[EL] WI voter ID ruling
Justin Levitt
levittj at lls.edu
Wed Jul 30 23:58:30 PDT 2014
Rick's absolutely right that if the state Supreme Court strikes down
Wisconsin's photo ID law, it could have national implications in that it
would likely moot an appeal on the federal section 2 case. But in that
respect, this is an asymmetrical case: the reverse isn't true. (To be
clear, Rick never claimed it was.) If the Wisconsin Supreme Court
_upholds_ the state's law, it would have very little meaning for the
federal claim, or for claims in other states.
None of the Wisconsin cases -- and indeed, none of the cases brought
against the more restrictive ID laws in any state -- have been yes/no
referenda on whether a generic photo ID law is generically OK. Each
case is premised on a particular claim ... and some claims are stronger
than others
<http://blog.constitutioncenter.org/2013/10/voter-id-update-the-diversity-in-the-details/>.
As an analogy, the failure to convict a particular person of a
particular crime on particular evidence doesn't amount to a verdict on
any other crime, or on the individual's character more generally. It's
just a verdict on whether the prosecutor has sufficiently proved that
particular crime with that evidence.
In Wisconsin, the state cases are very different cases than the federal
cases. Some of the claims kind of feel like analogous federal
constitutional claims, ish, but with different evidence before the
court. Some of the claims are different claims entirely -- including
the claim that the Wisconsin legislature has no authority to test a
voter's identity at all (this was alleged, but was not the basis for
relief in the lower state courts).
A state-court decision agreeing with the plaintiffs' challenges and
striking down the law would not bear on the merits of the federal case
-- the only federal impact would be, as Rick notes, in potentially
mooting the federal case entirely. Similarly, a state-court decision
disagreeing with these challenges and upholding the law would not bear
on the merits of the federal case either -- and so won't really affect
the federal case one way or another.
Justin
--
Justin Levitt
Professor of Law
Loyola Law School | Los Angeles
919 Albany St.
Los Angeles, CA 90015
213-736-7417
justin.levitt at lls.edu
ssrn.com/author=698321
On 7/30/2014 8:45 PM, Rick Hasen wrote:
>
>
> Wisconsin Supreme Court Set to Issue Voter ID Ruling, Other Major
> Rulings, Thursday Morning--Could Moot Federal Case
> <http://electionlawblog.org/?p=63841>
>
> Posted on July 30, 2014 8:36 pm
> <http://electionlawblog.org/?p=63841>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Milwaukee Journal Sentinel
> <http://www.jsonline.com/news/statepolitics/act-10-voter-id-same-sex-partner-issues-converge-thursday-b99320335z1-269071231.html>:
>
> Three bolts of legal lightning --- affecting union bargaining,
> election law and same-sex couples --- will finally come down
> Thursday morning in what promises to be a historic day for the
> Wisconsin Supreme Court.
>
> Set for release are long-awaited opinions on whether Gov. Scott
> Walker's labor law is constitutional, whether voters can be made
> to show photo IDs and whether the state can run a registry for
> same-sex partners. On the question of photo ID at the polls, the
> court is ruling on two consolidated lawsuits challenging the same
> law, meaning essentially four significant legal cases in all being
> decided Thursday.
>
> The article says the voter id ruling won't be so significant because a
> federal court has already held the law unconstitutional and a
> violation of Section 2 of the Voting Rights Act. But that federal
> court ruling, Frank v. Walker, is a quite significant ruling on the
> meaning of the Voting Rights Act in vote denial cases. A state ruling
> striking down the id on state law grounds could moot the appeal in
> Frank v. Walker, meaning we will not get our first federal appellate
> ruling (this from the 7th Circuit) on the vote denial Section 2
> issue. and potentially even lead to an attempt to vacate the federal
> court opinion. So tomorrow's ruling, if it does strike down the law,
> could have some national implications.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63841&title=Wisconsin%20Supreme%20Court%20Set%20to%20Issue%20Voter%20ID%20Ruling%2C%20Other%20Major%20Rulings%2C%20Thursday%20Morning%E2%80%93Could%20Moot%20Federal%20Case&description=>
> 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 Rights Act
> <http://electionlawblog.org/?cat=15>
>
>
> Yahoo News Lists Major Donors to "No Labels"
> <http://electionlawblog.org/?p=63838>
>
> Posted on July 30, 2014 4:46 pm
> <http://electionlawblog.org/?p=63838>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Much more interesting stuff in this Meredith Shiner report.
> <http://news.yahoo.com/no-labels--no-results--no-problem-212252637.html>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63838&title=Yahoo%20News%20Lists%20Major%20Donors%20to%20%E2%80%9CNo%20Labels%E2%80%9D&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>
>
>
> Daily Kos Diarist Criticizes MayDay PAC for Supporting What
> Diarist Terms Tea Party Candidate
> <http://electionlawblog.org/?p=63836>
>
> Posted on July 30, 2014 3:40 pm
> <http://electionlawblog.org/?p=63836>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Here
> <http://www.dailykos.com/story/2014/07/29/1317493/-Mayday-PAC-s-first-two-candidate-choices-Does-the-left-hand-know-what-the-right-hand-s-doing>.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63836&title=Daily%20Kos%20Diarist%20Criticizes%20MayDay%20PAC%20for%20Supporting%20What%20Diarist%20Terms%20Tea%20Party%20Candidate&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>,
> campaigns <http://electionlawblog.org/?cat=59>
>
>
> Three Democratic FEC Commisioners Release Statement on "Dark
> Money" in Relation to Commission Deadlock on Americans for Job
> Security, AAN <http://electionlawblog.org/?p=63833>
>
> Posted on July 30, 2014 2:56 pm
> <http://electionlawblog.org/?p=63833>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> You can read it here <http://go.usa.gov/NcGB>.
>
> UPDATE: Here <http://t.co/9xV3L2U6eJ> is the statement from the
> Republican commissioners.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63833&title=Three%20Democratic%20FEC%20Commisioners%20Release%20Statement%20on%20%E2%80%9CDark%20Money%E2%80%9D%20in%20Relation%20to%20Commission%20Deadlock%20on%20Americans%20for%20Job%20Security%2C%20AAN&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>,
> federal election commission <http://electionlawblog.org/?cat=24>
>
>
> "How the Republican Governors Association chose sides in
> Colorado's primary" <http://electionlawblog.org/?p=63831>
>
> Posted on July 30, 2014 1:32 pm
> <http://electionlawblog.org/?p=63831>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Reid Wilson
> <http://www.washingtonpost.com/blogs/govbeat/wp/2014/07/30/how-the-republican-governors-association-chose-sides-in-colorados-primary/>:
> "Though it ostensibly stays neutral in primary elections, the
> Republican Governors Association appears to have played favorites in
> at least one contest this year, apparently financing outside spending
> against a well-known fellow Republican."
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63831&title=%E2%80%9CHow%20the%20Republican%20Governors%20Association%20chose%20sides%20in%20Colorado%E2%80%99s%20primary%E2%80%9D&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>,
> campaigns <http://electionlawblog.org/?cat=59>
>
>
> "Leaked Docs: How a Secret FreedomWorks Donor Sought a Return on
> Its 'Investments'" <http://electionlawblog.org/?p=63829>
>
> Posted on July 30, 2014 12:50 pm
> <http://electionlawblog.org/?p=63829>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Andy Kroll reports
> <http://www.motherjones.com/politics/2014/07/freedomworks-switzerland-richard-stephenson-matt-kibbe>
> for Mother Jones.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63829&title=%E2%80%9CLeaked%20Docs%3A%20How%20a%20Secret%20FreedomWorks%20Donor%20Sought%20a%20Return%20on%20Its%20%E2%80%98Investments%E2%80%99%E2%80%9D&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>
>
>
> DOJ Files Amicus Brief in Wisconsin Voter ID Case, Statement of
> Interest in Ohio Early Voting Case
> <http://electionlawblog.org/?p=63827>
>
> Posted on July 30, 2014 12:34 pm
> <http://electionlawblog.org/?p=63827>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> DOJ Wisconsin Filing
> <http://www.scribd.com/doc/235474087/DOJ-Wisconsin-Filing>
>
> DOJ Ohio Filing <http://www.scribd.com/doc/235474083/DOJ-Ohio-Filing>
>
> Ryan Reilly
> <http://www.huffingtonpost.com/2014/07/30/obama-voting-rights-ohio-wisconsin_n_5634804.html?utm_hp_ref=tw>
> HuffPo story.
>
> DOJ Press release:
>
> *ATTORNEY GENERAL HOLDER ANNOUNCES JUSTICE DEPARTMENT FILINGS IN
> VOTING RIGHTS CASES IN WISCONSIN AND OHIO*
>
> WASHINGTON -- Attorney General Eric Holder announced today that
> the Justice Department has submitted filings in voting rights
> cases in Wisconsin and Ohio. The department's involvement in
> these two cases represents its latest steps to enforce the
> remaining parts of the Voting Rights Act against restrictive state
> laws, following up on the department's lawsuits last year against
> similar measures in Texas and North Carolina.
>
> In the Wisconsin case, the department filed an amicus brief in
> /Frank v. Walker/ and /LULAC v. Deininger/, supporting an earlier
> ruling by the U.S. District Court for the Eastern District of
> Wisconsin that struck down Wisconsin's strict photo voter
> identification requirement due to its effects on minority voters
> under Section 2 of the Voting Rights Act, and because it unduly
> burdens a substantial number of voters in violation of the
> Fourteenth Amendment. In the Ohio case, the department filed a
> statement of interest in /NAACP v. Husted/, a challenge by a civil
> rights group to a state law curtailing early voting and same day
> registration. The department's brief contests the state of Ohio's
> incorrect interpretation of the standards set forth by Section 2
> of the Voting Rights Act.
>
> "These filings are necessary to confront the pernicious measures
> in Wisconsin and Ohio that would impose significant barriers to
> the most basic right of our democracy," said Attorney General Eric
> Holder. "These two states' voting laws represent the latest,
> misguided attempts to fix a system that isn't broken. These
> restrictive state laws threaten access to the ballot box. The
> Justice Department will never shrink from our responsibility to
> protect the voting rights of every eligible American. And we will
> keep using every available tool at our disposal to guard against
> all forms of discrimination, to prevent voter disenfranchisement,
> and to secure the rights of every citizen."
>
> In the amicus brief filed today in the U.S. Court of Appeals for
> the Seventh Circuit, the department argues that the district court
> reached the correct decision by finding that Wisconsin's voter ID
> law, known as Act 23, violated the Fourteenth Amendment, because
> it imposes unjustified burdens on a significant number of voters,
> and violated Section 2 of the Voting Rights Act, because it has a
> discriminatory result on African-American and Hispanic voters. In
> addition to finding that Act 23 would result in minority voters
> having less opportunity to participate in the political process
> relative to other members of the electorate, the court found that
> the state's claimed interests in combating voter fraud and
> promoting electoral confidence did not justify the significant
> burdens Act 23 imposes on substantial numbers of voters who lack a
> qualifying ID.
>
> In the statement of interest filed today in U.S. District Court
> for the Southern District of Ohio, the department makes clear that
> Section 2 prohibits the state of Ohio from imposing any voting
> qualification, prerequisite to voting, or any standard, practice
> or procedure that would result in the denial or abridgement of the
> right to vote on account of a person's race, color or membership
> in a language minority group. The filing also makes clear that in
> its own filings in the case the state of Ohio has incorrectly
> interpreted its requirements under Section 2. The department did
> not take a position on any of the other claims in the case.
>
> "The United States Department of Justice today affirms its clear
> position that, under Wisconsin's Act 23, minority voters have less
> opportunity to participate in the political process," said James
> L. Santelle, United States Attorney for the Eastern District of
> Wisconsin. "The amicus brief that we are filing not only supports
> the trial court's findings but also reflects the department's
> continuing focus on ensuring that the franchise remains fully
> available to all qualified voters."
>
> "Wisconsin's proud history is one of expanding the opportunity to
> vote," said John W. Vaudreuil, United States Attorney for the
> Western District of Wisconsin. "I'm honored to file this brief
> with the United States Department of Justice seeking to ensure
> that this great Wisconsin tradition is reaffirmed, and that every
> Wisconsin citizen has an equal opportunity to participate in
> democracy."
>
> "This office remains committed to preserving the rights of every
> Ohio voter," said Steven M. Dettelbach, United States Attorney for
> the Northern District of Ohio. "Making sure that courts continue
> to carefully examine voting restrictions, such as the ones
> recently imposed in this state, is an important part of that effort."
>
> In the year since the Supreme Court struck down the coverage
> formula that determined which jurisdictions were subject to
> preclearance under the Voting Rights Act in /Shelby v. Holder/,
> Section 2 of the Voting Rights Act remains one of the department's
> most powerful tools to protect voting rights. Last year the
> department used Section 2 to file two lawsuits against the state
> of Texas to stop the newly enacted discriminatory voter ID law and
> and to obtain a ruling that the state engaged in intentional
> discrimination in adopting its 2011 redistricting plans. In North
> Carolina, the department used Section 2 to sue to stop a number of
> provisions in an election law that imposes strict voter ID
> requirements, restricts early voting, eliminates same-day
> registration and refuses to count otherwise valid provisional
> ballots cast in the wrong precinct. The suit alleges that the
> challenged law was motivated by a racially discriminatory purpose
> and will result in African-American voters having less opportunity
> than other citizens to participate in the political process. All
> three cases are ongoing.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63827&title=DOJ%20Files%20Amicus%20Brief%20in%20Wisconsin%20Voter%20ID%20Case%2C%20Statement%20of%20Interest%20in%20Ohio%20Early%20Voting%20Case&description=>
> Posted in The Voting Wars <http://electionlawblog.org/?cat=60>, Voting
> Rights Act <http://electionlawblog.org/?cat=15>
>
>
> "Hood calls out 'political blogger' in pay-to-lie scheme"
> <http://electionlawblog.org/?p=63825>
>
> Posted on July 30, 2014 12:10 pm
> <http://electionlawblog.org/?p=63825>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Clarion Ledger
> <http://www.clarionledger.com/story/dailyledes/2014/07/30/jim-hood-political-blogger/13363041/>:
>
> Attorney General Jim Hood
> <http://www.clarionledger.com/search/Jim%20Hood/> said his office
> is investigating whether a "political blogger" paid a Meridian man
> to lie about a vote-buying scheme.
>
> During his speech at the Neshoba County Fair, Hood called for more
> civility and integrity in political races and pointed to the
> Republican primary for U.S. Senate as being out of control. He
> said a "political blogger" paid a self-described pastor to lie
> about being asked to pay people to vote and that things like that
> do nothing to help political discourse.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63825&title=%E2%80%9CHood%20calls%20out%20%E2%80%98political%20blogger%E2%80%99%20in%20pay-to-lie%20scheme%E2%80%9D&description=>
> Posted in chicanery <http://electionlawblog.org/?cat=12>, vote buying
> <http://electionlawblog.org/?cat=43>
>
>
> Irony Dept: Group Exposing Names of Signers of Anti-Gay Petition
> are Themselves Staying Anonymous Citing Fears of Harassment
> <http://electionlawblog.org/?p=63823>
>
> Posted on July 30, 2014 11:58 am
> <http://electionlawblog.org/?p=63823>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> You can't make this stuff up.
>
> Chris Geidner
> <http://www.buzzfeed.com/chrisgeidner/mystery-campaign-publishes-names-addresses-of-opponents-of-l>:
>
> In a twist, the people behind the website, HEROpetition.com, are
> themselves remaining anonymous. A person responding to an inquiry
> made to the email address provided on the website,
> HEROpetition.com, told BuzzFeed Tuesday night that they "aren't
> identifying people associated with the website to protect our
> personal safety."
>
> The domain name was registered on July 3 through Domains By Proxy,
> a service whose purpose is to mask the identity of a person
> purchasing a web domain. The person or people making the petitions
> available to all defended their anonymity.
>
> "The personal safety risks to the people who run this site are far
> greater than the risk to any one individual among tens of thousand
> who signed the petition," the person responding to inquires made
> at the website's email address wrote to BuzzFeed. "[S]ome people
> claim they will be the victims of harassment because of this site,
> but some of them have no problem coming after the folks on this
> side. People who have spoken out publicly in favor of HERO are
> already facing threats against their jobs."
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63823&title=Irony%20Dept%3A%20Group%20Exposing%20Names%20of%20Signers%20of%20Anti-Gay%20Petition%20are%20Themselves%20Staying%20Anonymous%20Citing%20Fears%20of%20Harassment&description=>
> Posted in direct democracy <http://electionlawblog.org/?cat=62>
>
>
> In Personal Email, Lois Lerner Called Conservatives "Assholes"
> <http://electionlawblog.org/?p=63821>
>
> Posted on July 30, 2014 10:26 am
> <http://electionlawblog.org/?p=63821>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> WSJ
> <http://online.wsj.com/articles/gop-says-lerner-email-shows-bias-against-conservatives-1406739923?mod=rss_US_News>:
>
> A newly discovered email
> <http://waysandmeans.house.gov/uploadedfiles/lerner_email_a.pdf>
> shows that former Internal Revenue Service official Lois Lerner
> once referred to conservatives as "---holes," according to new
> documents released by House Republicans.
>
> In the November 2012 email exchange, apparently with a friend or
> family member, Ms. Lerner also suggests that conservatives could
> threaten the nation's future, saying, "So we don't need to worry
> about alien teRrorists [sic]. It's our own crazies that will take
> us down."
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63821&title=In%20Personal%20Email%2C%20Lois%20Lerner%20Called%20Conservatives%20%E2%80%9CAssholes%E2%80%9D&description=>
> Posted in tax law and election law <http://electionlawblog.org/?cat=22>
>
>
> "Motor voter problems mean delays at polls"
> <http://electionlawblog.org/?p=63819>
>
> Posted on July 30, 2014 9:41 am
> <http://electionlawblog.org/?p=63819>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> USA Today reports
> <http://www.usatoday.com/story/news/politics/2014/07/29/motor-voter-states-dmv/12752595/>
> (via Doug Chapin
> <http://blog.lib.umn.edu/cspg/electionacademy/2014/07/usa_today_motor_voter_problems.php>).
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63819&title=%E2%80%9CMotor%20voter%20problems%20mean%20delays%20at%20polls%E2%80%9D&description=>
> Posted in election administration
> <http://electionlawblog.org/?cat=18>, NVRA (motor voter)
> <http://electionlawblog.org/?cat=33>
>
>
> "Dark Money Groups Dominate Independent Spending in House Toss-Up
> Races" <http://electionlawblog.org/?p=63817>
>
> Posted on July 30, 2014 9:22 am
> <http://electionlawblog.org/?p=63817>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Brennan Center report
> <http://www.brennancenter.org/analysis/election-spending-2014-13-toss-house-districts>.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63817&title=%E2%80%9CDark%20Money%20Groups%20Dominate%20Independent%20Spending%20in%20House%20Toss-Up%20Races%E2%80%9D&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>
>
>
> "K Street's elite mini-mega donors have blown beyond" Beyond
> Aggregate Limits Struck in McCutcheon
> <http://electionlawblog.org/?p=63815>
>
> Posted on July 30, 2014 7:43 am
> <http://electionlawblog.org/?p=63815>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Roll Call reports.
> <http://blogs.rollcall.com/beltway-insiders/k-street-files-mini-mega-donors-dominate-downtown-giving/?dcz=>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63815&title=%E2%80%9CK%20Street%E2%80%99s%20elite%20mini-mega%20donors%20have%20blown%20beyond%E2%80%9D%20Beyond%20Aggregate%20Limits%20Struck%20in%20McCutcheon&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>
>
>
> "High Court again asked to intervene in state judicial elections"
> <http://electionlawblog.org/?p=63812>
>
> Posted on July 30, 2014 7:33 am
> <http://electionlawblog.org/?p=63812>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> Ron Collins blogs
> <http://www.concurringopinions.com/archives/2014/07/fan-25-first-amendment-news-high-court-again-asked-to-intervene-in-state-judicial-elections.html#more-89342>.
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63812&title=%E2%80%9CHigh%20Court%20again%20asked%20to%20intervene%20in%20state%20judicial%20elections%E2%80%9D&description=>
> Posted in judicial elections <http://electionlawblog.org/?cat=19>
>
>
> "Koch-backed seniors group low-balling election spending?"
> <http://electionlawblog.org/?p=63810>
>
> Posted on July 30, 2014 7:32 am
> <http://electionlawblog.org/?p=63810>by Rick Hasen
> <http://electionlawblog.org/?author=3>
>
> CPI reports.
> <http://www.publicintegrity.org/2014/07/30/15163/koch-backed-seniors-group-low-balling-election-spending>
>
> Share
> <http://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D63810&title=%E2%80%9CKoch-backed%20seniors%20group%20low-balling%20election%20spending%3F%E2%80%9D&description=>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>
>
>
>
> --
> 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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