[EL] Possible Causes of Long Lines

Fri Feb 8 13:44:01 PST 2013

There have always been lines for voting, with or without early voting.  Get over it!

Frank B. Strickland
Strickland Brockington Lewis LLP
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From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Doug Hess
Sent: Friday, February 08, 2013 4:36 PM
To: law-election at department-lists.uci.edu
Subject: [EL] Possible Causes of Long Lines

As I sit here in bed on day five of the world's worst flu (not a fun way to lose weight), I'm wondering what cuases (possible or known) exist for long lines.

Have analysts ever conducted some sort of Taylorism study of voting precincts? I've always wondered what "operations research" courses that some policy schools offer were about, but if that field is about placing resources and flow of clients, can or has that been applied to this issue?

More immediately, I can imagine that almost any steps in the process of voting in person can contribute to bottlenecks at various places, but which steps are the largest or most likely culprits?

Doug
On Feb 8, 2013 3:00 PM, <law-election-request at department-lists.uci.edu<mailto:law-election-request at department-lists.uci.edu>> wrote:
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Today's Topics:

   1. Re: OFA: A Shot Heard 'round the World? (JBoppjr at aol.com<mailto:JBoppjr at aol.com>)
   2. Voter fraud? What voter fraud!?! Nothing to see here,     people.
      Move along. (Joe La Rue)
   3. Re: Voter fraud? What voter fraud!?! Nothing to see here,
      people. Move along. (Rick Hasen)
   4. Re: Voter fraud? What voter fraud!?! Nothing to see here,
      people. Move along. (Tova Wang)
   5. ELB News and Commentary 2/8/13 (Rick Hasen)
   6. Re: Voter fraud? What voter fraud!?! Nothing to see here,
      people. Move along. (Frank Askin)
   7. Re: Voter fraud? What voter fraud!?! Nothing to see       here,
      people. Move along. (Frank Askin)
   8. How strange. I've written about and called for reform of
      absentee ballots for years (John Fund)
   9. Re: Voter fraud? What voter fraud!?! Nothing to see here,
      people. Move along. (Salvador Peralta)
  10. Re: Voter fraud? What voter fraud!?! Nothing to see here,
      people. Move along. (dasmith)
  11. Re: How strange. I've written about and called for reform of
      absentee ballots for years (Ryan J. Reilly)
  12. Re: How strange. I've written about and called for reform of
      absentee ballots for years (Rick Hasen)
  13. Re: OFA: A Shot Heard 'round the World? (Steve Hoersting)
  14. Absentee ballots and voter ID (Jon Roland)
  15. Re: How strange. I've written about and called for reform of
      absentee ballots for years (Sean Parnell)
  16. Re: Absentee ballots and voter ID (Greenberg, Kevin)

---------- Forwarded message ----------
From: JBoppjr at aol.com<mailto:JBoppjr at aol.com>
To: sean at impactpolicymanagement.com<mailto:sean at impactpolicymanagement.com>, schmitt.mark at gmail.com<mailto:schmitt.mark at gmail.com>, PRyan at campaignlegalcenter.org<mailto:PRyan at campaignlegalcenter.org>, law-election at uci.edu<mailto:law-election at uci.edu>
Cc:
Date: Fri, 8 Feb 2013 09:45:40 -0500 (EST)
Subject: Re: [EL] OFA: A Shot Heard 'round the World?
Sean is right.

In addition, it is already quite common and clearly legal for Members of Congress to work with advocacy groups regarding grass roots lobbying in favor of legislation which the Congressman favors or opposes.

It is also not unprecedented for a Presidential campaign to morph into an advocacy group -- Pat Robertson's campaign in 1988 became the basis for the Christian Coalition.

So I see nothing remarkable or illegal about OFA, aside from the remarkable hypocrisy of it all.

But even the hypocrisy of it is not that remarkable.  The campaign finance "reform"  industry works with Members of Congress on their grass roots lobbying and also the groups benefit from the fundraising that some Congressmen do for them. And these groups also provide direct benefits to various Congressmen -- featuring them and praising them in public relations campaigns and paying for their litigation expenses.

And of course they accept unlimited corporate contributions of "dark money," too, to fund it all.  Jim Bopp

In a message dated 2/7/2013 1:45:37 P.M. Eastern Standard Time, sean at impactpolicymanagement.com<mailto:sean at impactpolicymanagement.com> writes:
I'm not sure about 501c3 and c4 groups that are used by officeholders to keep family and campaign staff employed, but I do know it's pretty common for officeholders to sign letters on behalf of a wide variety of c3 and c4 groups urging people to donate to them, and there is typically not much of a connection between the officeholder and the entity other than they like the group's work. Some of these groups are fairly ideological - lots of Congressman have signed letters on behalf of Heritage over the years, for example - while others are not, such as the charity that sent oral surgeons to Central America to do cleft lip and cleft palate surgery on children that the Congressman I used to work for signed a letter for (actually, used his fundraising list to send it to as well).

I only throw this out there because it seems worth recognizing these things in a discussion of officeholders raising funds for c3 and c4 groups.

Sean Parnell
President
Impact Policy Management, LLC
6411 Caleb Court
Alexandria, VA  22315
571-289-1374<tel:571-289-1374> (c)
sean at impactpolicymanagement.com<mailto:sean at impactpolicymanagement.com>

From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [mailto:law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>] On Behalf Of Mark Schmitt
Sent: Thursday, February 07, 2013 11:59 AM
To: Paul Ryan; law-election at uci.edu<mailto:law-election at uci.edu>
Subject: Re: [EL] OFA: A Shot Heard 'round the World?

Good points, Paul, and you're right that the idea of "shutting down" OFA is a bit of a straw-man. I think we agree that the issues around office-holder fundraising for OFA or similar organizations are in a somewhat different zone, having to do with activities of elected officials, than the zone of campaign-finance regulation that Steve connects them to.

I believe, by the way, that a lot of elected officials already have 501(c)4's and 501(c)3's that they raise money for, and often they use them not so much for issue advocacy as to keep their spouses, family members, and campaign staffers employed, and as a platform for fundraising. Rep. Steve Buyer's golf charity was, I suspect, the tip of a very big iceberg.

On 2/7/2013 10:58 AM, Paul Ryan wrote:
I appreciate your thoughtful post, Mark.  I think there's a lot to be said for "public official exceptionalism," not just "electoral exceptionalism."  You note that "there are all sorts of regulations on the time and activity of public officials, as opposed to ordinary citizens, such as revolving-door regulations on later employment, financial disclosure requirements, public meetings laws, etc."  I would add to your list important restrictions on gifts to public officials, anti-bribery laws, restrictions on outside employment, restrictions on profiting from information obtained in the exercise of official duties, etc..  I believe that these sorts of restrictions on public official involvement in financial transactions, together with election-specific fundraising restrictions, are vital to a well-functioning democracy.  Our campaign finance fundraising restrictions are supported by the governmental interest in preventing actual and apparent corruption of officeholders-the same governmental interest that supports the rest of the money-related ethics rules/restrictions listed above.

And that's really what I'm talking/writing about when it comes to President Obama and OFA.  You wrote that "as a matter of policy, shutting down operations that are intended to organize the public on particular issue priorities, but don't intervene in elections, doesn't seem to me like a very high priority.  And it's certainly not essential to making other campaign finance reforms work."  I haven't advocated "shutting down operations that are intended to organize the public on particular issue priorities."  This is a straw man.  My concern is with an officeholder raising big contributions for such an operation.  "Operations that are intended to organize the public on particular issue priorities" are free to raise and spend unlimited funds and such organizations have been around a long time doing so.  What's new here-and troubling to me-is an officeholder's direct involvement in this activity.  Why must such an organization involve an officeholder when doing so raises the threat of corruption?  If donors support the group's work, won't they give generously even if doing so won't result in access to an officeholder?

As for your assertion that restricting an officeholder's fundraising for such a group is "certainly not essential to making other campaign finance reforms work," I suppose that depends on the goal of the campaign finance reforms.  If the goal is for such campaign finance reforms to work in tandem with other officeholder financial activity restrictions like those listed above, in order to prevent actual and apparent corruption, then limiting officeholder fundraising for such a group does seem essential to me.  You note the "challenge is in finding the real borders of the election."  Your "electoral exceptionalism" theory exponentially increases the importance of doing so.  (By contrast, my theory of "public official exceptionalism" requires only that we identify those public officials whose financial activity we deem appropriate to regulate.)  If the President's operation of OFA isn't checked, I have no doubt that other Members of Congress will soon set up their own (c)(4)s for unlimited fundraising, with sharp lawyers ready to defend the activities as "intended to organize the public on particular issue priorities."  The borders will be pushed hard.  Existing campaign contribution limits will be severely undermined.  Those who oppose existing contribution limits will take great delight in this development.  The rest of us might reasonably be concerned by the precedent likely to be set by President Obama and OFA.

Best,

Paul Seamus Ryan
Senior Counsel
The Campaign Legal Center
215 E Street NE
Washington, DC 20002
Ph. (202) 736-2200 ext. 214<tel:%28202%29%20736-2200%20ext.%20214>
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From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Mark Schmitt
Sent: Thursday, February 07, 2013 12:34 AM
To: law-election at uci.edu<mailto:law-election at uci.edu>
Subject: Re: [EL] OFA: A Shot Heard 'round the World?

There's a lot to be said for "electoral exceptionalism." Money and economic inequality influence politics and policy outcomes in millions of ways, but elections are a protected space in which the potential for corruption is much higher (since elections have a direct, winner-take-all effect on who holds power) and in which we necessarily impose some rules in the interest of orderly and balanced participation. (No campaigning within 75 feet of a polling place, for example, is a restriction on expression but one that we generally accept as common sense and in the interest of an orderly, fair election.) Elections are a structured process, and the rules governing them will always be, and should be, somewhat different from the rules governing more freewheeling debate about policies and ideas.

The challenge is in finding the real borders of the election. Sometimes ads that say "call your member of Congress" really mean, "call your member of Congress." And sometimes, as we know, they mean, "vote against that tax-raising jerk," and should be considered a de facto campaign contribution. (In the case of gun safety, the example you used in an earlier piece, Steve, "Call your member of Congress" 20 months before the next election, probably means exactly that, because elected officials are unsure where their constituents stand right now on that issue.) Getting that line right can be a challenge, but the complexity and occasional idiosyncratic outcome doesn't invalidate the basic distinction.

It's not great to have elected officials involved in raising money to try to help them achieve their substantive goals, which may create a relationship of dependency similar to that of campaign contributions. But it's not the same kind of problem, and not as pervasive. Paul may well be right that the Court would accept some regulation of public officials raising money for such organizations  -- there are all sorts of regulations on the time and activity of public officials, as opposed to ordinary citizens, such as revolving-door regulations on later employment, financial disclosure requirements, public meetings laws, etc. But as a matter of policy, shutting down operations that are intended to organize the public on particular issue priorities, but don't intervene in elections, doesn't seem to me like a very high priority. And it's certainly not essential to making other campaign finance reforms work.

Another interesting dimension of this is the question of when an organization is considered to be aligned with a political party, or pursuing the aims of that party. Twenty years ago, for example, an environmental organization wouldn't have been seen as "aligned" with the Democratic Party; now it might be. The same is true on guns or health reform or any number of issues. It seems difficult to develop a robust legal theory about when an organization is "partisan" when an issue can go from bipartisan to partisan, or vice versa, in days. Organizing to push "the president's agenda" might be partisan on some issues, but not on immigration, probably.

On 2/6/2013 1:04 PM, Doug Hess wrote:
Not sure I can agree on the "no matter to what ends" language (by agree, I mean thinking through my own views, not what this or that court has said). Surely there is some line, where if the fundraiser is not taking money for their own office or own campaign, they are raising money for mobilization and public organizing that is not candidate focused. I guess the area in between is when they are raising money that then supports another candidate. I.e., three scenarios:

1) donor --> official --> official's election campaign
2) donor --> official --> another person's election campaign
3) donor --> official --> organizing the public on issues

The first seems bad, the second I'd be concerned about as it quickly could equal the first, but the third one doesn't strike me as necessarily corrupt or appearing corrupt (although it could need regulating to keep it "clean") . Presumably wealthy donors, in the end, have plenty of ways of "buying off" the fundraiser or organization's board/staff through other donations nowadays.

Doug

On Wed, Feb 6, 2013 at 12:01 PM, Paul Ryan <PRyan at campaignlegalcenter.org<mailto:PRyan at campaignlegalcenter.org>> wrote:
Doug,

You wonder, in your email, whether President Obama plans to help raise funds for OFA while in office.  The President "announced the relaunch of his remaining campaign apparatus as a new tax-exempt group called Organizing for Action . . . ."  (http://www.politico.com/story/2013/01/obama-campaign-to-relaunch-as-tax-exempt-group-86375.html)  If press accounts are accurate, the President and his political team will be very involved in all aspects of running OFA and this presumably includes fundraising for the group.

My concern/objection is that an officeholder will be soliciting very large (i.e., unlimited) contributions from unlimited sources (e.g., individuals, corporations, unions, foreign nationals-quite possibly with business before the officeholder) and that the law doesn't even require public disclosure of these contributions/sources.   (Though OFA is apparently planning to voluntarily disclose some degree of information about its donors, other officeholders may emulate this strategy without the voluntary disclosure.)

As I explained in my email to the listserv yesterday, the Supreme Court has recognized, in upholding limits on candidate/officeholder fundraising and related disclosure requirements, that unlimited officeholder fundraising gives rise to "corruption or the appearance of corruption" "regardless of the ends to which those funds are ultimately put."  I agree with the Court on this point.  In my view, officeholder fundraising for a 501(c)(4) dedicated to promoting that officeholder's political agenda gives rise to precisely the same threat of corruption as officeholder fundraising for his/her reelection campaign.  The threat of corruption exists "regardless of the ends to which those funds are ultimately put."

Best,

Paul Seamus Ryan
Senior Counsel
The Campaign Legal Center
215 E Street NE
Washington, DC 20002
Ph. (202) 736-2200 ext. 214<tel:%28202%29%20736-2200%20ext.%20214>
Mobile Ph. (202) 262-7315<tel:%28202%29%20262-7315>
Fax (202) 736-2222<tel:%28202%29%20736-2222>
Website: http://www.campaignlegalcenter.org/
Blog: http://www.clcblog.org/
To sign up for the CLC Blog, visit: http://www.campaignlegalcenter.org/index.php?option=com_forme&fid=1&Itemid=63
Follow us on Twitter @CampaignLegal<http://bit.ly/j8Q1bg>
Become a fan on Facebook<http://on.fb.me/jroDv2>

From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [mailto:law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>] On Behalf Of Doug Hess
Sent: Wednesday, February 06, 2013 10:54 AM
To: law-election at department-lists.uci.edu<mailto:law-election at department-lists.uci.edu>
Subject: [EL] OFA: A Shot Heard 'round the World?

I don't understand the objection to an organization (the new OFA) that promotes mobilization around community and national issues receiving donations. If the members don't like who funds the group, they won't fund it (i.e., donate or join it) either.

I guess for appearances, Obama's involvement raises questions, but there are ways to limit that involvement in reality and in appearance. It will be interesting to see if he plans to help raise funds for it while in office. If it endorses, then things are trickier, I guess. But a 501(c)4 organization (I think that is what it is) can only inform members of its endorsement, right? And it would be odd for a sitting president to endorse many people in a primary fight in a systematic way (FDR learned that) and even odder that he would endorse members of the opposite party. So, what is the concern? That people may organize and a president encourage it?

On another topic: It is interesting to note that an extra-party organization is needed to do more creative political organizing in American politics.

-Doug

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---------- Forwarded message ----------
From: Joe La Rue <joseph.e.larue at gmail.com<mailto:joseph.e.larue at gmail.com>>
To: law-election at uci.edu<mailto:law-election at uci.edu>
Cc:
Date: Fri, 8 Feb 2013 08:35:48 -0700
Subject: [EL] Voter fraud? What voter fraud!?! Nothing to see here, people. Move along.
This is not directed at Rick, who has candidly acknowledged that voter fraud does, sometimes, happen.  But there are others who say that "voter fraud" is nothing but an invention of those who want to suppress voters by requiring photo ID.  Worse, some say that it is an invention to keep minorities from voting.  Well, for all who say that voter fraud never, ever, happens, here's another example of that "non-existent" phenomenon. http://www.nationalreview.com/corner/340174/voter-fraud-never-happens-keeps-coming-back-john-fund

Joe
___________________
Joseph E. La Rue
cell: 480.272.2715<tel:480.272.2715>
email: joseph.e.larue at gmail.com<mailto: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.

---------- Forwarded message ----------
From: Rick Hasen <rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>>
To: Joe La Rue <joseph.e.larue at gmail.com<mailto:joseph.e.larue at gmail.com>>
Cc: law-election at uci.edu<mailto:law-election at uci.edu>
Date: Fri, 8 Feb 2013 07:44:23 -0800
Subject: Re: [EL] Voter fraud? What voter fraud!?! Nothing to see here, people. Move along.
I don't know any serious person studying this issue who says there is no election fraud.  The vast majority of the relatively small number of cases involve either election officials committing fraud, or voters, candidates, and others committing absentee ballot fraud.
The problem is that the supposed cure---voter id---does not stop these main types of fraud.
If John Fund and others started a serious push to eliminate the use of absentee ballots, then I would take their concerns about voter fraud much more seriously. But it is not a part of the antifraud measures proposed and adopted by those who claim this is a major problem.
On 2/8/13 7:35 AM, Joe La Rue wrote:
This is not directed at Rick, who has candidly acknowledged that voter fraud does, sometimes, happen.  But there are others who say that "voter fraud" is nothing but an invention of those who want to suppress voters by requiring photo ID.  Worse, some say that it is an invention to keep minorities from voting.  Well, for all who say that voter fraud never, ever, happens, here's another example of that "non-existent" phenomenon. http://www.nationalreview.com/corner/340174/voter-fraud-never-happens-keeps-coming-back-john-fund

Joe
___________________
Joseph E. La Rue
cell: 480.272.2715<tel:480.272.2715>
email: joseph.e.larue at gmail.com<mailto: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.

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---------- Forwarded message ----------
From: Tova Wang <twang at demos.org<mailto:twang at demos.org>>
To: Joe La Rue <joseph.e.larue at gmail.com<mailto:joseph.e.larue at gmail.com>>, "law-election at uci.edu<mailto:law-election at uci.edu>" <law-election at uci.edu<mailto:law-election at uci.edu>>
Cc:
Date: Fri, 08 Feb 2013 10:41:59 -0500
Subject: Re: [EL] Voter fraud? What voter fraud!?! Nothing to see here, people. Move along.
I believe people argue that there is very little fraud perpetrated by voters at the polling place.  Correct me if I'm wrong, but don't these cases mostly involve absentee ballots and the actions of an election official?  In the one case where a voter says it appeared that someone else had voted in her name, I would say to stand by to see if there is a clerical error, as is often the case.

http://www.sfgate.com/news/crime/article/Possible-Ohio-voter-fraud-investigation-heats-up-4256259.php

From: law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu> [mailto:law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>] On Behalf Of Joe La Rue
Sent: Friday, February 08, 2013 4:36 PM
To: law-election at uci.edu<mailto:law-election at uci.edu>
Subject: [EL] Voter fraud? What voter fraud!?! Nothing to see here, people. Move along.

This is not directed at Rick, who has candidly acknowledged that voter fraud does, sometimes, happen.  But there are others who say that "voter fraud" is nothing but an invention of those who want to suppress voters by requiring photo ID.  Worse, some say that it is an invention to keep minorities from voting.  Well, for all who say that voter fraud never, ever, happens, here's another example of that "non-existent" phenomenon. http://www.nationalreview.com/corner/340174/voter-fraud-never-happens-keeps-coming-back-john-fund

Joe
___________________
Joseph E. La Rue
cell: 480.272.2715<tel:480.272.2715>
email: joseph.e.larue at gmail.com<mailto: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.

---------- Forwarded message ----------
From: Rick Hasen <rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>>
To: "law-election at UCI.edu<mailto:law-election at UCI.edu>" <law-election at UCI.edu<mailto:law-election at UCI.edu>>
Cc:
Date: Fri, 8 Feb 2013 08:03:07 -0800
Subject: [EL] ELB News and Commentary 2/8/13
Forum on "The Voting Wars" at Cardozo law Feb. 11<http://electionlawblog.org/?p=46018>
Posted on February 8, 2013 8:00 am<http://electionlawblog.org/?p=46018> by Rick Hasen<http://electionlawblog.org/?author=3>

[Moving to top, and looking forward to attending this event Monday--assuming the weather cooperates.]

Cardozo Law School's Foersheimer Center for Constitutional Democracy is putting on this event<http://www.cardozo.yu.edu/MemberContentDisplay.aspx?ccmd=ContentDisplay&ucmd=UserDisplay&userid=10374&contentid=25758&folderid=340> Feb. 11 at noon:
The Voting Wars: From Florida 2000 to the Next Election Meltdown, a discussion with the author
2/11/2013
12:00 pm - 1:30 pm

Richard L. Hasen, Chancellor's Professor of Law and Political Science at the University of California, Irvine, will discuss and respond to commentary about his recent book, The Voting Wars: From Florida 2000 to the Next Election Meltdown. Professor Hasen is a well-known expert in the field of election law, having co-founded the Election Law Journal and published more than eighty articles in the field.

Commenting on Professor Hasen's book will be election law Professors Janai S. Nelson, from St. John's University School of Law; Richard Briffault, from Columbia Law School; and Mark C. Alexander, from Seton Hall Law School. Professor Alexander is currently running for the New Jersey Senate.

The panel will be moderated by Professor Michelle Adams.
[Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D46018&title=Forum%20on%20%E2%80%9CThe%20Voting%20Wars%E2%80%9D%20at%20Cardozo%20law%20Feb.%2011&description=>
Posted in election administration<http://electionlawblog.org/?cat=18>, The Voting Wars<http://electionlawblog.org/?cat=60> | Comments Off
A Quick Reminder on Voter Fraud<http://electionlawblog.org/?p=47061>
Posted on February 8, 2013 7:52 am<http://electionlawblog.org/?p=47061> by Rick Hasen<http://electionlawblog.org/?author=3>

With news<http://politicalwire.com/archives/2013/02/08/ohio_poll_worker_admits_to_voting_twice.html> of possible fraud claims coming out of Hamilton County, Ohio, it is worth remembering that vast majority of the relatively small number of cases involve either election officials committing fraud, or voters, candidates, and others committing absentee ballot fraud.
The problem is that the supposed cure-voter id-does not stop these main types of fraud.
If John Fund and others started a serious push to eliminate the use of absentee ballots, then I would take their concerns about voter fraud much more seriously. But it is not a part of the antifraud measures proposed and adopted by those who claim this is a major problem.
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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
"Democrats Cite Long Lines in Bid to Shift Voting Rights Debate"<http://electionlawblog.org/?p=47058>
Posted on February 8, 2013 7:41 am<http://electionlawblog.org/?p=47058> by Rick Hasen<http://electionlawblog.org/?author=3>

Bloomberg reports<http://www.bloomberg.com/news/2013-02-08/democrats-cite-long-lines-in-bid-to-shift-voting-rights-debate.html?alcmpid=politics>.
[Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D47058&title=%E2%80%9CDemocrats%20Cite%20Long%20Lines%20in%20Bid%20to%20Shift%20Voting%20Rights%20Debate%E2%80%9D&description=>
Posted in election administration<http://electionlawblog.org/?cat=18>, The Voting Wars<http://electionlawblog.org/?cat=60>, Voting Rights Act<http://electionlawblog.org/?cat=15> | Comments Off
"Online symposium announcement: Shelby County v. Holder"<http://electionlawblog.org/?p=47055>
Posted on February 7, 2013 5:31 pm<http://electionlawblog.org/?p=47055> by Rick Hasen<http://electionlawblog.org/?author=3>

SCOTUSBlog symposium on Shelby County is coming<http://www.scotusblog.com/2013/02/online-symposium-announcement-shelby-county-v-holder/>.
[Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D47055&title=%E2%80%9COnline%20symposium%20announcement%3A%20Shelby%20County%20v.%20Holder%E2%80%9D&description=>
Posted in Supreme Court<http://electionlawblog.org/?cat=29>, Voting Rights Act<http://electionlawblog.org/?cat=15> | Comments Off
"Watch Out in the Covered Jurisdictions"<http://electionlawblog.org/?p=47052>
Posted on February 7, 2013 5:18 pm<http://electionlawblog.org/?p=47052> by Rick Hasen<http://electionlawblog.org/?author=3>

Mike Pitts has written this contribution<http://blogs.reuters.com/great-debate/2013/02/07/watch-out-in-the-covered-jurisdictions/> to the Reuters voting rights symposium<http://www.reuters.com/subjects/voting-rights> on the Shelby County case.  A snippet: "In contrast, on the local level, there could be widespread retrogression. This could come from redistricting plans that eliminate 'safe' districts, switches to at-large elections or annexations of white population by cities and towns that would reduce minority voters' influence. The key reason these changes are likely is that if you look at the Justice Department's pre-clearance enforcement over the past 30 years, what stands out is that a disproportionate number of pre-clearance denials involved vote dilution on the local level. If local jurisdictions are most likely to violate Section 5 now, they are far more likely to be emboldened when it's killed."
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Posted in Supreme Court<http://electionlawblog.org/?cat=29>, Voting Rights Act<http://electionlawblog.org/?cat=15> | Comments Off
Crossroad GPS's Tax Status Still in Limbo<http://electionlawblog.org/?p=47049>
Posted on February 7, 2013 5:13 pm<http://electionlawblog.org/?p=47049> by Rick Hasen<http://electionlawblog.org/?author=3>

Ken Vogel tweets<https://twitter.com/kenvogel/status/299646127370813445>.
[Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D47049&title=Crossroad%20GPS%E2%80%99s%20Tax%20Status%20Still%20in%20Limbo&description=>
Posted in campaign finance<http://electionlawblog.org/?cat=10>, tax law and election law<http://electionlawblog.org/?cat=22> | Comments Off
"Pro-Obama group says it's not partisan, but has wide latitude"<http://electionlawblog.org/?p=47046>
Posted on February 7, 2013 5:10 pm<http://electionlawblog.org/?p=47046> by Rick Hasen<http://electionlawblog.org/?author=3>

The LA Times reports.<http://www.latimes.com/news/politics/la-pn-organizing-for-action-partisan-issues-20130207,0,6239594.story>
[Share]<http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D47046&title=%E2%80%9CPro-Obama%20group%20says%20it%E2%80%99s%20not%20partisan%2C%20but%20has%20wide%20latitude%E2%80%9D&description=>
Posted in campaign finance<http://electionlawblog.org/?cat=10>, tax law and election law<http://electionlawblog.org/?cat=22> | Comments Off
"Shareholders question corporate political spending"<http://electionlawblog.org/?p=47043>
Posted on February 7, 2013 5:08 pm<http://electionlawblog.org/?p=47043> by Rick Hasen<http://electionlawblog.org/?author=3>

Darrell Delamaide column<http://www.marketwatch.com/story/shareholders-question-corporate-political-spending-2013-02-07> for Marketwatch.
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"Non-political nonprofit's spending spikes in election years"<http://electionlawblog.org/?p=47040>
Posted on February 7, 2013 5:06 pm<http://electionlawblog.org/?p=47040> by Rick Hasen<http://electionlawblog.org/?author=3>

CPI reports<http://www.publicintegrity.org/2013/02/07/12160/non-political-nonprofits-spending-spikes-election-years?utm_source=publicintegrity&utm_medium=social_media&utm_campaign=twitter>.
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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
Extensive Ari Berman Cover Story for Nation on Shelby County Case<http://electionlawblog.org/?p=47037>
Posted on February 7, 2013 4:51 pm<http://electionlawblog.org/?p=47037> by Rick Hasen<http://electionlawblog.org/?author=3>

The piece<http://www.thenation.com/article/172685/why-are-conservatives-trying-destroy-voting-rights-act?page=full> includes quotes from Rep. Sensenbrenner, and also this tidbit:

Many of the states and donors who have supported discriminatory voting laws are also backing Blum. His Project on Fair Representation is exclusively funded by Donors Trust, a consortium of conservative funders that might be the most influential organization you've never heard of. Donors Trust doled out $22 million to a Who's Who of influential conservative groups in 2010, including the American Legislative Exchange Council (ALEC), which drafted mock voter ID laws and a raft of controversial state-based legislation; the Americans for Prosperity Foundation, the Koch brothers' main public policy arm; as well as Grover Norquist's Americans for Tax Reform Foundation. Donors Trust has received seven-figure donations from virtually every top conservative donor, including $5.2 million since 2005 from Charles Koch's Knowledge and Progress Fund. (The structure of Donors Trust allows wealthy conservative donors like Koch to disguise much of their giving.)

>From 2006 to 2011, Blum received $1.2 million from Donors Trust, which allowed him to retain the services of Wiley Rein, the firm that unsuccessfully defended Ohio's and Florida's attempts to restrict early voting in federal court last year. As a "special program fund" of the tax-exempt Donors Trust, Blum's group does not have to disclose which funders of Donors Trust are giving him money, but he has identified two of them: the Bradley Foundation and the Searle Freedom Trust. The Wisconsin-based Bradley Foundation paid for billboards in minority communities in Milwaukee during the 2010 election with the ominous message "Voter Fraud Is a Felony!", which voting rights groups denounced as voter suppression. Both Bradley and Searle have given six-figure donations to ALEC in recent years, and Bradley funded a think tank in Wisconsin, the MacIver Institute, that hyped discredited claims of voter fraud to justify the state's voter ID law, currently blocked in state court.
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Posted in Supreme Court<http://electionlawblog.org/?cat=29>, Voting Rights Act<http://electionlawblog.org/?cat=15> | Comments Off
"Voting Rights Act at Risk"<http://electionlawblog.org/?p=47034>
Posted on February 7, 2013 4:41 pm<http://electionlawblog.org/?p=47034> by Rick Hasen<http://electionlawblog.org/?author=3>

That important CQ story<http://public.cq.com/docs/weeklyreport/weeklyreport-000004214386.html> is now free, out from the paywall.
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Posted in 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<tel:949.824.3072> - office

949.824.0495<tel:949.824.0495> - fax

rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>

http://law.uci.edu/faculty/page1_r_hasen.html

http://electionlawblog.org

---------- Forwarded message ----------
From: "Frank Askin" <faskin at kinoy.rutgers.edu<mailto:faskin at kinoy.rutgers.edu>>
To: "Joe La Rue" <joseph.e.larue at gmail.com<mailto:joseph.e.larue at gmail.com>>, <law-election at uci.edu<mailto:law-election at uci.edu>>
Cc:
Date: Fri, 08 Feb 2013 11:09:56 -0500
Subject: Re: [EL] Voter fraud? What voter fraud!?! Nothing to see here, people. Move along.
If this is the best National Review can come up with, I would agree that
there is virtually no in-person voter fraud.  As for absentee ballots,
in New Jersey any one who requests an absentee ballot has an A placed by
the name on the voter roll.  If they sign an affidavit that they did n
it submit the absentee allot, they are allowed to vote by provisional
ballot, which can then    be verified quite easily and the provisional
will be discarded if they did vote. FRANK ASKIN

Prof. Frank Askin
Distinguished Professor of Law       and Director
Constitutional Litigation Clinic
Rutgers Law School/Newark
(973) 353-5687<tel:%28973%29%20353-5687>

>>> Joe La Rue <joseph.e.larue at gmail.com<mailto:joseph.e.larue at gmail.com>> 2/8/2013 10:35 AM >>>
This is not directed at Rick, who has candidly acknowledged that voter
fraud does, sometimes, happen.  But there are others who say that
"voter
fraud" is nothing but an invention of those who want to suppress voters
by
requiring photo ID.  Worse, some say that it is an invention to keep
minorities from voting.  Well, for all who say that voter fraud never,
ever, happens, here's another example of that "non-existent"
phenomenon.
http://www.nationalreview.com/corner/340174/voter-fraud-never-happens-keeps-coming-back-john-fund

Joe
___________________
*Joseph E. La Rue*
cell: 480.272.2715<tel:480.272.2715>
email: joseph.e.larue at gmail.com<mailto: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.

---------- Forwarded message ----------
From: "Frank Askin" <faskin at kinoy.rutgers.edu<mailto:faskin at kinoy.rutgers.edu>>
To: "Joe La Rue" <joseph.e.larue at gmail.com<mailto:joseph.e.larue at gmail.com>>, "Frank Askin" <faskin.LAWSCHOOL.CLJ at kinoy.rutgers.edu<mailto:faskin.LAWSCHOOL.CLJ at kinoy.rutgers.edu>>, <law-election at uci.edu<mailto:law-election at uci.edu>>
Cc:
Date: Fri, 08 Feb 2013 11:17:00 -0500
Subject: Re: [EL] Voter fraud? What voter fraud!?! Nothing to see here, people. Move along.
corection. That should say "did not" submit an absentee. FRANK

Prof. Frank Askin
Distinguished Professor of Law       and Director
Constitutional Litigation Clinic
Rutgers Law School/Newark
(973) 353-5687<tel:%28973%29%20353-5687>

>>> "Frank Askin" <faskin at kinoy.rutgers.edu<mailto:faskin at kinoy.rutgers.edu>> 2/8/2013 11:09 AM >>>
If this is the best National Review can come up with, I would agree
that
there is virtually no in-person voter fraud.  As for absentee ballots,
in New Jersey any one who requests an absentee ballot has an A placed
by
the name on the voter roll.  If they sign an affidavit that they did n
it submit the absentee allot, they are allowed to vote by provisional
ballot, which can then    be verified quite easily and the provisional
will be discarded if they did vote. FRANK ASKIN

Prof. Frank Askin
Distinguished Professor of Law       and Director
Constitutional Litigation Clinic
Rutgers Law School/Newark
(973) 353-5687<tel:%28973%29%20353-5687>

>>> Joe La Rue <joseph.e.larue at gmail.com<mailto:joseph.e.larue at gmail.com>> 2/8/2013 10:35 AM >>>
This is not directed at Rick, who has candidly acknowledged that voter
fraud does, sometimes, happen.  But there are others who say that
"voter
fraud" is nothing but an invention of those who want to suppress
voters
by
requiring photo ID.  Worse, some say that it is an invention to keep
minorities from voting.  Well, for all who say that voter fraud never,
ever, happens, here's another example of that "non-existent"
phenomenon.
http://www.nationalreview.com/corner/340174/voter-fraud-never-happens-keeps-coming-back-john-fund

Joe
___________________
*Joseph E. La Rue*
cell: 480.272.2715<tel:480.272.2715>
email: joseph.e.larue at gmail.com<mailto: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.
_______________________________________________
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Law-election at department-lists.uci.edu<mailto:Law-election at department-lists.uci.edu>
http://department-lists.uci.edu/mailman/listinfo/law-election

---------- Forwarded message ----------
From: John Fund <johnfund99 at yahoo.com<mailto:johnfund99 at yahoo.com>>
To: Rick Hasen <rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>>
Cc: law-election at uci.edu<mailto:law-election at uci.edu>
Date: Fri, 8 Feb 2013 08:25:02 -0800 (PST)
Subject: [EL] How strange. I've written about and called for reform of absentee ballots for years

Rick (whose book I read and found much to agree with in)  says he would take my concerns about voter fraud more seriously if I and others  "started a serious push to eliminate the use of absentee ballots."

That is strange. No one serious calls for ELIMINATING absentee ballots. They are needed by old people, bedridden people, military voters, expats and people who travel a great deal. In "Who's Counting: How Fraudsters and Bureaucrats Put Your Vote At Risk," my co-author an I call for absentee ballot REFORM and vigorously. The chapter is entitled "Absentee Ballots: the Tool of Choice for Vote Thieves."

Indeed, I have gotten into hot water with some Republicans for criticizing some state legislatures that have not passed comprehensive anti-fraud efforts that include Photo ID, absentee ballot reform and cleaning up voter rolls despite the federal strictures on that activity.

 As the liberal Talking Points Memo wrote last August:

Fund said that many voter ID laws "take some provisions to curb absentee ballot fraud," with a few exceptions. But he confessed that Democrats had a point when they say that Republicans focus on voter ID because of a potential electoral advantage.

"I think it is a fair argument of some liberals that there are some people who emphasize the voter ID part more than the absentee ballot part because supposedly Republicans like absentee ballots more and they don't want to restrict that," Fund said. "But the bottom line is, on good government grounds, we have to have both voter ID laws and absentee ballot laws."

Just last Wednesday, my co-author and I were in Raleigh, North Carolina on a panel with two liberal opponents of Photo ID laws. We all agreed that absentee ballot fraud was a real problem, however the two opposing panelists declined to endorse any specific legislation to combat it despite a clear invitation to do so.

--- On Fri, 2/8/13, Rick Hasen <rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>> wrote:

From: Rick Hasen <rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>>
Subject: Re: [EL] Voter fraud? What voter fraud!?! Nothing to see here, people. Move along.
To: "Joe La Rue" <joseph.e.larue at gmail.com<mailto:joseph.e.larue at gmail.com>>
Cc: law-election at uci.edu<mailto:law-election at uci.edu>
Date: Friday, February 8, 2013, 10:44 AM
I don't know any serious person studying this issue who says there is no election fraud.  The vast majority of the relatively small number of cases involve either election officials committing fraud, or voters, candidates, and others committing absentee ballot fraud.
The problem is that the supposed cure---voter id---does not stop these main types of fraud.
If John Fund and others started a serious push to eliminate the use of absentee ballots, then I would take their concerns about voter fraud much more seriously. But it is not a part of the antifraud measures proposed and adopted by those who claim this is a major problem.
On 2/8/13 7:35 AM, Joe La Rue wrote:
This is not directed at Rick, who has candidly acknowledged that voter fraud does, sometimes, happen.  But there are others who say that "voter fraud" is nothing but an invention of those who want to suppress voters by requiring photo ID.  Worse, some say that it is an invention to keep minorities from voting.  Well, for all who say that voter fraud never, ever, happens, here's another example of that "non-existent" phenomenon. http://www.nationalreview.com/corner/340174/voter-fraud-never-happens-keeps-coming-back-john-fund

Joe
___________________
Joseph E. La Rue
cell: 480.272.2715<tel:480.272.2715>
email: joseph.e.larue at gmail.com<http://mc/compose?to=joseph.e.larue@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.

_______________________________________________

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Law-election at department-lists.uci.edu<http://mc/compose?to=Law-election@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<tel:949.824.3072> - office

949.824.0495<tel:949.824.0495> - fax

rhasen at law.uci.edu<http://mc/compose?to=rhasen@law.uci.edu>

http://law.uci.edu/faculty/page1_r_hasen.html

http://electionlawblog.org

-----Inline Attachment Follows-----
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Law-election mailing list
Law-election at department-lists.uci.edu<http://mc/compose?to=Law-election@department-lists.uci.edu>
http://department-lists.uci.edu/mailman/listinfo/law-election

---------- Forwarded message ----------
From: Salvador Peralta <oregon.properties at yahoo.com<mailto:oregon.properties at yahoo.com>>
To: Joe La Rue <joseph.e.larue at gmail.com<mailto:joseph.e.larue at gmail.com>>, "law-election at uci.edu<mailto:law-election at uci.edu>" <law-election at uci.edu<mailto:law-election at uci.edu>>
Cc:
Date: Fri, 8 Feb 2013 08:29:37 -0800 (PST)
Subject: Re: [EL] Voter fraud? What voter fraud!?! Nothing to see here, people. Move along.
Joe,

Isolated incidents of voter fraud do occur.  For example, here in Oregon, a Clackamas County elections worker was caught allegedly filling out ballots with a straight Republican ticket for voters who chose not to vote in certain races:

http://now.msn.com/deanna-swenson-accused-of-tampering-with-two-ballots-during-stint-as-election-worker

Elections fraud is not limited to actual voting of course, but also to voter registration drives, as we also saw in 2012:

http://nbcpolitics.nbcnews.com/_news/2012/10/19/14556980-gop-registration-worker-charged-with-voter-fraud?lite

The problem is that the cures recommended by folks such as yourself for these relatively isolated incidents tend to be overly broad and tend to disproportionately target minority voters.

The other problem for someone like yourself who has a genuine interest in voter fraud and not voter suppression is that a lot of water is being carried for you on this issue by those who seem to be admitting that their own motives for  addressing "voter fraud" are not quite so pure as your own:

http://www.salon.com/2012/07/27/fla_republican_we_suppressed_black_votes/

http://www.youtube.com/watch?v=EuOT1bRYdK8

It begs the question, have you spoken out against efforts actually do appear to intentionally target minority voters.

If not, why not?

Best,

Sal Peralta

________________________________
From: Joe La Rue <joseph.e.larue at gmail.com<mailto:joseph.e.larue at gmail.com>>
To: law-election at uci.edu<mailto:law-election at uci.edu>
Sent: Friday, February 8, 2013 7:35 AM
Subject: [EL] Voter fraud? What voter fraud!?! Nothing to see here, people. Move along.

This is not directed at Rick, who has candidly acknowledged that voter fraud does, sometimes, happen.  But there are others who say that "voter fraud" is nothing but an invention of those who want to suppress voters by requiring photo ID.  Worse, some say that it is an invention to keep minorities from voting.  Well, for all who say that voter fraud never, ever, happens, here's another example of that "non-existent" phenomenon. http://www.nationalreview.com/corner/340174/voter-fraud-never-happens-keeps-coming-back-john-fund

Joe
___________________
Joseph E. La Rue
cell: 480.272.2715<tel:480.272.2715>
email: joseph.e.larue at gmail.com<mailto: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.

_______________________________________________
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---------- Forwarded message ----------
From: dasmith <dasmith at UFL.EDU<mailto:dasmith at UFL.EDU>>
To: <law-election at department-lists.uci.edu<mailto:law-election at department-lists.uci.edu>>, <twang at demos.org<mailto:twang at demos.org>>, rick hasen <rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>>, <johnfund99 at yahoo.com<mailto:johnfund99 at yahoo.com>>
Cc:
Date: Fri, 8 Feb 2013 11:30:03 -0500
Subject: Re: [EL] Voter fraud? What voter fraud!?! Nothing to see here, people. Move along.
indeed, i agree with rick that there are other serious issues regarding the fraudulent use of absentee ballots here in florida.

yet, ironically, as michael herron and i discovered and documented in early november, we have found several cases of super-conscientious absentee voters subsequently disenfranchising themselves if they moved to another county and updated their addresses on the voter file, but did so before the county canvassing board in their former county tabulated their absentee ballots.

we discuss this loophole in florida's election code here: http://electionsmith.wordpress.com/2012/11/01/exclusive-glitch-in-floridas-voter-registration-system-can-disenfranchise-absentee-voters/

i'm hopeful that the state legislature will address this Catch-22 in the coming legislative session, as it is mentioned as item 2 of additional considerations for reform in the florida secretary of state's list of recommendations, found here: http://www.dos.state.fl.us/pdf/2-4-2013_Recs_for_Increased_Accessibility_and_Efficiency_in_FL_Elections.pdf

dan

daniel a. smith, ph.d.

professor & uf research foundation professor (2010-2012)

coordinator, political science internship program

department of political science

003 anderson hall              |  phone: 352-273-2346<tel:352-273-2346>

po box 117325                  |  fax: 352-392-8127<tel:352-392-8127>

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On 2/8/2013 10:44 AM, Rick Hasen wrote:
I don't know any serious person studying this issue who says there is no election fraud.  The vast majority of the relatively small number of cases involve either election officials committing fraud, or voters, candidates, and others committing absentee ballot fraud.
The problem is that the supposed cure---voter id---does not stop these main types of fraud.
If John Fund and others started a serious push to eliminate the use of absentee ballots, then I would take their concerns about voter fraud much more seriously. But it is not a part of the antifraud measures proposed and adopted by those who claim this is a major problem.
On 2/8/13 7:35 AM, Joe La Rue wrote:
This is not directed at Rick, who has candidly acknowledged that voter fraud does, sometimes, happen.  But there are others who say that "voter fraud" is nothing but an invention of those who want to suppress voters by requiring photo ID.  Worse, some say that it is an invention to keep minorities from voting.  Well, for all who say that voter fraud never, ever, happens, here's another example of that "non-existent" phenomenon. http://www.nationalreview.com/corner/340174/voter-fraud-never-happens-keeps-coming-back-john-fund

Joe
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