[EL] "FEC Deadlock Derail Matters"

JBoppjr at aol.com JBoppjr at aol.com
Tue Feb 19 04:02:54 PST 2013


If one picks out an irrelevant characteristic to identify the two side, it  
does mislead rather than illuminate.  What if the 3 Reps happened to be  
female and the 3 Dems male. It would be accurate to say that the Commission  
split along gender lines but this would certainly be misleading.  As  Brad 
correctly pointed out, the obvious conclusion one can draw by the  persistent 
use of the word "partisan" is to suggest that the underlying motive  is 
political party advantage, not ideology, which is the actual reason.   Jim
 
 
In a message dated 2/18/2013 5:54:02 P.M. Eastern Standard Time,  
tpotter at capdale.com writes:

If the reality is that the votes are 3 Democratic Commissioners vs 3  
Republicans, that is a "partisan" split, even if not motivated by partisan  
purposes. . The fact that the reasons for the split are to advance an  
ideological or legal agenda, rather than the interests of a political party,  do not 
make the vote non-partisan. When 41 Senators vote to continue debating  the 
Hagel nomination, that is correctly reported as a "split of the Senate  along 
partisan lines" although most if not all Republicans would say it was  not 
a "partisan vote."


That of course does not even address the possibility that the two parties  
now have partisan positions on campaign finance law and enforcement, and 
that  the Commissioners are accurately reflecting their party's broader 
ideological  and political positions in their votes on enforcement matters.


Trevor Potter

Sent from my iPad

On Feb 18, 2013, at 2:03 PM, "_JBoppjr at aol.com_ (mailto:JBoppjr at aol.com) " 
<_JBoppjr at aol.com_ (mailto:JBoppjr at aol.com) > wrote:





Craig, if it is true that the 3-3 votes are  "not pro-Democratic  or 
pro-Republican; they are ideological," which I also think they are, then  why do 
you refer to them as "partisan?" If they are ideological then the  fact that 
they line up as Repubs on one side and Dems on the other is just  
coincidental. but referring to them as "partisan" is misleading also  since it implies 
that they are for political purposes. So why the "partisan"  label? Jim Bopp
 
 
In a message dated 2/18/2013 9:15:53 A.M. Eastern Standard Time, 
_holman at aol.com_ (mailto:holman at aol.com)   writes:



Hi Justin:

Nearly all of the split votes  are 3-3, but there are some cases in which a 
commissioner recused him- or  herself, so a split vote could be 3-2. The 
split votes are not  pro-Democratic or pro-Republican; they are ideological. 
The Republican  members have consistently voted to prevent enforcement of 
much of the law  against anybody, regardless of party.

I have not tried doing a  content analysis of the matters subject to a 
vote. Though it would be  interesting to try to see if specific content matters 
are subject to the  deadlock phenomenon, the primary point behind these 
numbers is already  made.






Craig Holman, Ph.D.
Government Affairs  Lobbyist
Public Citizen
215 Pennsylvania Avenue SE
Washington,  D.C. 20003
T-(202) 454-5182
C-(202) 905-7413
F-(202)  547-7392
_Holman at aol.com_ (mailto:Holman at aol.com) 




-----Original  Message-----
From: Justin Levitt <_jml269 at connect.yale.edu_ 
(mailto:jml269 at connect.yale.edu) >
To:  law-election <_law-election at department-lists.uci.edu_ 
(mailto:law-election at department-lists.uci.edu) >
Sent:  Sun, Feb 17, 2013 9:36 pm
Subject: Re: [EL] "FEC Deadlock Derail  Matters"


Two sincere questions, both pertinent to a  paper I'm editing at the moment.

1:  Craig, in your chart, are  all of the "split" votes 3-3, along party 
lines?  That is, are any of  the instances of the 25 splits in 2012 
cross-party or 4-2 decisions?   (And is the updated chart available online?)

2:  If plausible  differences in constitutional and/or statutory 
interpretation aren't the  cause of the splits, why aren't all of the enforcement 
votes 3-3 (or at  least all of the enforcement votes targeting entities 
perceived as aligned  with Republicans or Democrats)?  That is, what explains why 25 
votes  in 2012 were splits, but 110 weren't?

Justin

On 2/17/2013 9:09 PM, Smith, Brad  wrote:


No,  just the misrepresentation of why they occur and what they mean.


Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
   Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
614.236.6317
_http://law.capital.edu/faculty/bios/bsmith.aspx_ 
(http://law.capital.edu/faculty/bios/bsmith.aspx) 


  
____________________________________
  
From: Craig Holman [_holman at aol.com_ (mailto:holman at aol.com) ]
Sent:  Sunday, February 17, 2013 8:40 PM
To: Smith, Brad; _law-election at uci.edu_ (mailto:law-election at uci.edu) 
Subject:  Re: [EL] "FEC Deadlock Derail Matters"


So, Brad, the numbers do indeed frustrate you.  




Craig Holman, Ph.D.
Government Affairs  Lobbyist
Public Citizen
215 Pennsylvania Avenue SE
Washington,  D.C. 20003
T-(202) 454-5182
C-(202) 905-7413
F-(202)  547-7392
_Holman at aol.com_ (mailto:Holman at aol.com) 




-----Original  Message-----
From: Smith, Brad _<BSmith at law.capital.edu_ (mailto:BSmith at law.capital.edu) 
>
To:  law-election _<law-election at uci.edu_ (mailto:law-election at uci.edu) >
Sent:  Sun, Feb 17, 2013 8:16 pm
Subject: Re: [EL] "FEC Deadlock Derail  Matters"


Craig's  post, like the Bloomberg BNA story that launched this thread, also 
 demonstrates why it is so hard for people to understand the FEC.   


The debate in the Agency is rather obviously not between those who  
"believe in the law  and those who don't" (unless Craig means to put he and all the 
reformers  who don't believe in Citizens United and other Supreme Court 
decisions  in the latter camp), but between different understandings of what 
the  law requires and/or permits. For years the regulatory speech camp which  
Craig represents has sought to portray the FEC as a fight of good  against 
evil, and to suggest that anyone who doesn't agree with their  particular 
interpretations of the law is in actuality simply refusing to  enforce the law. 
Most of the lawyers on this list, however, are  sophisticated enough to 
understand that "the law" is not what a handful  of advocacy groups seeking 
more regulation say it is (a kind of  "brooding omnipresence," apparently), but 
rather what Congress has  actually passed and how it is interpreted by the 
body assigned by  Congress to administer it, subject to judicial review. 
Even error is not  a malignant refusal to do one's duty, but that possibility 
seems not to  occur to the anointed.  
 


For years many persons in the  self-described "reform community" have 
regularly maligned, in the most  casual, off-hand manner, and deeply cynical 
manner, the integrity of all  those who disagree with them on what the law 
requires or permits. It's a  low-rent practice that ought to stop. 


Meanwhile, Public Citizen's press release  again cynically tries to sell 
this as a problem of "partisanship" rather  than one of ideology. A 3-3 vote 
is a 3-3 vote, but in thinking about  whether and how it matters (no doubt 
Craig would be happier if 4  commissioners "did not believe in the law" and 
the votes were 4-2), it  is important whether in fact it is simply raw 
partisanship on display or  whether there are legitimate (or even illegitimate) 
disagrees about the  meaning of the law and its proper and best 
interpretations. It is true  that the ideological division breaks along partisan lines. And 
having  accused the "reform community" of cynicism, perhaps I am myself too 
 cynical in presuming that Public Citizen likes the "partisan" spin  simply 
because they see that as getting more traction with the public  and 
credulous journalists. But I believe it is a conscious spin because  they recognize 
that when they say the issue is "partisan," people will  think that 
Commissioners from each party are simply protecting their  own, rather than having 
serious debate over the law. It is quite obvious  (at least to all those who 
seriously follow the Commission, including  Craig) that any problem is not 
because Commissioners from each party  simply seek to protect their own. But 
that sounds better than saying  that the law operates in a difficult area 
of First Amendment liberties,  and there is no easy answer to issues of 
corruption in  politics. 


It would also be interesting to go back and  look at how little the 
argument of the anti-FEC lobby has changed. When  the percentages of 3-3 votes were 
much lower (see Craig's charts), as  during my time on the Commission, we 
heard exactly the same arguments  alleging "partisan gridlock" etc. etc. that 
we hear today. This might  lead one to think that while it is (for Craig, 
at least) a happy  coincidence that 3-3 votes are increasing, that's not 
really what is  important to most critics. What is important is to explain away 
the  failures of the regulatory regime in a way that does not suggest a  
complex issue of First Amendment liberties and practical realities.  
Commissioners come and go; Presidents come and go; General Counsels come  and go. 
There is legislation and there are judicial decisions, and the  Supreme Court 
swings towards greater deference to the First Amendment  and then away, then 
back again. "Loopholes" are eliminated and new ones  discovered. But one 
thing is always the same - the failure of the reform  project to acheive 
meaningful improvements in government or in  positively affecting the lives of 
citizens is not a problem with the law  or the underlying principles of 
"reform," but with the people selected  to run things, who simply don't believe in 
"the law." To consider that  possibility would truly turn worlds upside down.



 
 
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
   Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
614.236.6317
_http://law.capital.edu/faculty/bios/bsmith.aspx_ 
(http://law.capital.edu/faculty/bios/bsmith.aspx) 


  
____________________________________
  
From: _law-election-bounces at department-lists.uci.edu_ 
(mailto:law-election-bounces at department-lists.uci.edu)   
[_law-election-bounces at department-lists.uci.edu_ (mailto:law-election-bounces at department-lists.uci.edu) ]  on behalf 
of Craig Holman [_holman at aol.com_ (mailto:holman at aol.com) ]
Sent:  Sunday, February 17, 2013 6:07 PM
To: _law-election at uci.edu_ (mailto:law-election at uci.edu) 
Subject:  Re: [EL] "FEC Deadlock Derail Matters"



I just updated the figures on FEC split votes. Besides the numbers  that so 
frustrate Brad -- of which I need not debate, the numbers speak  for 
themselves -- are the numbers of radically declining actions. The  FEC is not just 
immobilized between those commissioners who believe in  the law and those 
who don't (the deadlock numbers), it is actually  deadlocking on far, far 
fewer actions under consideration.

So,  while split votes on enforcement matters has increased eight-fold, the 
 number of actions under consideration has plummeted ten-fold.  

The dysfunction within the commission clearly is demoralizing  the staff of 
the agency as well. Though I have the highest regard for  the staff, it is 
hard to work well when the commissioners will  not.

Updated chart is attached.




Craig Holman, Ph.D.
Government Affairs  Lobbyist
Public Citizen
215 Pennsylvania Avenue SE
Washington,  D.C. 20003
T-(202) 454-5182
C-(202) 905-7413
F-(202)  547-7392
_Holman at aol.com_ (mailto:Holman at aol.com) 




-----Original  Message-----
From: Smith, Brad <_BSmith at law.capital.edu_ (mailto:BSmith at law.capital.edu) 
>
To:  _law-election at UCI.edu_ (mailto:law-election at UCI.edu)  
<_law-election at uci.edu_ (mailto:law-election at uci.edu) >
Sent:  Sat, Feb 16, 2013 5:19 pm
Subject: Re: [EL] "FEC Deadlock Derail  Matters"


This  is the type of reporting that is so frustrating.   


First, if a faculty, for example, has a rule requiring a two-thirds  vote 
for tenure, we wouldn't normally say that a 19-13 vote "derailed"  tenure. 
Indeed, if you had a simple majority rule, we wouldn't usually  say that a 
16-16 vote was a "deadlock." We would say the person was  denied tenure. If the 
House votes 216-216 on a measure, we don't say it  "deadlocked," we say the 
measure lost.


Similarly, when the FEC votes 3-3 not to find reason to believe, it  has 
not found reason to believe that the law was broken, the predicate  for an 
investigation under the statute.


Second, the article not only tells us that the Commission  "deadlocked," 
but that it "deadlocked along party lines." Factually  accurate, true. But 
pretty much everyone who follows the Commission  agrees that partisanship is 
not the reason for 3-3 votes. It would be  sort of like writing, "President 
Obama today nominated one Republican  and one Democrat to seats on the 
FEC...," and leaving it at that. Such  an act would not really be a demonstration 
of bipartisanship, but if it  were not explained later why he nominated a 
Republican, it is simply  misleading. 
 


Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
   Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
614.236.6317
_http://law.capital.edu/faculty/bios/bsmith.aspx_ 
(http://law.capital.edu/faculty/bios/bsmith.aspx) 


  
____________________________________
  
From: _law-election-bounces at department-lists.uci.edu_ 
(mailto:law-election-bounces at department-lists.uci.edu)   
[_law-election-bounces at department-lists.uci.edu_ (mailto:law-election-bounces at department-lists.uci.edu) ]  on behalf 
of Rick Hasen [_rhasen at law.uci.edu_ (mailto:rhasen at law.uci.edu) ]
Sent:  Saturday, February 16, 2013 4:05 PM
To: _law-election at UCI.edu_ (mailto:law-election at UCI.edu) 
Subject:  Re: [EL] ELB News and Commentary 2/16/13



 
_“FEC Deadlocks Derail Matters Involving Crossroads GPS,  Family-Member 
Super PAC”_ (http://electionlawblog.org/?p=47362)  
Posted  on _February 15, 2013 5:50  pm_ 
(http://electionlawblog.org/?p=47362)  by _Rick Hasen_ (http://electionlawblog.org/?author=3)  
 
_Bloomberg BNA_ 
(http://news.bna.com/mpdm/MPDMWB/split_display.adp?fedfid=29745575&vname=mpebulallissues&jd=a0d6m0d6q4&split=0) :

The Federal Election Commission dismissed two cases involving  allegations 
of illegal coordination between congressional candidates  and outside 
spending groups after the commissioners deadlocked along  party lines regarding 
whether the cases should be investigated, the  FEC announced Feb. 15.
One case involved Crossroads GPS, among the most prominent  
Republican-leaning nonprofit groups involved in recent campaigns.  Designated Matter Under 
Review (MUR) 6368, the case involved  allegations that the group’s founder, 
Republican strategist Karl  Rove, illegally coordinated efforts with 
then-Rep. Roy Blunt’s  (R-Mo.) successful 2010 campaign for U.S. Senate.
The other case (MUR 6611) involved a super PAC funded by the  mother of 
Laura Ruderman, an unsuccessful Democratic candidate for  the U.S. House in 
2012. The case was the FEC’s first consideration  of a single-candidate PAC 
financed by the candidate’s family,  according a written statement from three 
of the  commissioners.

 
_<ELFECDea>_ 
(http://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=47362&title=“
FEC%20Deadlocks%20Derail%20Matters%20Involving%20Crossroads%20GPS,%20Family-Member%20Super%20PAC”&description=) 


Posted  in _campaign finance_ (http://electionlawblog.org/?cat=10) , 
_federal election commission_ (http://electionlawblog.org/?cat=24)  |  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_ (mailto:rhasen at law.uci.edu) 

_http://law.uci.edu/faculty/page1_r_hasen.html_ 
(http://law.uci.edu/faculty/page1_r_hasen.html) 

_http://electionlawblog.org_ (http://electionlawblog.org/) 


_______________________________________________

Law-election mailing list

_Law-election at department-lists.uci.edu_ 
(mailto:Law-election at department-lists.uci.edu) 

_http://department-lists.uci.edu/mailman/listinfo/law-election_ 
(http://department-lists.uci.edu/mailman/listinfo/law-election) 


-- 

Rick Hasen

Chancellor's Professor of Law and Political Science

UC Irvine School of Law

401 E. Peltason Dr., Suite 1000

Irvine, CA 92697-8000

949.824.3072 - office

949.824.0495 - fax

_rhasen at law.uci.edu_ (mailto:rhasen at law.uci.edu) 

_http://law.uci.edu/faculty/page1_r_hasen.html_ 
(http://law.uci.edu/faculty/page1_r_hasen.html) 

_http://electionlawblog.org_ (http://electionlawblog.org/) 






_______________________________________________ Law-election mailing list
 _Law-election at department-lists.uci.edu_ 
(mailto:Law-election at department-lists.uci.edu) 
 _http://department-lists.uci.edu/mailman/listinfo/law-election_ 
(http://department-lists.uci.edu/mailman/listinfo/law-election) 











_______________________________________________
 Law-election mailing list
 _Law-election at department-lists.uci.edu_ 
(mailto:Law-election at department-lists.uci.edu) 
 _http://department-lists.uci.edu/mailman/listinfo/law-election_ 
(http://department-lists.uci.edu/mailman/listinfo/law-election) 








_______________________________________________

Law-election mailing list

_Law-election at department-lists.uci.edu_ 
(mailto:Law-election at department-lists.uci.edu) 

_http://department-lists.uci.edu/mailman/listinfo/law-election_ 
(http://department-lists.uci.edu/mailman/listinfo/law-election) 




_______________________________________________ Law-election mailing list
 _Law-election at department-lists.uci.edu_ (mai
lto:Law-election at department-lists.uci.edu) 
 _http://department-lists.uci.edu/mailman/listinfo/law-election_ 
(http://department-lists.uci.edu/mailman/listinfo/law-election) 





_______________________________________________
Law-election  mailing list
_Law-election at department-lists.uci.edu_ 
(mailto:Law-election at department-lists.uci.edu) 
http://department-lists.uci.edu/mailman/listinfo/law-election




_______________________________________________
Law-election  mailing list
_Law-election at department-lists.uci.edu_ 
(mailto:Law-election at department-lists.uci.edu) 
_http://department-lists.uci.edu/mailman/listinfo/law-election_ 
(http://department-lists.uci.edu/mailman/listinfo/law-election) 


<- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -  -> To 
ensure compliance with requirements imposed by the IRS, we inform you  that, 
unless specifically indicated otherwise, any tax advice contained in  this 
communication (including any attachments) was not intended or written to  be 
used, and cannot be used, for the purpose of (i) avoiding tax-related  
penalties under the Internal Revenue Code, or (ii) promoting, marketing, or  
recommending to another party any tax-related matter addressed herein. This  
message is for the use of the intended recipient only. It is from a law firm  and 
may contain information that is privileged and confidential. If you are  
not the intended recipient any disclosure, copying, future distribution, or  
use of this communication is prohibited. If you have received this  
communication in error, please advise us by return e-mail, or if you have  received 
this communication by fax advise us by telephone and delete/destroy  the 
document. <--> 
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://webshare.law.ucla.edu/Listservs/law-election/attachments/20130219/0f22adbe/attachment.html>


View list directory