[EL] Wisconsin John Doe decision

JBoppjr at aol.com JBoppjr at aol.com
Sat May 10 05:48:07 PDT 2014


Actually the effect of declaring speech a contribution, by deeming it to be 
 coordinated, does prohibit a  corp or labor union from doing it.  CU  
struck down the corp prohibition on doing ECs so labeling ECs as a contribution  
does the same thing and I doubt the Court will buy that.  It has nothing to 
 do with "disclosure."  Jim
 
 
In a message dated 5/10/2014 8:36:03 A.M. Eastern Daylight Time,  
tpotter at capdale.com writes:

What the  court said in CU is not that the electioneering communication 
standard was  unconstitutional-- it upheld the disclosure provisions of the 
standard 8-1  after all. Rather , the Court's opinion address only the portion 
of that  standard that forbade corporations from making such communications. 
Thus, the  usefulness of the standard as a descriptor or political speech 
and activity is  not impaired by CU.

Trevor Potter

Sent from my iPhone

On  May 10, 2014, at 7:34 AM, "JBoppjr at aol.com<mailto:JBoppjr at aol.com>"  
<JBoppjr at aol.com<mailto:JBoppjr at aol.com>>  wrote:

Hummmmmmmm. But I do seem to recall that CU said that the  "electioneering 
communication" provision that you want to use as a content  test for 
coordination is unconstitutional.

Anyone who relies on what is  left of McConnell is booking a trip on the 
Titanic.  Jim

In a  message dated 5/9/2014 9:19:22 P.M. Eastern Daylight Time,  
PRyan at campaignlegalcenter.org<mailto:PRyan at campaignlegalcenter.org>  writes:
Hmmmmmm. Seems like I don't recall any facts in the Citizens United  record 
related to coordination. Please tell us, Jim, about which electoral  
opponent of Hillary Clinton Citizens United was discussing movie and movioe ad  
details with.  As CU's counsel before the district court, you'd certainly  
know these facts.  Was it Barack Obama?  Envisioning Citizens United  
discussing movie and movie ad details with any of Ms. Clinton's primary  opponents is 
difficult.  I'm very excited to hear the coordination  backstory.  Best,

Paul S. Ryan
Sent from a handheld device.  Please pardon any typos.

On May 9, 2014, at 8:13 PM, "Jboppjr"  
<jboppjr at aol.com<mailto:jboppjr at aol.com>> wrote:

Seems like  I recall that Citizens United changed the law a bit. Jim  Bopp


-------- Original message --------
From: Paul Ryan  
<PRyan at campaignlegalcenter.org<mailto:PRyan at campaignlegalcenter.org>>
Date:  05/08/2014 10:24 AM (GMT-05:00)
To:  law-election at uci.edu<mailto:law-election at uci.edu>
Subject: Re: [EL]  Wisconsin John Doe decision


Echoing Trevor’s point about the  federal law “electioneering communication
” standard being a constitutionally  permissible bright line test, and 
pushing back against Jim’s suggestion that  such a test is “way overbroad and 
probably unconstitutional,” it’s worth  noting that the Supreme Court in 
McConnell explicitly upheld as constitutional  the treatment of coordinated “
electioneering communication” as contributions,  and explicitly rejected Judge 
Randa’s view that only express advocacy can be  subject to a coordination 
analysis.  The McConnell Court  wrote:

Section 202 of BCRA amends FECA . . . to provide that  disbursements for “
electioneering communication[s]” that are coordinated with  a candidate or 
party will be treated as contributions to, and expenditures by,  that 
candidate or party.  The amendment clarifies the scope of the  preceding subsection, 
which states more generally that “expenditures made by  any person in 
cooperation, consultation, or concert, with, or at the request  or suggestion of” 
a candidate or party will constitute contributions.  In  Buckley we 
construed the statutory term “expenditure” to reach only spending  for express 
advocacy.  BCRA § 202 pre-empts a possible claim that §  315(a)(7)(B) is 
similarly limited, such that coordinated expenditures for  communications that 
avoid express advocacy cannot be counted as  contributions.  As we explained 
above, Buckley's narrow interpretation of  the term “expenditure” was not a 
constitutional limitation on Congress' power  to regulate federal elections.  
Accordingly, there is no reason why  Congress may not treat coordinated 
disbursements for electioneering  communications in the same way it treats all 
other coordinated  expenditures.  We affirm the judgment of the District 
Court insofar as it  held that plaintiffs had advanced “no basis for finding 
Section 202  unconstitutional.”

McConnell, 540 U.S. at 202-03 (internal citations  omitted).

Paul Seamus Ryan
Senior Counsel
The Campaign Legal  Center, Recipient of the 2014 MacArthur Award for 
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From:  
law-election-bounces at department-lists.uci.edu<mailto:law-election-bounces at department-lists.uci.edu>  
[mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of  JBoppjr at aol.com<mailto:JBoppjr at aol.com>
Sent: Thursday, May 08, 2014  8:53 AM
To: rhasen at law.uci.edu<mailto:rhasen at law.uci.edu>; TP  External
Cc:  law-election at uci.edu<mailto:law-election at uci.edu>
Subject: Re: [EL]  [Leg] Wisconsin John Doe decision

I agree that this is a bright line  test but way overbroad and probably 
unconstitutional under Citizens United  which struck an identical standard.

However, in Wisc there is no such  provision. The prosecutors are just 
making up the law as they raid innocent  people's homes in the middle of the 
night with guns drawn (ok maybe they had  not drawn their guns -- yet) .  Jim

In a message dated 5/7/2014  5:19:18 P.M. Eastern Daylight Time,  
rhasen at law.uci.edu<mailto:rhasen at law.uci.edu> writes:
I had  inadvertently sent one of my posts to the Legislation list, and
then Trevor  and Jim both responded on that list. Bringing this back to
the Election Law  list---members should see Trevor and Jim's posts below.

On 5/7/14, 2:16  PM, Trevor Potter wrote:
> The federal election communications standard  provides such a bright line 
test-- a public advertisement naming a candidate  during the election 
period ( numbered days) and run in the district or state  where the election 
occurs....
>
> The FEC coordination regs  similarly address this issue by creating 
measurable tests . They are not as  inclusive as I believe they should be, but 
they exist.
>
>  Trevor
>
> Sent from my iPad
>
> On May 7, 2014, at  4:40 PM, "Jboppjr"  
<jboppjr at aol.com<mailto:jboppjr at aol.com<mailto:jboppjr at aol.com%3cmailto:jboppjr at aol.com>>>  wrote:
>
> The problem in this area is that without a bright line  test for what 
communications are political and trigger coordination concerns  is that every 
allegation of coordination would trigger this type of ugly  investigation. 
This is intolerable.  Jim Bopp
>
>
>  -------- Original message --------
> From: Rick Hasen  
<rhasen at law.uci.edu<mailto:rhasen at law.uci.edu<mailto:rhasen at law.uci.edu%3cmailto:rhasen at law.uci.edu>>>
>  Date: 05/07/2014 10:32 AM (GMT-05:00)
> To: "Smith, Brad"  
<BSmith at law.capital.edu<mailto:BSmith at law.capital.edu<mailto:BSmith at law.capital.edu%3cmailto:BSmith at law.capital.edu>>>,law-legislat
ion at uci.edu<mailto:law-legislation at uci.edu><mailto:law-legislation at uci.edu>,
"Confessore,  Nicholas"  
<nconfess at nytimes.com<mailto:nconfess at nytimes.com<mailto:nconfess at nytimes.com%3cmailto:nconfess at nytimes.com>>>
>  Subject: Re: [Leg] [EL] Wisconsin John Doe decision
>
>
>  Brad (and the judge) may be right on the end result.  I haven't followed 
 this quite closely enough to have a strong and fully informed  opinion.
>
> But I am concerned about the broad language of the  opinion. I do think 
this ruling breaks new ground and goes much further than  even Citizens 
United and McCutcheon.  While the Supreme Court is willing  to tolerate 
circumvention of rules in the name of the First Amendment, this  ruling celebrates 
it.  Further, it sees extensive cooperation between  candidate campaigns and 
outside groups as well protected by the First  Amendment when in fact it is 
the presence or absence of this cooperation which  has been key in creating 
the dividing line between contributions and  expenditures.  By blurring the 
rationales between contributions and  expenditures, and by solidifying the 
distinction between express advocacy and  issue advocacy, the opinion, if it 
stands, would lead to even further  deregulation of the political system.
>
>
> On 5/7/14, 6:52  AM, Smith, Brad wrote:
> This is an extremely important ruling. Under  the theory advanced by the 
state, a great many of the individuals on this  list, and the organizations 
with which many are affiliated, including many  "reform" organizations, 
could be subjected to the same type of investigations  that were underway in 
Wisconsin. People in politics know each other and work  together on projects. 
Issues can and do affect campaigns for office. The  decision does not 
dramatically alter federal law, but it makes clear that  sweeping allegations of 
"coordination," and ensuing investigations, cannot be  used as a substitute 
for the outright suppression of speech that many wish  were in the law.
>
> Coordination allegations are easily made. We  know, for example, that 
Craig Holman is up on the Hill all the time, and we  know some of the members 
with whom he speaks; we know of Trevor Potter's tight  relationship with 
certain members of the Keating 5; we know that Fred  Wertheimer and Norm 
Ornstein work closely with various members. We know that  the groups with which 
they are affiliated trumpet issues of importance to  these members, often 
favorably quote these members, sometimes give them awards  at big dinners in New 
York City that raise hundreds of thousands for the  Brennan Center, which 
can put those funds back into promoting these same  issues and the candidates 
affiliated with them. A knows B who knows C who  knows D, and they are all 
talking about X. Voila! Coordination! If, as most in  the reform camp argue, 
there need be no election advocacy to bring an  allegedly coordinated 
communication within the regulatory purview of the law,  than the routine 
communications by all these groups could easily be deemed  "coordinated." 
Fortunately, there has generally been some self-restraint in  pushing coordination 
allegations, perhaps because all involved realize that  under the expansive 
theories of "coordination" some advocate, a huge swath of  routine and highly 
valuable political activity would suddenly be  illegal.
>
> But allegations are made at times, and once made,  coordination 
investigations are among the most intrusive the government can  undertake. By 
definition, they involve pawing through organizational records,  learning who meets 
with whom, what they talk about, how officeholders and  advocacy groups 
coordinate messages and work to pass legislation. They involve  numerous 
depositions and demands for countless documents. Conducting these  investigations 
under criminal law - and in secret, no less - merely makes the  problem 
greater. Jim Bopp, Heidi Abegg and others have written about this at  length in 
numerous law review pieces. Steve Hoersting and I addressed the  problem in 
an Election Law Journal article, "A Toothless Anaconda," and also  in my 
Statement of Reasons in FEC MUR 4626, available here:  
http://www.fec.gov/members/former_members/smith/smithreason6.htm. As I note in  the outset to that 
SOR,
>
> "Despite the fact that the Commission  has now found no violations in 
this case, I strongly suspect that the original  complainant, the Democratic 
National Committee, considers its complaint to  have been a success.  The 
complaint undoubtedly forced their political  opponents to spend hundreds of 
thousands, if not millions of dollars in legal  fees, and to devote countless 
hours of staff, candidate, and executive time to  responding to discovery and 
handling legal matters.  Despite our finding  that their activities were 
not coordinated and so did not violate the Act, I  strongly suspect that the 
huge costs imposed by the investigation will  discourage similar 
participation by these and other groups in the  future."
>
> There are very few federal court decisions on  coordination, but they 
have generally taken a similar hard line against the  government. See FEC v. 
Christian Coalition, 52 F. Supp.2d 45 (D.D.C. 1999). So  in that sense, the 
Wisconsin decision does not make new law. But it does  emphasize good law in 
an area that has been largely unsupervised by the  courts.
>
> A potentially unique element is that Wisconsin  substantive law requires 
"express advocacy" even for "coordinated  communications." This clearly 
shows the wisdom of having some type of "content  standard" for determining if 
something is "coordinated"  as a threshold  barrier to exactly this type of 
intrusive investigation. As I point in MUR  4626 quoted above, absent a 
"content" threshold, coordination allegations are  very easy to make and the 
process is itself the punishment, as we saw both in  MUR 4626 and in this very 
case in Wisconsin. The key paragraph to  understanding yesterday's ruling is 
the paragraph beginning at the bottom of  page 19,  and footnote 7 which 
immediately precedes this paragraph. I'll  quote it here in it's entirety,:
>
> "fn.7
>  Moreover,  if Wisconsin could regulate issue advocacy — coordinated or 
otherwise —  it
> would open the door to a trial on every ad ―on the theory that the  
speaker actually intended to affect
> an election, no matter how  compelling the indications that the ad 
concerned a pending legislative  or
> policy issue. No reasonable speaker would choose to run an ad . . .  if 
its only defense to a criminal
> prosecution would be that its  motives were pure.‖ WRTL at 468.
>
> TEXT: "Defendants‘ attempt to  construe the term ―political purposes‖ to 
reach issue
> advocacy would  mean transforming issue advocacy into express advocacy by
>  interpretative legerdemain and not by any analysis as to why it would 
rise to  the level
> of quid pro quo corruption. As the defendants argue, the  Club would 
become a
> ―subcommittee‖ of a campaign  comm
=
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