[EL] ELB News and Commentary 11/19/13

Rick Hasen rhasen at law.uci.edu
Mon Nov 18 20:24:57 PST 2013


    What Would A Complaint Look Like If We Moved Voting Rights Beyond
    Race or Party? <http://electionlawblog.org/?p=56823>

Posted on November 18, 2013 7:48 pm 
<http://electionlawblog.org/?p=56823>by Rick Hasen 
<http://electionlawblog.org/?author=3>

In my forthcoming essay 
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2353068> (and 
related oped 
<http://www.nytimes.com/2013/11/16/opinion/voter-suppressions-new-pretext.html?_r=0>from 
this past weekend), I suggest a claim under the Equal Protection Clause 
against those states which have made voting harder for no good reason.  
It is not a racially based claim, nor a partisan gerrymandering claim, 
nor a Bush v. Gore claim. Instead I am advocating something like 
Burdick-Anderson balancing with teeth, where the state must prove with 
actual evidence that there is a problem which a strict voting law is 
reasonably tailored to solve.

That claim is not at issue in the Justice Department's cases against 
Texas or North Carolina, and it does not appear to be at issue in the 
Wisconsin voter id cases in federal court either.

But now it looks l 
<http://txredistricting.org/post/67018241032/texas-league-of-young-voters-expands-voter-id-claims-to>ike 
the Texas League of Young Voters may have filed just such a complaint 
<https://drive.google.com/file/d/0BxeOfQQnUr_geTJNem5hQVpSME0/edit?usp=sharing>against 
the State of Texas---though I would claim it should be unnecessary to 
prove a "severe" burden for this claim to succeed.

    Count 4
    117. Plaintiff-Intervenors reallege the facts set forth above.
    118. SB 14 violates the Equal Protection Clause of the Fourteenth
    Amendment to the United States Constitution, pursuant to 42 U.S.C. §
    1983, because it denies many Texas citizens, including
    Plaintiff-Intervenors, their constitutionally protected right to
    participate in elections on an equal basis with other Texas citizens.
    119. SB 14 imposes severe, unconstitutional burdens on the right to
    vote of many Texas citizens, particularly those who are poor, who
    lack one of the required IDs under SB 14.
    120. As a result of SB 14's particular requirements and other
    factors (such as the
    inaccessibility of many DPS offices), the amount of resources
    (including time and money) that many eligible voters will be forced
    to expend to obtain one of the required IDs will be substantial.
    121. Thousands, potentially hundreds of thousands, of Texas voters
    currently lack one of the required IDs and, therefore, will be
    forced to bear the significant cost of obtaining the necessary ID.
    122. Because the cost of complying with SB 14 will be prohibitive
    for many of these
    voters, SB 14 will disfranchise a significant number of registered
    and otherwise eligible Texas voters.
    123. Defendants have not demonstrated and cannot show an interest
    sufficient to justify the severe, unconstitutional burdens that SB
    14 places on many Texas voters who lack the requisite IDs.
    124. Though purportedly designed to protect against in-person voter
    fraud, there is no evidence that such voter fraud actually occurred
    in Texas before SB 14's passage or that existing State and federal
    laws did not adequately deter in-person voting fraud.
    125. SB 14 thus purportedly targets a problem that does not exist in
    fact. The law places a severe, unconstitutional burden on the
    fundamental right to vote of many Texas citizens, including
    Plaintiff-Intervenors, which is not justified by any legitimate
    countervailing state interest.

I'll be watching this one closely, as well as watching whether anyone 
makes a similar claim against North Carolina's new strict voting law.

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Posted in election administration <http://electionlawblog.org/?cat=18>, 
The Voting Wars <http://electionlawblog.org/?cat=60>, voter id 
<http://electionlawblog.org/?cat=9>, voting 
<http://electionlawblog.org/?cat=31>


    "Herring lawyer: recount 'extremely unlikely' to give Obenshain win"
    <http://electionlawblog.org/?p=56821>

Posted on November 18, 2013 7:26 pm 
<http://electionlawblog.org/?p=56821>by Rick Hasen 
<http://electionlawblog.org/?author=3>

That would be 
<http://www.dailypress.com/news/politics/dp-nws-herring-recount-lawyer-20131119,0,7725373.story>Marc 
Elias---most notably of the Franken-Coleman saga.  This one will be an 
easier commute for all the Washington lawyers.

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Posted in recounts <http://electionlawblog.org/?cat=50>


    Ohio Voter Integrity Project Defends Its Work
    <http://electionlawblog.org/?p=56819>

Posted on November 18, 2013 7:24 pm 
<http://electionlawblog.org/?p=56819>by Rick Hasen 
<http://electionlawblog.org/?author=3>

See here 
<http://news.cincinnati.com/apps/pbcs.dll/article?AID=/201311160522/EDIT02/311160040>.

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


    "Anti-Obama nonprofit tells IRS it's not 'political'"
    <http://electionlawblog.org/?p=56817>

Posted on November 18, 2013 7:23 pm 
<http://electionlawblog.org/?p=56817>by Rick Hasen 
<http://electionlawblog.org/?author=3>

CPI reports 
<http://www.publicintegrity.org/2013/11/18/13785/anti-obama-nonprofit-tells-irs-its-not-political>.

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Posted in campaign finance <http://electionlawblog.org/?cat=10>, tax law 
and election law <http://electionlawblog.org/?cat=22>


    "WI Club for Growth, Target of Walker Recall Probe, at Center of
    Dark Money Web" <http://electionlawblog.org/?p=56815>

Posted on November 18, 2013 7:21 pm 
<http://electionlawblog.org/?p=56815>by Rick Hasen 
<http://electionlawblog.org/?author=3>

See here. 
<http://www.prwatch.org/news/2013/11/12309/new-john-doe-investigation-probes-dark-money-wisconsin-recall-elections-club>

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Posted in campaign finance <http://electionlawblog.org/?cat=10>, tax law 
and election law <http://electionlawblog.org/?cat=22>


    How Much Non-Citizen Voting in Colorado? Not Much
    <http://electionlawblog.org/?p=56813>

Posted on November 18, 2013 7:20 pm 
<http://electionlawblog.org/?p=56813>by Rick Hasen 
<http://electionlawblog.org/?author=3>

As goes Arizona <http://electionlawblog.org/?p=56809>, so goesColorado 
<http://www.gjsentinel.com/news/articles/the-gessler-155-zero-prosecutions-so-far-of-people/>:

    After years of critics demanding that Gessler forward names of
    suspected non-citizens whom he said were on the voter rolls, his
    office referred a list of 155 suspected non-?citizen voters in July
    to 15 district attorneys across the state, recommending prosecution
    and issuing a strongly worded statement saying the list was proof
    the state's election system is "vulnerable."

    A check by The Daily Sentinel with those district attorneys over the
    past two weeks, however, revealed that none of the referrals led to
    criminal prosecutions, though some still are under investigation.
    The analysis also showed that although some of the non-citizen
    voters did cast ballots in at least one election going as far back
    as 2004, the preponderance of the other voters actually were
    citizens who legally had the right to vote.

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


    "Is the VRA Still Necessary?: Attitudinal Support of Electoral
    Reform in a Post-Jim Crow Era" <http://electionlawblog.org/?p=56811>

Posted on November 18, 2013 7:12 pm 
<http://electionlawblog.org/?p=56811>by Rick Hasen 
<http://electionlawblog.org/?author=3>

A group of researchers at the University of Maryland have postedthis 
draft <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2348755> on 
SSRN.  Here is the abstract:

    The Supreme Court's recently issued opinion in Shelby County,
    Alabama v. Holder (2013) declared an important part of the Voting
    Rights Act (VRA) unconstitutional, finding the 2006 reauthorized
    coverage formula to be inappropriate for an era where race based
    electoral discrimination has declined significantly. Interrogating
    the "Bull Connor is Dead" concept, this study explores public
    support for anti-democratic reforms in election law. We analyze
    survey results from the 2008 and 2012 Cooperative Congressional
    Election Study, newspaper content analysis, and Department of
    Justice data to measure the degree to which attitudinal and
    contextual determinants explain the trends in white support for
    three election reform policies that affect minority voting rights.
    Building on prior research, we expect that support for voter ID laws
    and support for voters reading the Constitution in both periods will
    be best predicted by whether a person voted for Barack Obama.
    Additionally, we expect that beliefs about blacks will also
    determine support for voter ID laws. Lastly, we expect that support
    for Election Day Registration will be influenced by whether a person
    experienced problems registering in the past and their level of
    interest in the news. The implications of this study address the
    benefits and consequences of considering attitudinal support for
    minority voting rights in a post-Jim Crow era where some deem the
    VRA unnecessary.

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Posted in Supreme Court <http://electionlawblog.org/?cat=29>, Voting 
Rights Act <http://electionlawblog.org/?cat=15>


    How Much Non-Citizen Voting in Arizona? Not Much
    <http://electionlawblog.org/?p=56809>

Posted on November 18, 2013 9:05 am 
<http://electionlawblog.org/?p=56809>by Rick Hasen 
<http://electionlawblog.org/?author=3>

Arizona Republic: 
<http://www.azcentral.com/news/politics/articles/20131105arizona-immigrant-vote-fraud-rare.html>

    Arizona has spent enormous amounts of time and money waging war
    against voter fraud, citing the specter of illegal immigrants'
    casting ballots.

    State officials from Gov. Jan Brewer to Attorney General Tom Horne
    to Secretary of State Ken Bennett swear it's a problem.

    At an August news conference, Horne and Bennett cited voter-fraud
    concerns as justification for continuing a federal-court fight over
    state voter-ID requirements. And some Republican lawmakers have used
    the same argument to defend a package of controversial new election
    laws slated to go before voters in November 2014.

    But when state officials are pushed for details, the numbers of
    actual cases and convictions vary and the descriptions of the
    alleged fraud become foggy or based on third-hand accounts.

    An examination of voter-fraud cases in Maricopa County shows those
    involving illegal immigrants are nearly non-existent, and have been
    since before the changes to voter-ID requirements were enacted in 2004.

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

-- 
Rick Hasen
Chancellor's Professor of Law and Political Science
UC Irvine School of Law
401 E. Peltason Dr., Suite 1000
Irvine, CA 92697-8000
949.824.3072 - office
949.824.0495 - fax
rhasen at law.uci.edu
http://www.law.uci.edu/faculty/full-time/hasen/
http://electionlawblog.org

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