[EL] Roberts Court campaign cases
Rick Hasen
rhasen at law.uci.edu
Fri Apr 11 10:07:30 PDT 2014
That's much less high salience than overturning a ban on corporate
contributions. It did not require overturning any precedent. And the
Court got involved early through some pre-cert. emergency requests,
which got it on the Court's radar.
On 4/11/14, 10:03 AM, Bill Maurer wrote:
>
> But what about /Arizona Free Enterprise Club v. Bennett/? That was
> taken via petition.
>
> Bill
>
> *From:*law-election-bounces at department-lists.uci.edu
> [mailto:law-election-bounces at department-lists.uci.edu] *On Behalf Of
> *Rick Hasen
> *Sent:* Friday, April 11, 2014 9:39 AM
> *To:* law-election at UCI.edu
> *Subject:* [EL] ELB News and Commentary 4/11/14
>
>
> A Tale of Two Campaign Finance Appeals at SCOTUS: Why No Push to
> Allow Corporate Contributions to Candidates?
> <http://electionlawblog.org/?p=60392>
>
> Posted on April 11, 2014 9:34 am
> <http://electionlawblog.org/?p=60392>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Pardon the inside-baseball post, but I think it reveals a little bit
> more about how the Court is going about dismantling what’s left of
> campaign finance limits.
>
> After the Supreme Court decided McCutcheon v. FEC
> <http://www.scotusblog.com/case-files/cases/mccutcheon-v-federal-election-commission/>,
> striking down the aggregate limits on federal contributions, it
> disposed of two other cases it had been holding since /McCutcheon. /In
> one case, James v. FEC
> <http://www.supremecourt.gov/Search.aspx?FileName=/docketfiles/12-683.htm>,
> also involving federal aggregate limits, the Court sent the appeal
> back to the district court to reconsider in light of /McCutcheon.
> /That’s sort of standard operating procedure when the Court holds a
> case and then decides another case on the same topic. (Indeed, Justin
> wrote a column for Justia
> <http://jurist.org/forum/2013/02/justin-levitt-campaign-finance.php#.U0gTxse0Y3Y>a
> while back suggesting that /James/ might have been a better case for
> the Court than /McCutcheon /when it came to striking aggregate limits.)
>
> In contrast, the Court denied cert.
> <http://www.nytimes.com/2014/04/08/us/politics/justices-decline-cases-on-gay-rights-and-campaign-finance.html>
> in Iowa Right to Life v. Tooker
> <http://www.supremecourt.gov/Search.aspx?FileName=/docketfiles/13-407.htm>,
> a case challenging a ban on direct corporate contributions to
> candidates and allowing them for unions. The union twist is somewhat
> different, but I litigated the corporate ban against Jim Bopp in the
> Ninth Circuit and won. And all circuits to have considered the issue
> (including the 4th Circuit, reversing a contrary decision in the
> /Danielczyk/ case) have rejected challenges to the corporate ban under
> the authority of an earlier Supreme Court case, /FEC v. Beaumont.
> <http://www.law.cornell.edu/supct/html/02-403.ZS.html>/
>
> /Beaumont/ was on somewhat shaky ground after /Citizens United/, and
> on very shaky ground now (for reasons I explained at /Slate/) under
> /McCutcheon. /I still think lower courts are bound to follow
> /Beaumont. /But one can easily imagine a lower court on remand in
> /Tooker/ saying something like “While we are bound by /Beaumont/, we
> don’t see how /Beaumont/ can coexist with /McCutcheon/ and we urge the
> Supreme Court to clarify and take the case.” But the Court denied
> cert., meaning the case is essentially over.
>
> So why the different treatment of /James/ and /Tooker/? There is both
> a procedural answer and a strategic answer.
>
> The procedural answer is that /James/ came up on an appeal and
> /Tooker/ on a cert. petition. A cert. denial means nothing on the
> merits but a decision on appeal, even if it is a summary affirmance or
> dismissal, means the lower court got it right (although not
> necessarily for the right reasons). I’ve written a lot about how
> mandatory appellate jurisdiction in some election cases has skewed
> those cases (it explains the demise of the poll tax, for example, as I
> explain in /The Supreme Court and Election Law
> <http://www.amazon.com/exec/obidos/tg/detail/-/0814736599/qid=1066951895/sr=1-1/ref=sr_1_1/104-9675773-2517511?v=glance&s=books>/).
> Michael Solimine and Josh Douglas have written on these courts too,
> and Will Baude had a recent blog post
> <http://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/04/02/where-do-the-supreme-courts-campaign-finance-cases-come-from/>on
> it. So procedurally the cert. denial in /Tooker/ is no big deal and
> expresses nothing on the merits.
>
> But strategically I think it is a big deal. A remand of /Tooker/ to
> reconsider in light of /McCutcheon/ almost certainly would have set up
> the case for eventual Supreme Court review―because the lower court
> likely would have seen itself bound by /Beaumont/ but seriously
> questioning /Beaumont/‘s reasoning.
>
> And CJ Roberts is playing the long game, not wanting to move quickly.
> It is pretty clear he resents the mandatory appellate jurisdiction
> that brings so many McCain-Feingold and FECA campaign finance cases
> directly to the Supreme Court. Note what the Chief writes in
> /McCutcheon/: “McCutcheon and the RNC appealed directly to thisCourt,
> as authorized by law. 28 U. S. C. §1253. In such a case, ‘we ha[ve] no
> discretion to refuse adjudication of the case on its merits,’ Hicks v.
> Miranda, 422 U. S. 332, 344 (1975), and accordingly we noted probable
> jurisdiction.568 U. S. ___ (2013).” And consider this exchange
> <http://www.supremecourt.gov/oral_arguments/argument_transcripts/08-205.pdf>
> between the Chief and Ted Olson in the first /Citizens United/ oral
> argument:
>
> MR. OLSON: I ― I think I would agree with that, but I would also
> say that the ― the idea, the functional equivalent of express
> advocacy is the very magic word problem that this Court has
> struggled with in McConnell and in ― in each of the cases.
> I would ― I said at the beginning that this is an incomprehensible
> prohibition, and I ― and my ― I think that’s demonstrated by the
> fact that since 2003 this Court has issued something close to 500
> pages of opinions interpreting and trying to apply the First
> Amendment to Federal election law. And I counted 22 separate
> opinions from the Justices of this Court attempting to ― in just
> the last 6 years, attempting to figure out what this statute
> means, how it can be interpreted. In fact --
> CHIEF JUSTICE ROBERTS: Well, that’s because it’s mandatory
> appellate jurisdiction. I mean, you don’t have a choice.
> (Laughter.)
>
> Roberts wants to go slow. As I explained here
> <http://electionlawblog.org/wp-content/uploads/hasen-thomas-daily-journal.pdf>,
> the contrast is with Justice Thomas, who hates Roberts’ faux judicial
> restraint and is ready to kill off all of campaign finance.
>
> A decision striking the corporate ban next would further enmesh the
> Court in controversy. I expect instead Roberts’ preferred order is (1)
> strike down federal soft money ban (for reasons explained in the
> /Slate/ piece); (2) strike individual contribution limits: (3) strike
> corporate ban.
>
> This is about strategy, not the end result.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60392&title=A%20Tale%20of%20Two%20Campaign%20Finance%20Appeals%20at%20SCOTUS%3A%20Why%20No%20Push%20to%20Allow%20Corporate%20Contributions%20to%20Candidates%3F&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> Supreme Court <http://electionlawblog.org/?cat=29>
>
>
> “GOP creates new fundraising group after McCutcheon ruling”
> <http://electionlawblog.org/?p=60389>
>
> Posted on April 11, 2014 8:57 am
> <http://electionlawblog.org/?p=60389>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Byron Tau
> <http://www.politico.com/story/2014/04/gop-fundraising-mccutcheon-105627.html>
> reports:
>
> In the wake of a major campaign finance ruling from the Supreme
> Court last week, the three major Republican Party committees have
> formed a new joint fundraising effort that will allow them to
> collect big checks from major donors.
>
> According to documents filed with the Federal Election Commission,
> the newly formed Republican Victory Fund is a joint fundraising
> committee composed of the Republican National Committee, the
> National Republican Congressional Committee and the National
> Republican Senatorial Committee.
>
> Guess we are starting to see if some of the “wild hypotheticals”
> mentioned at the /McCutcheon /oral argument will come true.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60389&title=%E2%80%9CGOP%20creates%20new%20fundraising%20group%20after%20McCutcheon%20ruling%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> Supreme Court <http://electionlawblog.org/?cat=29>
>
>
> “Conservative Firepower Has Senate Democrats Playing Defense”
> <http://electionlawblog.org/?p=60387>
>
> Posted on April 11, 2014 8:55 am
> <http://electionlawblog.org/?p=60387>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Nick Confessore reports
> <http://www.nytimes.com/2014/04/12/us/politics/conservative-firepower-has-senate-democrats-playing-defense.html?_r=0>
> for NYT.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60387&title=%E2%80%9CConservative%20Firepower%20Has%20Senate%20Democrats%20Playing%20Defense%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> political parties <http://electionlawblog.org/?cat=25>, political
> polarization <http://electionlawblog.org/?cat=68>
>
>
> “In Chevron Case, FEC Brings Clarity to the Federal Contractor Ban
> and Super PACs” <http://electionlawblog.org/?p=60385>
>
> Posted on April 11, 2014 8:53 am
> <http://electionlawblog.org/?p=60385>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Covington
> <http://www.insidepoliticallaw.com/2014/04/11/in-chevron-case-fec-brings-clarity-to-the-federal-contractor-ban-and-super-pacs/>‘s
> Inside Political Law:
>
> The rules on corporate contributions to Super PACs were made
> clearer today when the Federal Election Commission (FEC) released
> its finding <http://eqs.fec.gov/eqsdocsMUR/14044353483.pdf> that
> Chevron Corporation’s $2.5 million contribution in 2012 to the
> Congressional Leadership Fund (a Super PAC) had not violated the
> bar on government contractors making contributions in federal
> elections.
>
> Public Citizen and several environmental groups had alleged that
> Chevron Corporation and Chevron U.S.A. Inc. had numerous federal
> contracts, and consequently could not contribute to a Super PAC.
> On a bipartisan 5-1 vote
> <http://eqs.fec.gov/eqsdocsMUR/14044353409.pdf>, the FEC dismissed
> the charges, finding that Chevron Corporation―which made the
> contribution―was not a federal contractor at the time, and that
> federal contractor status could not be imputed to the company
> merely because it had a wholly-owned subsidiary that owned a
> subsidiary that in turn owned a subsidiary that owned a federal
> contractor. In so doing, the FEC followed the agency’s
> longstanding practice of permitting a parent company with a
> federal contractor subsidiary to make a contribution as long as it
> has sufficient funds from sources other than the contractor
> subsidiary. Nor is the federal contractor ban particularly
> stringent, permitting officers, shareholders, a corporate PAC, and
> subcontractors to contribute, even when the contractor cannot.
>
> Having resolved the case by applying the facts to existing law,
> the FEC did not address an even more fundamental issue raised by
> Chevron <http://eqs.fec.gov/eqsdocsMUR/14044353375.pdf>: Applying
> the federal contractor ban to contributions to a Super PAC is
> inconsistent with the Supreme Court’s limiting of campaign finance
> restrictions to the prevention of /quid pro quo/ corruption or its
> appearance. Last Wednesday’s decision in /McCutcheon v. FEC
> /highlights the doctrinal fragility of the federal contractor ban
> in cases like this.
>
> Full disclosure: Covington represented Chevron before the FEC in
> this matter.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60385&title=%E2%80%9CIn%20Chevron%20Case%2C%20FEC%20Brings%20Clarity%20to%20the%20Federal%20Contractor%20Ban%20and%20Super%20PACs%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> federal election commission <http://electionlawblog.org/?cat=24>
>
>
> “Did the US Supreme Court’s ruling in McCutcheon v. FEC Put the
> Constitutionality of Some Pay-to-Play Laws in Doubt?”
> <http://electionlawblog.org/?p=60383>
>
> Posted on April 11, 2014 7:51 am
> <http://electionlawblog.org/?p=60383>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Stefan Passantino blogs.
> <http://www.paytoplaylawblog.com/2014/04/articles/in-the-news/did-the-us-supreme-courts-ruling-in-mccutcheon-v-fec-put-the-constitutionality-of-some-pay-to-play-laws-in-doubt/>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60383&title=%E2%80%9CDid%20the%20US%20Supreme%20Court%E2%80%99s%20ruling%20in%20McCutcheon%20v.%20FEC%20Put%20the%20Constitutionality%20of%20Some%20Pay-to-Play%20Laws%20in%20Doubt%3F%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> Supreme Court <http://electionlawblog.org/?cat=29>
>
>
> “Bopp doesn’t always score at Supreme Court”
> <http://electionlawblog.org/?p=60381>
>
> Posted on April 11, 2014 7:50 am
> <http://electionlawblog.org/?p=60381>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> IndyStar reports.
> <http://www.indystar.com/story/behind-closed-doors/2014/04/10/bopp-doesnt-always-score-at-supreme-court/7555045/>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60381&title=%E2%80%9CBopp%20doesn%E2%80%99t%20always%20score%20at%20Supreme%20Court%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> Supreme Court <http://electionlawblog.org/?cat=29>
>
>
> “Has the Roberts court placed landmark 1964 civil rights law on a
> hit list?” <http://electionlawblog.org/?p=60379>
>
> Posted on April 11, 2014 7:47 am
> <http://electionlawblog.org/?p=60379>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Extensive CNN report.
> <http://www.cnn.com/2014/04/10/us/roberts-court-civil-rights-law/>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60379&title=%E2%80%9CHas%20the%20Roberts%20court%20placed%20landmark%201964%20civil%20rights%20law%20on%20a%20hit%20list%3F%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> Supreme Court <http://electionlawblog.org/?cat=29>, Voting Rights Act
> <http://electionlawblog.org/?cat=15>
>
>
> “People don’t care about campaign finance. Someone tell the
> president and his party.” <http://electionlawblog.org/?p=60377>
>
> Posted on April 11, 2014 7:35 am
> <http://electionlawblog.org/?p=60377>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> The Fix reports.
> <http://www.washingtonpost.com/blogs/the-fix/wp/2014/04/10/people-dont-care-about-campaign-finance-someone-tell-the-president-and-his-party/>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60377&title=%E2%80%9CPeople%20don%E2%80%99t%20care%20about%20campaign%20finance.%20Someone%20tell%20the%20president%20and%20his%20party.%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> Supreme Court <http://electionlawblog.org/?cat=29>
>
>
> Ex-Felon Voting Rights Bill <http://electionlawblog.org/?p=60375>
>
> Posted on April 10, 2014 9:36 pm
> <http://electionlawblog.org/?p=60375>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Press release
> <http://www.cardin.senate.gov/newsroom/press/release/cardin-leads-reintroduction-of-bill-to-create-nationwide-standard-for-restoring-voting-rights-for-americans-released-from-prison>:
>
> *U.S. Senator Ben Cardin (D-MD) *has introduced a bill, S. 2235,
> the */Democracy Restoration Act
> <http://cardin.senate.gov/download/democracy-restoration-act-of-2014>
> /*that would reduce recidivism rates by restoring voting rights to
> individuals after they have served their time and have been
> released from incarceration. Studies indicate that former
> prisoners who have voting rights restored are less likely to
> reoffend, and that disenfranchisement hinders their rehabilitation
> and reintegration into their community. *Original cosponsors of S.
> 2235 include Senate Judiciary Committee Chairman Patrick Leahy
> (D-Vt.), and Senators Richard Durbin (D-Ill.), Sheldon Whitehouse
> (D-RI), Cory Booker (D-NJ), Tom Harkin (D-Iowa), and Bernie
> Sanders (I-Vt.). *Companion legislation also was introduced today
> in the House of Representatives by Congressman John Conyers
> (D-Mich.), Ranking Member of the House Judiciary Committee.
>
> Meanwhile, William & Mary Law School launches ‘Revive My Vote’
> project.
> <http://www.vagazette.com/news/va-vg-wm-revive-my-vote-20140409,0,4938146.story>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60375&title=Ex-Felon%20Voting%20Rights%20Bill&description=>
>
> Posted infelon voting <http://electionlawblog.org/?cat=66>
>
>
> “Democrats embrace adding photos to Social Security cards”
> <http://electionlawblog.org/?p=60373>
>
> Posted on April 10, 2014 9:23 pm
> <http://electionlawblog.org/?p=60373>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Must-read WaPo o
> <http://www.washingtonpost.com/politics/democrats-embrace-adding-photos-to-social-security-cards/2014/04/10/cfffe55a-c0cc-11e3-b574-f8748871856a_story.html?wprss=rss_AllWPStoriesandBlogs&Post+generic=%3Ftid%3Dsm_twitter_washingtonpost>n
> movement toward an national voter id on the Democratic side.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60373&title=%E2%80%9CDemocrats%20embrace%20adding%20photos%20to%20Social%20Security%20cards%E2%80%9D&description=>
>
> Posted inelection administration <http://electionlawblog.org/?cat=18>,
> The Voting Wars <http://electionlawblog.org/?cat=60>
>
>
> The EPI and Election Reform: The Early Returns Are Promising
> <http://electionlawblog.org/?p=60357>
>
> Posted on April 10, 2014 4:26 pm
> <http://electionlawblog.org/?p=60357>by Heather Gerken
> <http://electionlawblog.org/?author=6>
>
> I want to offer a brief response to Rick Hasen’s post
> <http://electionlawblog.org/?p=60264http://> about the release of
> Pew’s 2012 Election Performance Index
> <http://www.pewstates.org/research/reports/the-elections-performance-index-2012-85899445029>.
> Now that we can assess state performance across two comparable
> elections, he asks an excellent question: Will we see states trying to
> improve their performance? I suggested as much in my book, The
> Democracy Index: Why Our System is Failing and How to Fix It
> <http://www.amazon.com/The-Democracy-Index-Election-Failing/dp/0691136947>,
> where I proposed creating a ranking like the EPI.
>
> It’s only been a few days, of course, but the early returns are
> heartening. States are obviously paying attention; there are lots of
> stories about states touting their rise in the rankings or grumbling
> about their scores, with more discussions happening behind the scenes.
>
> More importantly, election officials are already using the EPI to push
> for reform. Secretary of State Jon Husted, for instance, noted
> <http://www.cincinnati.com/story/news/politics/elections/2014/04/08/tristate-election-performance-lacking/7451239/>
> that one of the reasons that Ohio didn’t rank higher on the EPI was
> its failure to keep up with other states in creating an online
> registration system and urged his legislature to take up the bill.
> Iowa is paying special attention
> <http://wcfcourier.com/news/local/govt-and-politics/iowa-ranks-th-in-national-voting-index/article_e6cca35f-4460-58b6-95cc-386eeff20fe8.html>
> to military and overseas balloting, which pushed its rankings down.
> Florida was working with Pew in advance of the EPI’s release and
> promises
> <http://miamiherald.typepad.com/nakedpolitics/2014/04/report-faults-fla-vote-but-state-says-issues-fixed-.html>
> that it has /already/ enacted transparency and access reforms that
> will improve its rankings next time. Indiana’s Secretary of State
> tells us that, as we speak, the state is working on a post-election
> auditing process in order to up its ranking. The state also issued “a
> call to action”
> <http://www.in.gov/activecalendar/EventList.aspx?fromdate=4/8/2014&todate=4/21/2014&display=&type=public&eventidn=166527&view=EventDetails&information_id=199177&print=print>
> suggesting further improvements. Georgia insists
> <http://www.usatoday.com/story/news/politics/2014/04/08/state-election-performance/7433501/>
> that it’s going to do a better job on data collection in the future in
> order to increase its score.
>
> We see the same thing happening at the top of the rankings, also as I
> predicted. For example, the Secretary of State of Montana -- which now
> ranks near the top -- is not resting on her laurels. She called
> <http://m.billingsgazette.com/news/state-and-regional/montana/study-montana-s-election-performance-ranks-th-best/article_03029f62-e6bb-5546-bd8b-b8e6c0d03f58.html?mobile_touch=true>for
> additional reform so that Montana could maintain its position. So,
> too, the Secretary of State of top-ranked Michigan, which fell just
> shy of the top five, has called
> <http://www.eastvillagemagazine.org/en/news-releases3/21091-michigan-elections-ranks-sixth-highest-in-nation>
> for online voter registration and changes to absentee voting in order
> to move the state higher up the list. Twelfth-ranked Washington is on
> the hunt
> <http://www.thenewstribune.com/2014/04/08/3137973/report-washington-ranks-no-12.html?sp=/99/289/&ihp=1>
> for ways to improve its already strong ranking. And in North Dakota,
> which ranked first in the nation, policymakers who oppose voting rules
> recently enacted in North Dakota are using the EPI as a cudgel to beat
> the other side, arguing
> <http://bismarcktribune.com/news/local/govt-and-politics/north-dakota-first-in-election-performance/article_7264dc64-bf66-11e3-8460-001a4bcf887a.html>
> that those changes put the state at risk of losing its treasured
> number one spot.
>
> I don’t want to overclaim. It’s going to be hard to prove exactly how
> much of a push the EPI gives reform going forward, as Rick noted in
> his generous review
> <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1392299> of my
> book a few years ago. Nonetheless, if anything the pressure on states
> to improve seems likely to increase over time. The EPI has only been
> on the scene for two years, and this is the first time we’ve been able
> to make an “apples to apples” comparison (comparing a presidential
> election to a presidential election). If the EPI continues to develop
> into the touchstone for measuring election performance, it should
> matter more in these debates. Moreover, the pressure will mount for
> low-performing states. States improved an average of 4.4 percentage
> points between 2008 and 2012. As the always observant Doug Chapin
> noted
> <http://blog.lib.umn.edu/cspg/electionacademy/2014/04/pews_2012_index_election_perfo.php>,
> “even states showing modest improvement run the risk of being left
> behind.” A spokesperson for Washington State has plainly gotten the
> message
> <http://www.thenewstribune.com/2014/04/08/3137973/report-washington-ranks-no-12.html?sp=/99/289/&ihp=1>:
> “[M]uch of what we’ve done is outstanding” but “others are catching up
> . . . We’re still a high performing state [but] other states are
> making rapid improvements. Essentially, all boats are rising . . .”
>
> Even if the EPI doesn’t prod a single state to do a single thing, it
> will still matter a great deal to election reform. That’s because it
> provides an essential tool for data-driven policymaking: a baseline.
> Just as we cannot get a good read on economic policy without measures
> like the GDP, so, too, we cannot get a good read on elections policy
> without a reliable measure of how well our election system is working
> across time. Already, for instance, we’ve begun to learn things we
> didn’t know before. States with high obesity rates, for instance, seem
> to have trouble getting their voters to the polls. So, too, we’re
> shaking loose some of our assumptions about which systems are working
> and which aren’t. For instance, a number of states with long lines in
> 2012 ranked pretty high on the EPI, suggesting that the long lines
> were not a sign of a failing system. Ohio and Florida, the perennial
> objects of late-night comedy during elections season, were somewhere
> in the middle of the pack. Moreover, we see rich states and poor
> states performing well and badly on the list, something that at least
> raises questions about the real drivers of election performance.
>
> All of the credit for this goes to Pew, which developed a rigorous and
> assiduously nonpartisan process for building the EPI. Pew’s careful
> procedure and remarkable end product put the lie to the naysayer’s
> claim that any index would be dismissed out of hand as partisan. As to
> the rest, we’ll see.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60357&title=The%20EPI%20and%20Election%20Reform%3A%20%20The%20Early%20Returns%20Are%20Promising&description=>
>
> Posted inelection administration <http://electionlawblog.org/?cat=18>,
> Uncategorized <http://electionlawblog.org/?cat=1> | TaggedDemocracy
> Indix <http://electionlawblog.org/?tag=democracy-indix>, EPI
> <http://electionlawblog.org/?tag=epi>, Pew
> <http://electionlawblog.org/?tag=pew>, rankings
> <http://electionlawblog.org/?tag=rankings>
>
>
> Republican FEC Commissioners Write NYT Letter to Editor Responding
> to Commr. Ravel’s NYT Oped <http://electionlawblog.org/?p=60366>
>
> Posted on April 10, 2014 4:22 pm
> <http://electionlawblog.org/?p=60366>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> It pulls
> <http://www.nytimes.com/2014/04/10/opinion/chiding-an-fec-colleague.html?_r=1>no
> punches, beginning: “Our Federal Election Commission colleague Ann M.
> Ravel would rather grandstand than follow the law and judicial precedent.”
>
> Flashback <http://electionlawblog.org/?p=57184> to Dec 4: “Ravel said
> she found the level of partisan division at the FEC ‘very surprising’
> after arriving in late October from her previous post as head of
> California’s campaign finance and ethics agency, the Fair Political
> Practices Commission (FPPC).”
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60366&title=Republican%20FEC%20Commissioners%20Write%20NYT%20Letter%20to%20Editor%20Responding%20to%20Commr.%20Ravel%E2%80%99s%20NYT%20Oped&description=>
>
> Posted infederal election commission <http://electionlawblog.org/?cat=24>
>
>
> “Rowland Charged In Campaign Finance Conspiracy”
> <http://electionlawblog.org/?p=60362>
>
> Posted on April 10, 2014 4:13 pm
> <http://electionlawblog.org/?p=60362>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Connecticut.
> <http://www.courant.com/news/connecticut/hc-rowland-charged-0412-20140410,0,3188195.story>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60362&title=%E2%80%9CRowland%20Charged%20In%20Campaign%20Finance%20Conspiracy%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> chicanery <http://electionlawblog.org/?cat=12>
>
>
> Truth-o-Meter v. Dick Morris on Voter Fraud
> <http://electionlawblog.org/?p=60355>
>
> Posted on April 10, 2014 3:26 pm
> <http://electionlawblog.org/?p=60355>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Who wins?
> <http://www.politifact.com/punditfact/statements/2014/apr/10/dick-morris/dick-morris-theres-proof-over-1-million-people-vot/>
> The suspense must be killing you.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60355&title=Truth-o-Meter%20v.%20Dick%20Morris%20on%20Voter%20Fraud&description=>
>
> Posted infraudulent fraud squad <http://electionlawblog.org/?cat=8>,
> The Voting Wars <http://electionlawblog.org/?cat=60>
>
>
> “House Committee Holds IRS Official in Contempt”
> <http://electionlawblog.org/?p=60353>
>
> Posted on April 10, 2014 3:25 pm
> <http://electionlawblog.org/?p=60353>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> /Legal Times /
> <http://www.nationallawjournal.com/legaltimes/id=1202650582953?kw=House%20Committee%20Holds%20IRS%20Official%20in%20Contempt&et=editorial&bu=National%20Law%20Journal&cn=20140410&src=EMC-Email&pt=Legal%20Times%20Afternoon%20Update&slreturn=20140310174538>reports.
> <http://www.nationallawjournal.com/legaltimes/id=1202650582953?kw=House%20Committee%20Holds%20IRS%20Official%20in%20Contempt&et=editorial&bu=National%20Law%20Journal&cn=20140410&src=EMC-Email&pt=Legal%20Times%20Afternoon%20Update&slreturn=20140310174538>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60353&title=%E2%80%9CHouse%20Committee%20Holds%20IRS%20Official%20in%20Contempt%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>, tax
> law and election law <http://electionlawblog.org/?cat=22>
>
>
> “Wall Street, GOP Poised For Mutual Gain From Supreme Court’s
> McCutcheon Decision” <http://electionlawblog.org/?p=60351>
>
> Posted on April 10, 2014 2:36 pm
> <http://electionlawblog.org/?p=60351>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Paul Blumenthal writes
> <http://www.huffingtonpost.com/2014/04/10/mccutcheon-republican-party_n_5127498.html?1397163531>
> for HuffPo.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60351&title=%E2%80%9CWall%20Street%2C%20GOP%20Poised%20For%20Mutual%20Gain%20From%20Supreme%20Court%E2%80%99s%20McCutcheon%20Decision%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>
>
>
> NYT Editorial Ties Medicare Payments, CJ Roberts’ View of
> Corruption <http://electionlawblog.org/?p=60349>
>
> Posted on April 10, 2014 2:29 pm
> <http://electionlawblog.org/?p=60349>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Here.
> <http://www.nytimes.com/2014/04/11/opinion/abusing-both-medicare-and-politics.html?smid=tw-share>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60349&title=NYT%20Editorial%20Ties%20Medicare%20Payments%2C%20CJ%20Roberts%E2%80%99%20View%20of%20Corruption&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> Supreme Court <http://electionlawblog.org/?cat=29>
>
>
> Republican FEC Commissioners Issue Statement About Enforcement
> <http://electionlawblog.org/?p=60346>
>
> Posted on April 10, 2014 2:28 pm
> <http://electionlawblog.org/?p=60346>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Statement re Defending the Commission in Public Citizen v. FEC
> <http://electionlawblog.org/wp-content/uploads/Statement-re-Defending-the-Commission-in-Public-Citizen-v.-FEC-1.pdf>
> begins:
>
> For nearly forty years, votes to defend the Commission in cases
> challenging dismissals of administrative complaints have been
> routine, pro forma acts. Even when the Commission has split on
> whether to proceed in an enforcement matter, the decision to
> defend has been uncontroversial. In recent days, however, our
> colleague Commissioner Ann Ravel has announced her desire to upend
> this consensus. Not only does this effort derail longstanding
> Commission practice, but more troublingly, it contravenes
> well-established legal precedents and evinces a flippant disregard
> for judicial review.
>
> A copy of the email from Commissioner Hunter’s office with the press
> release has the following cover note:
>
> Good afternoon, hope you are well. Attached please find a
> statement from Lee Goodman, Matt Petersen and me regarding the
> FEC’s vote to authorize defense of suit in Public Citizen v. FEC.
>
> Please remember any response to this email is subject to a FOIA
> request. As we have learned, CREW views positive emails to
> Republican Commissioners as evidence of collusion.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60346&title=Republican%20FEC%20Commissioners%20Issue%20Statement%20About%20Enforcement&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> federal election commission <http://electionlawblog.org/?cat=24>
>
>
> “In India, show the finger after voting, get cheaper gas and food”
> <http://electionlawblog.org/?p=60344>
>
> Posted on April 10, 2014 2:20 pm
> <http://electionlawblog.org/?p=60344>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Love this
> <http://www.thenewage.co.za/122910-1020-53-In_India_show_the_finger_after_voting_get_cheaper_gas_and_food>:
>
> Showing the finger can get you a punch in the face in many parts
> of the world. In India, during this general election at least, it
> can earn discounts at gas stations, restaurants, spas, stores and
> hospitals after voting.
>
> India’s polling stations mark each voter’s left forefinger with an
> indelible dot of a silver nitrate solution after casting the
> ballot to guard against voter fraud.
>
> Could we do this in the US
> <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=257564>? Not in
> elections with federal candidates on the ballots and not in some
> states even in state and local elections.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60344&title=%E2%80%9CIn%20India%2C%20show%20the%20finger%20after%20voting%2C%20get%20cheaper%20gas%20and%20food%E2%80%9D&description=>
>
> Posted invote buying <http://electionlawblog.org/?cat=43>
>
>
> “How to start a Super PAC because you can”
> <http://electionlawblog.org/?p=60342>
>
> Posted on April 10, 2014 2:16 pm
> <http://electionlawblog.org/?p=60342>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> WaPo
> <http://www.washingtonpost.com/blogs/in-the-loop/wp/2014/04/10/how-to-start-a-super-pac-because-you-can/>on
> 17 year old PACmeister.
>
> The three boys aimed to make their application as “ridiculous as
> possible,” Grant said. He picked “Corporate Antelope” as his
> official title or position. His friends Brady Harper and Hudson
> Roberts are “Arch-Mage” and “Not Pope,” respectively. They left
> blank the section asking for the bank accounts where they would
> deposit funds, because, well, the teens don’t have bank accounts.
> They created a Web site using the free service “Weebly.” (It’s
> currently blank <http://becausewecanpac.weebly.com/> other than a
> background of the Manhattan skyline and the PAC’s name.)
>
> Within several days, Grant received the notice from the FEC that
> his application had been received. And just like that, “Because We
> Can” was given an official committee ID number.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60342&title=%E2%80%9CHow%20to%20start%20a%20Super%20PAC%20because%20you%20can%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>
>
>
> “Campaign Finance and the Social Contract”
> <http://electionlawblog.org/?p=60340>
>
> Posted on April 10, 2014 2:15 pm
> <http://electionlawblog.org/?p=60340>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Charles Fried
> <http://www.clcblog.org/index.php?option=com_content&view=article&id=556:campaign-finance-and-the-social-contract>
> guest blog post at CLC.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60340&title=%E2%80%9CCampaign%20Finance%20and%20the%20Social%20Contract%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>
>
>
> “How the Supreme Court Blowtorched Democracy and What You Can Do
> About It” <http://electionlawblog.org/?p=60338>
>
> Posted on April 10, 2014 2:08 pm
> <http://electionlawblog.org/?p=60338>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> /The Nation /
> <http://www.thenation.com/article/179264/how-supreme-court-blowtorched-democracy-and-what-you-can-do-about-it>editorial.
> <http://www.thenation.com/article/179264/how-supreme-court-blowtorched-democracy-and-what-you-can-do-about-it>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60338&title=%E2%80%9CHow%20the%20Supreme%20Court%20Blowtorched%20Democracy%20and%20What%20You%20Can%20Do%20About%20It%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> Supreme Court <http://electionlawblog.org/?cat=29>, Voting Rights Act
> <http://electionlawblog.org/?cat=15>
>
>
> ” Watchdog Groups Challenge House Ways and Means Committee Letter
> Claiming IRS Pursuit of Crossroads GPS was Improper; Statement of
> Democracy 21 President Fred Wertheimer and Campaign Legal Center
> Executive Director J. Gerald Hebert”
> <http://electionlawblog.org/?p=60336>
>
> Posted on April 10, 2014 2:07 pm
> <http://electionlawblog.org/?p=60336>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Here
> <http://www.democracy21.org/money-in-politics/letters-to-the-irs/watchdog-groups-challenge-house-ways-and-means-committee-letter-claiming-irs-pursuit-of-crossroads-gps-was-improper/>.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60336&title=%E2%80%9D%20Watchdog%20Groups%20Challenge%20House%20Ways%20and%20Means%20Committee%20Letter%20Claiming%20IRS%20Pursuit%20of%20Crossroads%20GPS%20was%20Improper%3B%20%20Statement%20of%20Democracy%20>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>, tax
> law and election law <http://electionlawblog.org/?cat=22>
>
>
> “Campaign Finance and the Nihilist Politics of Resignation”
> <http://electionlawblog.org/?p=60334>
>
> Posted on April 10, 2014 1:46 pm
> <http://electionlawblog.org/?p=60334>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Lessig:
> <http://www.theatlantic.com/politics/archive/2014/04/campaign-finance-and-the-nihilist-politics-of-resignation/360437/>
>
> his is the politics of resignation. We accept the status quo not
> because we want it, and certainly not because we don’t care about
> “process.” To the contrary: We are resigned precisely because we
> view the very process by which we would effect change as corrupt.
> We thus steer away from the politics of reform, and focus our
> (dwindling level of) political attention on other issues instead.
>
> This is reform’s greatest challenge. The ordinary way we do
> politics in America―Democrats yelling at Republicans, Republicans
> yelling at Democrats―won’t move this issue, because neither side
> will seem credible as reformers, at least as against the other.
> That is Cillizza’s sensible, and unfortunately true, point.
>
> But what if we could crack this cynicism, and melt the
> resignation? What if there were a way to give Americans hope―not
> that ordinary politicians could be different, but that a different
> kind of political power could matter? Not one from the inside, but
> one born on the outside. Not a power seeking political office, but
> a power seeking to change the way politics works. Americans might
> not rally to yet another politician promising change. That’s
> Cillizza’s insight. But could they be rallied to a cause that
> would change the way politicians promise?
>
> Such a movement is this generation’s moonshot. Yet the reformers I
> know―as decent and committed as anyone could imagine―think small.
> They call their thinking “realistic.”
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60334&title=%E2%80%9CCampaign%20Finance%20and%20the%20Nihilist%20Politics%20of%20Resignation%E2%80%9D&description=>
>
> Posted incampaign finance <http://electionlawblog.org/?cat=10>,
> Supreme Court <http://electionlawblog.org/?cat=29>
>
>
> “Feds appeal ruling in voter citizenship case”
> <http://electionlawblog.org/?p=60332>
>
> Posted on April 10, 2014 1:43 pm
> <http://electionlawblog.org/?p=60332>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> AP reports.
> <http://ksn.com/2014/04/09/feds-appeal-ruling-in-voter-citizenship-case/>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60332&title=%E2%80%9CFeds%20appeal%20ruling%20in%20voter%20citizenship%20case%E2%80%9D&description=>
>
> Posted inelection administration <http://electionlawblog.org/?cat=18>,
> Election Assistance Commission <http://electionlawblog.org/?cat=34>,
> Elections Clause <http://electionlawblog.org/?cat=70>, NVRA (motor
> voter) <http://electionlawblog.org/?cat=33>, The Voting Wars
> <http://electionlawblog.org/?cat=60>
>
>
> Breaking: Republicans Offering Potential Nominees for EAC
> <http://electionlawblog.org/?p=60329>
>
> Posted on April 10, 2014 10:03 am
> <http://electionlawblog.org/?p=60329>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Bloomberg BNA has a breaking news report saying that the names were
> put in by Senate Leader McConnell. It quotes a spokesperson for Sen.
> Roberts, ranking Republican on Rules, that “The ball is with the White
> House.”
>
> Lots of questions here.
>
> 1. Are these viable Republican nominees? If not, what will the
> President do?
>
> 2. Why would Republicans do this? Perhaps the calculation is that it
> is better to have two Republicans to deadlock with the two new
> Democratic nominees on the commission than to have the two Democrats
> speak for the Commission―even though two commissioners does not a
> quorum make. [corrected]
>
> 3. Is there any chance there could be common ground at a new EAC? Or
> will Republicans come in Don McGahn style, acting as flame throwers at
> an agency they despise?
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60329&title=Breaking%3A%20Republicans%20Offering%20Potential%20Nominees%20for%20EAC&description=>
>
> Posted inelection administration <http://electionlawblog.org/?cat=18>,
> Election Assistance Commission <http://electionlawblog.org/?cat=34>,
> The Voting Wars <http://electionlawblog.org/?cat=60>
>
>
> “The Doctrine of One Last Chance”
> <http://electionlawblog.org/?p=60327>
>
> Posted on April 10, 2014 8:22 am
> <http://electionlawblog.org/?p=60327>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Richard Re has posted this must-read short essay
> <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2421362>on SSRN
> (/Green Bag/).
>
> Here is the abstract:
>
> Constitutional avoidance is an old idea, but the Roberts Court has
> given it a new twist. Instead of avoiding constitutional questions
> whenever possible, recent Supreme Court majorities have tended to
> engage in avoidance just once before issuing disruptive decisions.
> For example, the Roberts Court initially ducked constitutional
> challenges to central pillars of the Bipartisan Campaign Reform
> Act and the Voting Rights Act. But when those measures came before
> the Court for a second time, they were both struck down as
> unconstitutional, despite their importance and bipartisan support.
> A similar pattern of limited deferral may be visible in other
> recent cases, as the Roberts Court has taken a pass on its first
> opportunities to strike at the Affordable Care Act, affirmative
> action in higher education, and same-sex marriage laws.
>
> This emerging use of constitutional avoidance might be called “the
> doctrine of one last chance.” Under this doctrine, the Court must
> signal its readiness to impose major disruptions before actually
> doing so. Put more colorfully, the doctrine of one last chance is
> avoidance on steroids, but with an expiration date. The result is
> a practical rule of judicial decision-making ― an attempt not just
> to extol the dueling virtues of judicial action and restraint, but
> to balance them. And the balance is attractive. Here as elsewhere,
> there is good reason to afford notice and postpone decision before
> causing massive and potentially unexpected disruptions. Still, the
> doctrine should give us pause: by facilitating major legal change,
> the doctrine of one last chance converts a cornerstone principle
> of judicial restraint into a playbook for judicial action.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60327&title=%E2%80%9CThe%20Doctrine%20of%20One%20Last%20Chance%E2%80%9D&description=>
>
> Posted inSupreme Court <http://electionlawblog.org/?cat=29>
>
>
> “Why voting rights is the Democrats’ most important project in
> 2014″ <http://electionlawblog.org/?p=60325>
>
> Posted on April 10, 2014 7:33 am
> <http://electionlawblog.org/?p=60325>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> The Fix reports.
> <http://www.washingtonpost.com/blogs/the-fix/wp/2014/04/10/why-voting-rights-is-the-democrats-most-important-project-in-2014/>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60325&title=%E2%80%9CWhy%20voting%20rights%20is%20the%20Democrats%E2%80%99%20most%20important%20project%20in%202014%E2%80%B3&description=>
>
> Posted inelection administration <http://electionlawblog.org/?cat=18>,
> The Voting Wars <http://electionlawblog.org/?cat=60>
>
>
> What Does Movement on the EAC Nominees Mean?
> <http://electionlawblog.org/?p=60323>
>
> Posted on April 10, 2014 7:31 am
> <http://electionlawblog.org/?p=60323>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Doug Chapin games it out.
> <http://blog.lib.umn.edu/cspg/electionacademy/2014/04/light_at_the_end_of_the_tunnel.php>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D60323&title=What%20Does%20Movement%20on%20the%20EAC%20Nominees%20Mean%3F&description=>
>
> Posted inelection administration <http://electionlawblog.org/?cat=18>,
> Election Assistance Commission <http://electionlawblog.org/?cat=34>,
> The Voting Wars <http://electionlawblog.org/?cat=60>
>
> --
> 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://www.law.uci.edu/faculty/full-time/hasen/
> http://electionlawblog.org
> ------------------------------------------------------------------------
>
>
> Spam
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--
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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