[EL] ELB News and Commentary 5/5/14
Rick Hasen
rhasen at law.uci.edu
Sun May 4 21:27:20 PDT 2014
"Congressman John Conyers Probably Will File a Lawsuit to get on
Democratic Primary Ballot" <http://electionlawblog.org/?p=61198>
Posted on May 4, 2014 9:22 pm <http://electionlawblog.org/?p=61198>by
Rick Hasen <http://electionlawblog.org/?author=3>
Ballot Access News
<http://www.ballot-access.org/2014/05/congressman-john-conyers-probably-will-file-a-lawsuit-to-get-on-democratic-primary-ballot/>:
Michigan election officials are likely to keep Congressman John
Conyers off the August 5 primary ballot, unless he files and wins a
lawsuit. See this story
<http://www.freep.com/article/20140502/NEWS06/305020117/John-Conyers-Cathy-Garrett>,
which explains that Michigan law requires circulators for primary
candidates to be registered voters. It appears some of Conyers'
circulators weren't registered voters when they circulated his
petition. He needed 1,000 signatures, and he has fewer than 1,000 if
the petitions circulated by the apparently unregistered voters are
excluded.
As the story says, in 1999 the U.S. Supreme Court ruled in Buckley v
American Constitutional Law Foundation that states cannot require
petitioners to be registered voters. Although that case involved
initiative petitions, lower courts since 1999 have unanimously ruled
that the principle applies to all types of petitions.
In 2009, a U.S. District Court in Michigan ruled, "Overall, the
Court finds that the distinctions between the various kinds of
petition circulators are not of great significance to the analysis
of the burdens posed by registration and residency requirements."
That case struck down a requirement that recall petition circulators
must be registered voters. Ironically, in that case, the state of
Michigan argued that while a residency requirement and a
registration requirement for circulators of candidate petitions is a
severe burden, the requirement as applied to recall petitioners is
not severe. The Court rejected the state's argument. That decision
is Bogaert v Land, western district, 1:08-cv-687, issued December
17, 2009.
So far, Michigan officials are saying that whereas residency
requirements for circulators of independent candidate petitions are
unconstitutional, residency requirements for circulators of primary
candidates are constitutional. There is no case law to support that
conclusion....
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Posted in ballot access <http://electionlawblog.org/?cat=46>, direct
democracy <http://electionlawblog.org/?cat=62>, petition signature
gathering <http://electionlawblog.org/?cat=39>
LA Times Endorses Pete Peterson, Only Republican Preference
Candidate for Secretary of State, Because He Would Focus on "the
More Mundane Tasks of the Job" <http://electionlawblog.org/?p=61196>
Posted on May 4, 2014 9:10 pm <http://electionlawblog.org/?p=61196>by
Rick Hasen <http://electionlawblog.org/?author=3>
Just as interesting
<http://www.latimes.com/opinion/endorsements/la-ed-end-secretary-of-state-20140504,0,4204662.story#axzz30oKeggZ0>
is why the Times does not like the "reform" candidates in the race:
Like Peterson, Derek Cressman, a Democrat, has excellent
qualifications for the job. As an executive with the good-government
group Common Cause, Cressman advocated for fair elections and
campaign finance reform, and he would continue that advocacy as
secretary of state. He has intelligent ideas about how to improve
voter education, including creating an online voter guide with
candidate videos, footage of debates and campaign contribution data.
Similarly, Dan Schnur would fight for anti-corruption laws,
including banning political contributions during the legislative
session. A former Republican consultant who became the director of
the Jesse M. Unruh Institute of Politics at USC, Schnur is running
as an independent and hopes to be the first independent candidate
elected to statewide office.
But both Cressman and Schnur are too focused on making the office a
bully pulpit for political reform rather than addressing the more
mundane tasks of the job.
State Sen. Alex Padilla
<http://www.latimes.com/topic/politics/government/alex-padilla-PEPLT00008179.topic>
(D-Pacoima) has immersed himself in the details of the job, meeting
with most county election officials and introducing bills to ban
campaign contributions in the final 100 days of the legislative
session and to increase the frequency of campaign finance
disclosures. Yet we are concerned that Padilla sees the job merely
as a steppingstone to higher office, at a moment when California
needs a secretary of state who is 100% committed to modernizing the
office, creating more transparent political campaigns and helping
increase the number of educated, engaged and voting citizens.
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Posted in election administration <http://electionlawblog.org/?cat=18>
"Liberal donors eye new long-term investments in states and new
voters to boost Democrats" <http://electionlawblog.org/?p=61194>
Posted on May 4, 2014 9:06 pm <http://electionlawblog.org/?p=61194>by
Rick Hasen <http://electionlawblog.org/?author=3>
WaPo
<http://www.washingtonpost.com/politics/liberal-donors-eye-new-long-term-investments-in-states-and-new-voters-to-boost-democrats/2014/05/04/0433e53a-d20f-11e3-9e25-188ebe1fa93b_story.html>:
A group of wealthy liberal donors who helped bankroll the Center for
American Progress and other major advocacy groups on the left is
developing a new big-money strategy that could boost state-level
Democratic candidates and mobilize core party voters.
The plan, being crafted in private by a group of about 100 donors
that includes billionaire hedge fund manager George Soros and San
Francisco venture capitalist Rob McKay, seeks to give Democrats a
stronger hand in the redrawing of district lines for state
legislatures and the U.S. House.
The effort reflects a sense among many top donors on the left that
Democrats missed opportunities in 2010 to shape the redistricting
process and contain the tea party wave that helped propel Republican
victories around the country.
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Posted in campaigns <http://electionlawblog.org/?cat=59>, political
parties <http://electionlawblog.org/?cat=25>, political polarization
<http://electionlawblog.org/?cat=68>, redistricting
<http://electionlawblog.org/?cat=6>
"Fewer lobbyists are passing through the revolving door from K
Street to Capitol Hill" <http://electionlawblog.org/?p=61192>
Posted on May 4, 2014 9:04 pm <http://electionlawblog.org/?p=61192>by
Rick Hasen <http://electionlawblog.org/?author=3>
WaPo reports
<http://www.washingtonpost.com/politics/fewer-lobbyists-are-passing-through-the-revolving-door-from-k-street-to-capitol-hill/2014/05/04/1c86939e-cfc1-11e3-a6b1-45c4dffb85a6_story.html>.
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Posted in campaigns <http://electionlawblog.org/?cat=59>, lobbying
<http://electionlawblog.org/?cat=28>
"The Battle to Protect Voting Rights"
<http://electionlawblog.org/?p=61190>
Posted on May 4, 2014 9:01 pm <http://electionlawblog.org/?p=61190>by
Rick Hasen <http://electionlawblog.org/?author=3>
Al Hunt
<http://www.nytimes.com/2014/05/05/us/politics/the-battle-to-protect-voting-rights.html?ref=politics>
for Bloomberg View/International NYT.
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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>
New "Latino Victory Project" Gets NYT Launch Coverage
<http://electionlawblog.org/?p=61188>
Posted on May 4, 2014 8:59 pm <http://electionlawblog.org/?p=61188>by
Rick Hasen <http://electionlawblog.org/?author=3>
Here
<http://www.nytimes.com/2014/05/05/us/politics/in-california-race-a-latina-democrat-carries-hopes-of-her-party-and-people.html?ref=politics&_r=0>.
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Posted in voting <http://electionlawblog.org/?cat=31>
When One Justice Makes a Mistake, It is an Embarrassing Blunder. But
When 9 Do, Silence. <http://electionlawblog.org/?p=61184>
Posted on May 4, 2014 5:00 pm <http://electionlawblog.org/?p=61184>by
Rick Hasen <http://electionlawblog.org/?author=3>
Bob Barnes of the Washington Post has a nice recap
<http://www.washingtonpost.com/politics/2014/05/03/8629d9d8-d231-11e3-937f-d3026234b51c_story.html>
of the partisanship surrounding Justice Scalia's error in a recent case
in which he mischaracterized a precedent (a precedent whose opinion he
authored). Justice Stevens made a mistake
<http://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/05/02/justice-stevens-made-the-same-mistake-before-justice-scalia/>
like this in a case as well, and Eugene Volokh offers more, some
corrected, some not
<http://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/05/02/errors-in-supreme-court-opinions/>.
These mistakes are easy to flag as mistakes because there is another
precedent to compare---the mistake consists of how a prior case is
characterized. But consider another kind of mistake: where a Court
opinion mischaracterize the law in a way that changes the law in a major
way, perhaps through inadvertence. That's what happened with a case on
the standard for permanent injunctions a few years ago, /eBay v.
MercExchange. /This kind of error is much more serious than the kind of
error Justice Scalia made, which changed neither the holding of a case
nor the standards lower courts would apply to a legal issue. The error
I described has changed the law in profound ways, and the Court has
never acknowledged that it might have resulted from an error.
Here's my analysis from a recent article in the /Emory Law Journal/,
Anticipatory Overrulings, Invitations, Time Bombs, and Inadvertence: How
Supreme Court Justices Move the Law
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1750398>.
D. Inadvertence
Inadvertence occurs when the Court changes the law without
consciously attempting to do so, through attempts to restate
existing law in line with the writing Justice's values. Of course,
it is possible that some of these misstatements of the law are
intentional, either on the part of a Justice or Justices or a clerk,
as a surreptitious means of shifting the law without alerting the
other Justices of the shift.[1] <http://electionlawblog.org/#_ftn1>
But the issue of such devious motivation is very difficult to
prove,[2] <http://electionlawblog.org/#_ftn2> and it is enough for
my purposes to treat all cases of legal misstatements as those of
inadvertence.
Consider the Supreme Court's recent treatment of the standards for
issuing permanent injunctions. In /eBay Inc. v. MercExchange
L. L. C./, the Supreme Court reversed a "'general rule,' [of the
United States Court of Appeals for the Federal Circuit] unique to
patent disputes, 'that a permanent injunction will issue once
infringement and validity have been adjudged.'"[3]
<http://electionlawblog.org/#_ftn3> Unremarkably, the Supreme Court,
in an opinion by Justice Thomas, held that the question of the
issuance of a permanent injunction must be judged on a case-by-case
basis through the application of judicial discretion.[4]
<http://electionlawblog.org/#_ftn4> It rejected the Federal
Circuit's special rule for patent injunctions.[5]
<http://electionlawblog.org/#_ftn5> The surprise in the case came in
the Court's statement of the "well-established principles"
applicable to the issuance of permanent injunctions:
*According to well-established principles of equity, a plaintiff
seeking a permanent injunction must satisfy a four-factor test
before a court may grant such relief. A plaintiff must demonstrate:
(1) that it has suffered an irreparable injury; (2) that remedies
available at law, such as monetary damages, are inadequate to
compensate for that injury; (3) that, considering the balance of
hardships between the plaintiff and defendant, a remedy in equity is
warranted; and (4) that the public interest would not be disserved
by a permanent injunction. The decision to grant or deny permanent
injunctive relief is an act of equitable discretion by the district
court, reviewable on appeal for abuse of discretion.[6]
<http://electionlawblog.org/#_ftn6>*
A major problem with the Supreme Court's recitation of this
supposedly "well-established" four-part test is that the test did
not exist before. Professor Doug Rendleman explained that
"[r]emedies specialists had never heard of the four-point test."[7]
<http://electionlawblog.org/#_ftn7> There was a familiar four-part
test for the issuance of /preliminary/ injunctions, but it was not
this same test.[8] <http://electionlawblog.org/#_ftn8> The test for
preliminary injunctions, which looks in part at future likelihood of
success on the merits, "make[s] no sense as applied to /permanent
/injunctions."[9] <http://electionlawblog.org/#_ftn9>
So how did this new test come into being in /eBay/? Professor
Laycock explains what appears to be Justice Thomas's inadvertence:
EBay and many of its amici, and the U.S. Solicitor General, who was
supporting MercExchange, all referred to some version of four
traditional considerations relevant to injunctive relief. They did
not all cite the same four factors, and none of the lead briefs
offered anything so flat footed as the Court's formulation. The
Court appears to have mostly taken its four-part test from the
district court, which took it from one earlier district court
opinion; putting irreparable injury in the past tense appears to
have been an innovation by Justice Thomas or one of his clerks. And
because the opinion gives no hint how any of the four parts of the
test apply to the facts of the case, its abstract pronouncement has
no real content. The case was litigated by an all-star cast of
Supreme Court lawyers, but none of them consulted a remedies
specialist.[10] <http://electionlawblog.org/#_ftn10>
But Court inadvertence takes on a life of its own.[11]
<http://electionlawblog.org/#_ftn11> The /eBay /test has now been
cited and applied by numerous lower courts,[12]
<http://electionlawblog.org/#_ftn12> and the Court recently
reaffirmed it as the "traditional four-factor test" last term
in/Monsanto Co. v. Geertson Seed Farms/.[13]
<http://electionlawblog.org/#_ftn13> "And once again the Court
appeared oblivious to any difference between permanent and
preliminary injunctions."[14] <http://electionlawblog.org/#_ftn14>
In the /eBay /and /Monsanto /cases, the law moved, significantly,
through apparent inadvertence. The term "inadvertence" might suggest
some randomness, but I expect inadvertent mistakes to more
systematically reflect the value judgments of the Justice drafting
the opinion. The causal mechanism for such a bias is
straightforward: an error in stating existing law (or inadvertent
change of law) in a draft opinion is less likely to capture the
attention of a Justice reviewing a draft opinion if the error is in
line with what the Justice expects the law to be.
The /eBay/ case provides a nice example of the nonrandomness of
inadvertence. In applying the (new) four-part test, the Court's
analysis in /Monsanto/ increased the burdens on plaintiffs seeking
permanent injunctions.[15] <http://electionlawblog.org/#_ftn15>
Before /eBay/, the common understanding was that it was up to a
defendant to raise the question of the public interest as a kind of
affirmative defense if the defendant believed the injunction sought
by the plaintiff did not serve the public interest.[16]
<http://electionlawblog.org/#_ftn16> Under the new test, however,
the /plaintiff/ must demonstrate that the public interest "would not
be /disserved/" by a permanent injunction.[17]
<http://electionlawblog.org/#_ftn17> As Professor Laycock asks:
"Might this mean that benefits to the public interest cannot count
in favor of issuing the injunction, but that harm to the public
interest is an absolute reason not to issue it? Did Justice Thomas
choose that phrasing deliberately in /eBay/, or might it be
inadvertent?"[18] <http://electionlawblog.org/#_ftn18> Whatever
Justice Thomas intended, he has certainly written or signed onto a
number of opinions in recent years that make it harder for
plaintiffs to obtain an injunction and easier for defendants to seek
modifications of injunctions that ease the burden on defendants.[19]
<http://electionlawblog.org/#_ftn19> His inadvertence appears to
line up with his values.
------------------------------------------------------------------------
[1] Douglas Laycock, /Federal Interference with State
Prosecutions: The Cases /Dombrowski/Forgot/, 46 U. Chi. L. Rev. 636,
670 (1979) ("It reads as though the Court were unaware of any case
after /Douglas/, but the Court could have deliberately created that
impression.").
[2] /Id./ at 669--79 (providing detailed analysis to
determine possible Supreme Court Justices' motivations in ignoring
relevant precedent in /Dombrowski v. Pfister/, 380 U.S. 479 (1965),
and concluding that the reason for ignoring precedent was likely
inadvertence).
[3] 547 U.S. 388, 393--94 (2006).
//[4]/ See id. /at 391.
//[5]/ See id. /at 393--94.
//[6]/ Id./ at 391 (citations omitted).
[7] Doug Rendleman, /The Trial Judge's Equitable
Discretion Following /eBay v. MercExchange, 27 Rev. Litig. 63, 76
n.71 (2007); /accord/ Doug Rendleman & Caprice L. Roberts, Remedies:
Cases and Materials 273 (8th ed. 2011).
[8] Rendleman, /supra /note 83, at 76 n.71.
//[9]/ See/ Douglas Laycock, Modern American Remedies: Cases and
Materials 426 (4th ed. 2010) (emphasis added). The test also suffers
from other problems, such as that the first and second elements
appear to be asking the same question. /Id./ at 426--27.
//[10]/ Id./ at 427.
//[11]/ See id./ ("There was no such test before, but there is now.").
//[12]/ See id. /("By early May 2010, /eBay/ had been cited more
than 4,100 times.").
[13] 130 S. Ct. 2743, 2757 (2010).
[14] Douglas Laycock, Modern American Remedies 26 (2011
Teachers' Update).
[15] 130 S. Ct. at 2757 ("It is not enough for a court
considering a request for injunctive relief to ask whether there is
a good reason why an injunction should /not/ issue; rather, a court
must determine that an injunction /should/ issue under the
traditional four-factor test set out above.").
//[16]/ See /Laycock, /supra/ note 85,//at 426--27.
//[17]/ eBay/, 547 U.S. at 391.
[18] Laycock, /supra/ note 90, at 4.
[19] /See, e.g./, /Monsanto/, 130 S. Ct. 2743;/see also
/Horne v. Flores, 129 S. Ct. 2579, 2593 (2009) ("The party seeking
relief bears the burden of establishing that changed circumstances
warrant relief, but once a party carries this burden, a court abuses
its discretion 'when it refuses to modify an injunction or consent
decree in light of such changes.''' (citation omitted) (quoting
Agostini v. Felton 521 U.S. 203, 215 (1997))); Winter v. Natural
Res. Def. Council, Inc., 129 S. Ct. 365, 375--76 (2008) ("Issuing a
preliminary injunction based only on a possibility of irreparable
harm is inconsistent with our characterization of injunctive relief
as an extraordinary remedy that may only be awarded upon a clear
showing that the plaintiff is entitled to such relief.").
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Posted in Supreme Court <http://electionlawblog.org/?cat=29>
"Prosecutors: County candidate lied about home address, drawing
felony voter fraud charges" <http://electionlawblog.org/?p=61182>
Posted on May 4, 2014 4:42 pm <http://electionlawblog.org/?p=61182>by
Rick Hasen <http://electionlawblog.org/?author=3>
AP
<http://www.dailyjournal.net/view/story/7ab3ab49792142c4bb9406777277bff5/CA--Candidate-Charged-Alameda-County/#.U2bP8ceCrjw>:
"Prosecutors say a woman running for the office of auditor-controller in
Alameda County lied about her address and now faces criminal charges."
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Posted in residency <http://electionlawblog.org/?cat=38>
"In Colorado, an effort to revive democracy"
<http://electionlawblog.org/?p=61180>
Posted on May 4, 2014 4:40 pm <http://electionlawblog.org/?p=61180>by
Rick Hasen <http://electionlawblog.org/?author=3>
Ryan Ross
<http://www.denverpost.com/opinion/ci_25684761/colorado-an-e-8800-ort-revive-democracy#ixzz30lwXXZir>:
An election initiative recently approved for signature-gathering by
Colorado ballot-access regulators means that for the first time in a
century, Coloradans have an alternative to political stagnation,
hyper-partisanship, and a seemingly endless stream of political
acrimony, recalls, court fights, government shutdowns, secession
movements and negative campaign ads.
That alternative is to give more power to the radical center, where
compromise is a virtue, where progress becomes the norm, not the
exception, where Coloradans can renew their faith in their state ---
and their country --- and where the economy can get supercharged, so
that job growth and wealth creation are accelerated.
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Posted in direct democracy <http://electionlawblog.org/?cat=62>
"Got a Voter ID?" <http://electionlawblog.org/?p=61178>
Posted on May 4, 2014 4:35 pm <http://electionlawblog.org/?p=61178>by
Rick Hasen <http://electionlawblog.org/?author=3>
Jessica Levinson oped
<http://politix.topix.com/story/11871-got-a-voter-id>on Politix.
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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>
"Voter ID is not worth the cost: Our View; Judge finds virtually no
evidence of voter fraud in Wisconsin"
<http://electionlawblog.org/?p=61176>
Posted on May 4, 2014 4:34 pm <http://electionlawblog.org/?p=61176>by
Rick Hasen <http://electionlawblog.org/?author=3>
Gannett editorial.
<http://www.wausaudailyherald.com/article/20140504/WDH06/305040079/Voter-ID-not-worth-cost-Our-View>
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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>
Must-Read Milwaukee Journal-Sentinel Analysis of Political
Polarization in Milwaukee and Wisconsin
<http://electionlawblog.org/?p=61174>
Posted on May 4, 2014 4:31 pm <http://electionlawblog.org/?p=61174>by
Rick Hasen <http://electionlawblog.org/?author=3>
Stark.
<http://www.jsonline.com/news/statepolitics/democratic-republican-voters-worlds-apart-in-divided-wisconsin-b99249564z1-255883361.html>
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Posted in political parties <http://electionlawblog.org/?cat=25>,
political polarization <http://electionlawblog.org/?cat=68>
--
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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