantage. Instead,
the more effective doctrinal path might be, in essence, a kind of
intensive scrutiny of the effects of voting laws, in which significant
burdens on access to the ballot box would be weighed against the
benefits to important state purposes --- an approach also suggested by
the majority opinion in /Crawford/.
I've explored some of these issues in my academic writing but I won't
cite that stuff here.
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Posted in Uncategorized <http://electionlawblog.org/?cat=1> | Comments Off
"Beyond the Discrimination Model on Voting"
<http://electionlawblog.org/?p=54075>
Posted on August 7, 2013 9:01 am <http://electionlawblog.org/?p=54075>
by Rick Hasen <http://electionlawblog.org/?author=3>
Sam Issacharoff has posted this draft
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2306080> on SSRN
(forthcoming, /Harvard L. Rev./). Here is the abstract:
The Supreme Court's contentious decision in Shelby County v. Holder
closes the chapter on the most important and most successful of the
civil rights laws from the 1960s. For the majority of the divided
Court, the preclearance requirements of the Voting Rights Act for
changing electoral practices stigmatized sovereign states and no
longer bore a logical relation to the voting problems of today. That
combination proved fatal for Congress's efforts to protect minority
voters through the 14th and 15th amendments. At the same time, the
Court in Arizona v. Inter Tribal Council of Arizona reaffirmed
expansive congressional powers under the Elections Clause. This
Article contrasts the distinct sources of federal power over
elections and compares their effectiveness for the renewed battles
over voter eligibility. Unlike the concerns of racial exclusion
under Jim Crow, the argument presented is that current voting
controversies are likely motivated by partisan zeal and emerge in
contested partisan environments. The Article concludes with a
proposed administrative process based on the Elections Clause that
can potentially be more effective than the provisions of the Voting
Rights Act struck down in Shelby County.
Looking forward to reading this!
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Posted in Elections Clause <http://electionlawblog.org/?cat=70>, Supreme
Court <http://electionlawblog.org/?cat=29>, Voting Rights Act
<http://electionlawblog.org/?cat=15> | 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://www.law.uci.edu/faculty/full-time/hasen/
http://electionlawblog.org
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