[EL] "IRS Scrutiny" sins
Mark Schmitt
schmitt.mark at gmail.com
Mon Jul 8 18:12:36 PDT 2013
One comment: You write, "For would-be campaign activists, 13 months is a
lifetime."
But the whole point of the scrutiny is that these groups are not
supposed to be mainly "campaign activists." If they wanted to be
campaign activists, they could have formed as 527s or candidate
committees, which some of them appear to have been. What they were
delayed in receiving was a privileged status that would have permitted
them to take contributions anonymously for non-electoral purposes. They
may have (or may not have) wanted this status in order to intervene in
elections, but whatever the definition of "primary purpose" or
"exclusive purpose," the IRS is surely under no obligation to hurry up
the process so that they can intervene in the very next election.
------ Original Message ------
From: "Roy Schotland" <schotlan at law.georgetown.edu>
To: "Rick Hasen" <rhasen at law.uci.edu>
Cc: "law-election at UCI.edu" <law-election at uci.edu>
Sent: 7/8/2013 1:40:55 PM
Subject: [EL] "IRS Scrutiny" sins
>“IRS Scrutiny Went Beyond the Political” [NYTimes, about 501(c)
>application delay and undue inquiries imposed on a Palestinian Rights
>group of Minnesotans, also a group of "struggling musicians", et al]
>
>Posted onJuly 5, 2013 8:21 ambyRick Hasen
>
>(Hoping particularly for reactions from Ellen April, Doug Chapin, Rick
>Pildes)
>
>When the IRS story first broke, there was Great Fuss over whether the
>TeaParty groups had been singled out, or was the mess just generalized
>and neutral screw-up-- impacting surely small, un-networked groups like
>the Minnesotans for Palestinian Rights. But the sin here, I believe,
>isn't against Left or Right, it's against small grass-roots efforts.
>As if the Status Quo doesn't always have more than enough defenses, we
>find this major gov't agency giving very tough times to groups whose
>views I don’t share … but I always care about whether independent,
>often dissenting voices can come thru. That's why I (with lotsa
>company even if only a minority) care so much about defending
>Independent Spending, despite its many many negatives.
>
>Justin Levitt recently posted "Did you know we have a Taxpayer
>Advocate" (yes, it's a version of Ombudsman, which your AdLaw
>colleagues probably note); Justin was posting the new report by that
>IRS official that, among the 8 violations of the TParty groups'
>"taxpayer bill of [10] rights", was a 13-month freeze against any
>approvals of new TParty "501(c)[whatevers]". (No other category of
>applicants was similarly mistreated, going by that report.) For
>would-be campaign activists, 13 months is a lifetime.
>
>Nihilists would sweepingly reduce regulation, but whether or not we’re
>bound to have an FECwe’re bound to have some agencies with powers that
>could be used to impact elections. Surely e.g,, tax-exempt status must
>be regulated to protect against a variety of private-sector abuses.
>Given the likelihood that various agencies (e.g. DOJ, FCC and obviously
>FEC) could if they abuse their powers, improperly affect elections, we
>need more steps to head off such abuse or provide quick correction.
>Perhaps at agencies which may have such impacts, a higher priority on
>oversight of such operations? And for agencies without an ombudsman,
>perhaps an "activists' advocate" to probe any such alleged abuses, and
>report?
>
>
>
>
>
>Roy A. Schotland
>
>Professor Emeritus
>
>Georgetown Law Center
>
>600 New Jersey Ave. N.W.
>
>Washington, D.C. 20001
>
>202/662-9098
>
> fax: -9680
>
>
>
>From:law-election-bounces at department-lists.uci.edu
>[mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of
>Rick Hasen
>Sent: Monday, July 08, 2013 12:32 PM
>To: Smith, Brad
>Cc:law-election at UCI.edu
>Subject: Re: [EL] ELB News and Commentary 7/8/13
>
>
>
>Emphasis not added by me; That was emphasis added by Kent Cooper in
>Roll Call ---that's where the excerpt was coming from. See the
>original here:
>
>http://blogs.rollcall.com/moneyline/obstruction-based-on-rank-partisanship-at-fec/
>
>
>nthony Herman, the FEC general counsel until he left the commission
>last Friday, drafted a detailed analysis and background report on the
>information sharing with the Department of Justice over the last 20
>years. The report detailed specific examples of cooperation on numerous
>matters. He submitted it to the commissioners at the end of June.
>
>Herman stressed that “sharing information with DOJ promotes the
>enforcement of the FECA …” “Record and information sharing with DOJ not
>only promotes DOJ’s enforcement of the Act, but the Commission’s
>enforcement as well. As discussed above, as the Commission increased
>its efforts to freely and openly cooperate with DOJ in the 1990s and
>2000s, DOJ has responded in kind and provided the Commission with
>valuable information that has helped the Commission fulfill its
>independent role as the prosecutor of civil violations of the Act.”
>
>The general counsel’s conclusion stated: “The Commission and OGC
>[Office of the General Counsel] have worked for years to achieve the
>mutually beneficial relationship the Commission enjoys with DOJ today.
>Those efforts – and the multiple benefits that have accrued to the
>Commission and the regulated community as a result – should not be
>wasted on unnecessary impediments to information sharing between the
>Commission and DOJ. Any steps that would make it more difficult for
>the Commission to share with DOJ would put the Commission out of step
>with other independent federal agencies, while resulting in no
>offsetting benefits to the Commission or the political community. It
>would open up the Commission to charges of obstruction based on rank
>partisanship. The Commission should therefor continue its
>long-established practice of freely cooperating with DOJ – as it has
>for more than 20 years.” [Emphasis added in bold.]
>
>
>
>On 7/8/13 9:29 AM, Smith, Brad wrote:
>
>>We also get in today's blurbs departing FEC General Counsel Anthony
>>Herman arguing that "Any steps that would make it more difficult for
>>the Commission to share with DOJ would put the Commission out of step
>>with other independent federal agencies, while resulting in no
>>offsetting benefits to the Commission or the political community. It
>>would open up the Commission to charges of obstruction based on rank
>>partisanship." (emphasis added by Rick)
>>
>>
>>
>>First, to clear the debris. I'm not sure why Rick added the emphasis.
>>It can't be because rank partisanship obstructs the Commission now.
>>There is virtually no serious observer of the FEC who believes that.
>>It is quite clear that ideology and corresponding interpretations of
>>the law, not "rank partisanship," dominate the Commission's
>>decision-making, with the Republicans frequently voting against
>>prosecution of Democratic and Democratic allied respondents, while the
>>Democrats vote in favor.
>>
>>
>>
>>Nevertheless, it is important that the FEC avoid partisan domination,
>>and perhaps Mr. Herman is correct that involving the Commissioners in
>>deciding which matters are shared with Justice would "open up the
>>Commission to charges of obstruction based on rank partisanship"
>>(regardless of the merits, and as if such charges are not routinely
>>made today). That is why the Commission is structured as it is, with
>>6 commissioners and a 4 vote majority required to exercise many of its
>>responsibilities.
>>
>>
>>
>>On to the issue:
>>
>>
>>
>>It should be noted that the answer is hardly what Mr. Herman and the
>>New York Times seems to think. The statute is clear:
>>
>>
>>
>>2 USC 437c (c): "the affirmative vote of 4 members of the Commission
>>shall be required in order for the Commission to take any action in
>>accordance with paragraph (6), (7), (8), or (9) of Section 437d(a) of
>>this title..."
>>
>>
>>
>>2 USC 437d (a): "The Commission has the power ... (9) to conduct
>>investigations ... and to report apparent violations to the
>>appropriate law enforcement authorities."
>>
>>
>>
>>That is to say, "the affirmative vote of 4 members of the Commission
>>shall be required in order for the Commission to ... report apparent
>>violations to the appropriate law enforcement authorities."
>>"Appropriate law enforcement authorities" would seem to include DOJ.
>>
>>
>>
>>The DOJ/FEC arrangement has not been the uniformly beneficial process
>>that Mr. Herman suggests, but more importantly, it appears to have
>>been an extra-legal, if not (more likely) illegal process adopted by
>>the Office of General Counsel. That it has gone on for some time does
>>not make it legal or appropriate. And it should be noted that
>>Commission staff can be - and have at time been - charged with acting
>>on "rank partisanship" as well. Perhaps, then, a system of checks and
>>balances makes sense.
>>
>>
>>
>>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
>>
>>--------------------------------------------------------------------------------
>>From:law-election-bounces at department-lists.uci.edu
>>[law-election-bounces at department-lists.uci.edu] on behalf of Rick
>>Hasen [rhasen at law.uci.edu]
>>Sent: Monday, July 08, 2013 11:47 AM
>>To:law-election at UCI.edu
>>Subject: [EL] ELB News and Commentary 7/8/13
>>
>>Quote of the Day
>>Posted onJuly 8, 2013 8:39 ambyRick Hasen
>>
>>“Super PACs may be bad for America, but they’re very good for CBS.”
>>
>>Les Moonves, head of CBS, quoted in NY Times, Campaign Ad Cash Lures
>>Buyers to Swing-State TV Stations (via Political Wire).
>>
>>
>>Posted incampaign finance|Comments Off
>>
>>“An Effects-Test Pocket Trigger?”
>>Posted onJuly 8, 2013 8:36 ambyRick Hasen
>>
>>Travis Crum, who wrote an excellent student note on Section 3 bail in
>>under the Voting Rights Act, has written this guest post:
>>
>>>An Effects-Test Pocket Trigger
>>>
>>>Travis Crum
>>>
>>> Following Shelby County v. Holder, civil rights advocates are
>>>searching for new strategies to protect voting rights. As I argued in
>>>my 2010 Yale Law Journal Note, section 3 of the Voting Rights Act
>>>provides a roadmap for the future. Commonly called the bail-in
>>>mechanism or the pocket trigger, section 3 authorizes federal courts
>>>to place States and political subdivisions that have violated the
>>>Fourteenth or Fifteenth Amendments under preclearance. Designed to
>>>trigger coverage in “pockets of discrimination” missed by the
>>>coverage formula, section 3 has been used to bail-in over a dozen
>>>jurisdictions, including Arkansas, New Mexico, and Los Angeles
>>>County. Although the pocket trigger has been historically
>>>overshadowed by section 5, it has garnered recent attention as a
>>>potential replacement for the coverage formula (see here, here, here,
>>>and here).
>>>
>>>So what does section 3 have to offer? First and foremost, it’s
>>>already the law of the land. With no need for lengthy hearings and
>>>legislative maneuvering, civil rights groups and the Justice
>>>Department can move expeditiously to reconstruct the preclearance
>>>regime. Indeed, civil rights groups moved last week to bail-in Texas
>>>based on findings of intentional discrimination in its 2011
>>>redistricting plans. Second, because section 3 utilizes a coverage
>>>mechanism, it sidesteps the “equal sovereignty of the States” problem
>>>inherent in any coverage formula. Third, the pocket trigger doesn’t
>>>single out jurisdictions using decades-old proxies. Rather, section 3
>>>perfectly tailors preclearance to “current conditions,” namely
>>>contemporary constitutional violations. And finally, the pocket
>>>trigger relies on judges—not Congress—to select jurisdictions for
>>>coverage.
>>>
>>>The pocket trigger also reduces preclearance’s federalism costs.
>>>Courts have often required jurisdictions to preclear only certain
>>>problematic changes. Arkansas, for example, was required to preclear
>>>majority-vote requirements. Courts have further tailored section 3
>>>preclearance by setting temporal limitations. Instead of mandating
>>>preclearance for a twenty-five year period, courts have fashioned
>>>more limited sunset dates—often imposing preclearance for a decade.
>>>
>>>To be sure, the current bail-in mechanism has its limitations.
>>>Establishing a constitutional violation is no easy task, and bail-in
>>>litigation will stretch the resources of civil rights groups. The
>>>pocket trigger, moreover, forces civil rights groups and the Justice
>>>Department to go on the offensive; though once a jurisdiction is
>>>bailed-in, the balance of time and inertia would flip back in favor
>>>of minority voters.
>>>
>>>In light of these concerns, the pocket trigger should be amended to
>>>authorize bail-in for violations of section 2 of the Voting Rights
>>>Act. As I stated in my 2010 piece, Congress should “decouple section
>>>3 from its constitutional trigger, predicating bail-in on a finding
>>>of discriminatory effect.” In a post-Shelby County world, an
>>>effects-test pocket trigger has several advantages.
>>>
>>>At the outset, it’s difficult to imagine a revamped coverage formula
>>>that could survive Congress and the Court. Many members of Congress
>>>would be loath to implicitly label their State as racist. Even
>>>agreeing on a coverage formula may be a political and theoretical
>>>fool’s errand. Although problems with the coverage formula were
>>>flagged during the 2006 reauthorization, there is still no
>>>agreed-upon replacement formula. And any revised coverage formula
>>>would have to satisfy Shelby County’s requirement that Congress
>>>“identify those jurisdictions to be singled out [for coverage] on a
>>>basis that makes sense in light of current conditions.”
>>>
>>>So how would an effects-test pocket trigger work in practice? It
>>>would make bailing-in jurisdictions far easier and quicker.
>>>Litigation is a costly and lengthy endeavor, and evidence to support
>>>intentional discrimination claims can be difficult to acquire. An
>>>effects-test pocket trigger would ease these burdens and
>>>fundamentally alter the cost/benefit analysis for bringing section 2
>>>suits. Most significantly, jurisdictions may find it in their
>>>self-interest to settle. In this age of austerity, governments,
>>>particularly local ones, are financially strapped and may view a
>>>preclearance settlement to be in their best interest. Indeed, the
>>>majority of section 3 cases have ended with consent decrees. For
>>>their part, civil rights groups and the Justice Department may be
>>>more willing to bring suit if they know that a preclearance remedy
>>>can be imposed at the end of litigation. This additional incentive
>>>might encourage more litigation against local jurisdictions, which
>>>are rarely the targets of section 2 litigation because the costs are
>>>too high.
>>>
>>>Amending section 3 to authorize bail-in for violations of section 2
>>>is a relatively straightforward response to Shelby County. But
>>>Congress need not stop there. Congress, for instance, could require
>>>bail-in for certain section 2 violations, such as a finding that a
>>>redistricting plan has a discriminatory effect. Congress could also
>>>set guidelines for how long jurisdictions should be bailed-in: a
>>>discriminatory polling place change could require preclearance for
>>>four years whereas a discriminatory redistricting plan could trigger
>>>coverage for ten years. And as Rick Pildes recently noted on this
>>>blog, Congress could fuse the civil-rights and universalist models by
>>>requiring preclearance for violations of HAVA and the Motor Voter
>>>Act—though this approach would necessitate a dramatic rethinking of
>>>preclearance’s doctrinal underpinnings, which target racial
>>>discrimination in voting.
>>>
>>>Only time will tell if Congress responds to Shelby County. But by
>>>combining an enforcement action with a prophylactic remedy, the
>>>pocket trigger provides civil rights groups and the Justice
>>>Department with an immediate response to Shelby County and gives
>>>Congress a template for how to design a preclearance regime without a
>>>coverage formula.
>>>
>>
>>Posted inSupreme Court, Voting Rights Act|Comments Off
>>
>>“Oregon Senate rejects universal voter registration proposal”
>>Posted onJuly 8, 2013 8:32 ambyRick Hasen
>>
>>The Oregonian reports.
>>
>>
>>Posted invoting|Comments Off
>>
>>“‘As singular a failure as I’ve seen in the history of the Supreme
>>Court’? McGinnis on Windsor, not Shelby County”
>>Posted onJuly 8, 2013 8:29 ambyRick Hasen
>>
>>Kevin Walsh:
>>
>>Even Totenberg nods.
>>
>>>Nina Totenberg’s end-of-the-term review (HT: How Appealing) includes
>>>an extended rip on the Supreme Court’s 5-4 Voting Rights Act decision
>>>in Shelby County v. Holder, highlighting criticism by “academic and
>>>judicial conservatives.” The quoted critics are Charles Fried,
>>>Michael McConnell, and John McGinnis.
>>>
>>>One of the most stinging quotations is attributed to McGinnis.
>>>Totenberg’s story characterizes McGinnis as arguing that “the court’s
>>>conservatives let their own policy disagreements with Congress trump
>>>the clear meaning of the Constitution and the post Civil War
>>>amendments.” She then quotes McGinnis’s comments at a recent judicial
>>>conference: “I’m sorry to say I think this opinion was as singular a
>>>failure as I’ve seen in the history of the Supreme Court.”
>>>
>>>The quotation comes from McGinnis’s comments on the Supreme Court
>>>review panel at the Fourth Circuit Judicial Conference. McGinnis did
>>>utter those words, but he was not talking about Shelby County.
>>>Instead, he was talking about Justice Kennedy’s opinion for the Court
>>>in United States v. Windsor. That’s a big difference….
>>>
>>>Totenberg’s other critical quotations about Shelby County seem
>>>correct given their content and context. But while it may be true
>>>that “two out of three ain’t bad” in some circumstances, this is not
>>>one of them.
>>>
>>>The idea that “academic and judicial conservatives” think Shelby
>>>County is wrong has already begun to spread. Rick Hasen’s influential
>>>Election Law Blog, for example, posts an extended excerpt from the
>>>Totenberg story under the post title, “Conservatives Criticize Shelby
>>>County Reasoning.”
>>>
>>I’ve reviewed the video and Walsh seems correct. I’ve updated my
>>original post to link to this one.
>>
>>
>>Posted inUncategorized|Comments Off
>>
>>“Deadlock by design hobbles election agency; The FEC was born of
>>idealism after Nixon era excesses, but its GOP members have all but
>>shut it down”
>>Posted onJuly 8, 2013 8:22 ambyRick Hasen
>>
>>Important Boston Globe report:
>>
>>>The FEC has often been the subject of criticism since its founding
>>>four decades ago. But the impression of weakness has escalated
>>>dramatically, as Republicans named to the panel in 2008, united in
>>>the belief that the commission had been guilty of regulatory
>>>overreach, have moved to soften enforcement, block new rules, and
>>>limit oversight.
>>>
>>>In essence, according to critics, the FEC has been rendered
>>>toothless, and at the worst possible time, when powerful special
>>>interests are freer than they have been in decades to exert financial
>>>influence on Washington politicians.
>>>
>>>The commission is taking up far fewer enforcement cases — down to 135
>>>in 2012, from 612 in 2007. And those cases it does consider often go
>>>nowhere. The frequency of deadlocked votes resulting in dismissed
>>>cases — like the case of the Romney friend’s chartered jet — has shot
>>>up, to 19 percent, from less than 1 percent, according to figures
>>>compiled by critics of its performance.
>>>
>>And there’s this:
>>
>>>The commission — which has 375 employees and a budget of $66 million
>>>— had been unable to make formal decisions for the previous six
>>>months: With four vacancies, it was down to just two members.
>>>Weintraub, a Harvard-educated lawyer who earned her Washington
>>>stripes as counsel for the House Ethics Committee, was ready to get
>>>to work.
>>>
>>>“I was all excited when everyone showed up,’’ she said. “I sent them
>>>an e-mail saying, ‘Welcome. What can I do to help your transition?
>>>I’m happy to provide any information about how we do things. My door
>>>is always open.’ ”
>>>
>>>Weintraub received no response, establishing what she described as a
>>>pattern of the Republicans keeping to themselves. Any substantive
>>>discussion takes place in formal meetings. She noticed that the GOP
>>>members and their staffers even went to lunch as a group, huddling in
>>>a knot in the elevator lobby.
>>>
>>>Weintraub said she rarely has private conversations with McGahn,
>>>whose office is next door to hers.
>>>
>>>“He in fact does not return my phone calls,’’ she said. “He never
>>>has.’’
>>>
>>
>>Posted incampaign finance, federal election commission|Comments Off
>>
>>“Obstruction Based on Rank Partisanship at FEC?”
>>Posted onJuly 8, 2013 8:19 ambyRick Hasen
>>
>>FEC General Counsel Anthony Herman’s parting words:
>>
>>>The General Counsel’s conclusion stated: “The Commission and OGC
>>>[Office of the General Counsel] have worked for years to achieve the
>>>mutually beneficial relationship the Commission enjoys with DOJ
>>>today. Those efforts – and the multiple benefits that have accrued
>>>to the Commission and the regulated community as a result – should
>>>not be wasted on unnecessary impediments to information sharing
>>>between the Commission and DOJ. Any steps that would make it more
>>>difficult for the Commission to share with DOJ would put the
>>>Commission out of step with other independent federal agencies, while
>>>resulting in no offsetting benefits to the Commission or the
>>>political community. It would open up the Commission to charges of
>>>obstruction based on rank partisanship. The Commission should
>>>therefor continue its long-established practice of freely cooperating
>>>with DOJ – as it has for more than 20 years.” [emphasis added in
>>>bold]
>>>
>>
>>Posted incampaign finance, federal election commission|Comments Off
>>
>>“Sabotage at the Election Commission”
>>Posted onJuly 8, 2013 7:46 ambyRick Hasen
>>
>>Important NYT editorial, which begins:
>>
>>>The Federal Election Commission is already in a state of wretched
>>>dysfunction, but it will only get worse if Republican members succeed
>>>in crippling the agency further when the commission meets on
>>>Thursday. The three Republicans on the commission appear ready to
>>>take advantage of a temporary vacancy on the three-member Democratic
>>>side to push through 3-to-2 votes for a wholesale retreat from
>>>existing regulations.
>>>
>>The FEC as good as dead? Worse than dead.
>>
>>
>>Posted incampaign finance, federal election commission|Comments Off
>>
>>“Where’s the Beef?”: Newby on the Bauer-Ginsberg Commission
>>Posted onJuly 8, 2013 7:43 ambyRick Hasen
>>
>>See here (h/t Doug Chapin).
>>
>>
>>Posted inelection administration|Comments Off
>>
>>--
>>Rick Hasen
>>Chancellor's Professor of Law and Political Science
>>UC Irvine School of Law
>>401 E. Peltason Dr., Suite 1000
>>Irvine, CA 92697-8000
>>949.824.3072 - office
>>949.824.0495 - fax
>>rhasen at law.uci.edu
>>http://law.uci.edu/faculty/page1_r_hasen.html
>>http://electionlawblog.org
>
>
>
>--
>Rick Hasen
>Chancellor's Professor of Law and Political Science
>UC Irvine School of Law
>401 E. Peltason Dr., Suite 1000
>Irvine, CA 92697-8000
>949.824.3072 - office
>949.824.0495 - fax
>rhasen at law.uci.edu
>http://law.uci.edu/faculty/page1_r_hasen.html
>http://electionlawblog.org
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