[EL] ELB News and Commentary 11/14/14

Rick Hasen rhasen at law.uci.edu
Thu Nov 13 21:46:24 PST 2014


    "California Legislature is looking more moderate due to voting
    reforms" <http://electionlawblog.org/?p=68374>

Posted onNovember 13, 2014 9:41 pm 
<http://electionlawblog.org/?p=68374>byRick Hasen 
<http://electionlawblog.org/?author=3>

George 
Skelton<http://www.latimes.com/local/politics/la-me-cap-moderates-20141113-column.html>LAT 
column:

    Until last week, no Democratic state legislator running for
    reelection had lost to a Republican in 20 years. Then suddenly three
    did.

    When incumbents start losing their legislative seats, it means
    something is happening.

    The national Republican wave? Sure. Some of that washed into
    California. But it wasn't just that.

    Also credit --- or blame --- voter-approved reforms that are
    starting to affect California's legislative elections.

I'll be interested to see how social scientists respond to the claims in 
this column.

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Posted incitizen commissions 
<http://electionlawblog.org/?cat=7>,primaries 
<http://electionlawblog.org/?cat=32>,redistricting 
<http://electionlawblog.org/?cat=6>


    "Race, Politics and Drawing Maps; The Supreme Court Hears an Alabama
    Case on the Voting Rights Act" <http://electionlawblog.org/?p=68371>

Posted onNovember 13, 2014 9:27 pm 
<http://electionlawblog.org/?p=68371>byRick Hasen 
<http://electionlawblog.org/?author=3>

NYT editorial 
<http://www.nytimes.com/2014/11/14/opinion/the-supreme-court-hears-an-alabama-case-on-the-voting-rights-act.html?ref=politics>begins:

    As long as politicians are entrusted with drawing legislative maps,
    they will use their pen to gain partisan advantage. Courts generally
    do not interfere with that process, but there are limits to this
    where race is involved. The problem is figuring out which motive
    <http://harvardlawreview.org/2014/01/race-or-party-how-courts-should-think-about-republican-efforts-to-make-it-harder-to-vote-in-north-carolina-and-elsewhere/> ---
    race or partisanship --- underlies the redistricting. On Wednesday,
    the Supreme Court considered
    <http://www.nytimes.com/2014/11/13/us/justices-hear-black-lawmakers-challenge-to-alabama-redistricting.html?hp&action=click&pgtype=Homepage&module=second-column-region&region=top-news&WT.nav=top-news> this
    issue in a thorny case that could have significant implications for
    the future of the Voting Rights Act.

It concludes:

    A purpose of the voting rights law was to preserve the voting power
    of minority groups in different ways depending on local conditions.
    This kind of rigid redistricting isolates minority voters and limits
    their political power. It is up to the justices to reaffirm the law
    and, as the election-law scholar Justin Levitt has written, to stop
    lawmakers from turning "a refined and sophisticated piece of federal
    legislation into a cartoon."

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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court 
<http://electionlawblog.org/?cat=29>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    "Governing and Deciding Who Governs"
    <http://electionlawblog.org/?p=68369>

Posted onNovember 13, 2014 8:14 pm 
<http://electionlawblog.org/?p=68369>byRick Hasen 
<http://electionlawblog.org/?author=3>

Josh Chafetz has postedthis 
draft<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2522906>on SSRN 
(forthcoming, /University of Chicago Legal Forum/). Here is the abstract:

    In /McCutcheon v. Federal Election Commission/, Chief Justice
    Roberts wrote that, "Campaign finance restrictions that pursue other
    objectives [than eradicating /quid pro quo/ corruption or its
    appearance], we have explained, impermissibly inject the Government
    'into the debate over who should govern.' And those who govern
    should be the /last/ people to help decide who /should/ govern."

    This passage sounds great --- after all, who could object to an
    attempt to purge official self-dealing, especially in the
    election-law context? And therein lies its insidiousness: this
    rousing language masks a programmatic attempt by Roberts and his
    colleagues to distance themselves rhetorically from the structures
    and processes of governance and thereby to justify their privileged
    place above the other branches with regard to such issues.

    This essay, written for the /University of Chicago Legal Forum/'s
    2014 "Does Election Law Serve the Electorate?" symposium, identifies
    and unpacks two distinct distancing strategies exemplified in that
    passage. First, the Court's use of the first-person plural ("we have
    explained") posits a trans-temporal unified identity for the Court,
    which is implicitly contrasted with the shifts and vagaries of mere
    electoral politics. Part I examines this judicial self-presentation
    by contrasting the treatment of corruption in /Caperton/, on the one
    hand, and /Citizens United/ and /McCutcheon/, on the other. Second,
    Roberts's implicit contrasting of the Court with "those who govern"
    serves to suggest that the Court is somehow removed from the arena
    of partisan politics. Part II discusses this claim with reference
    to/Bush v. Gore/, /Shelby County/, and election-law disputes
    surrounding the 2014 midterms.

    The conclusion will consider what these rhetorical distancing
    strategies get the Court, and what a critical evaluation of them
    gets us.

I heard this paper presented last week and it sounds terrific.  I can't 
wait to read it!

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Posted incampaign finance <http://electionlawblog.org/?cat=10>,Supreme 
Court <http://electionlawblog.org/?cat=29>


    "Liberal Donors Looking 6 Years Ahead"
    <http://electionlawblog.org/?p=68367>

Posted onNovember 13, 2014 5:26 pm 
<http://electionlawblog.org/?p=68367>byRick Hasen 
<http://electionlawblog.org/?author=3>

Nick 
Confessore<http://www.nytimes.com/2014/11/14/us/politics/shaking-off-midterm-drubbing-liberal-donors-look-6-years-ahead.html?ref=politics&_r=0>in 
the NYT on the Democracy Alliance meeting.

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Posted incampaign finance <http://electionlawblog.org/?cat=10>


    "Outside Spending Didn't Buy The Election"
    <http://electionlawblog.org/?p=68365>

Posted onNovember 13, 2014 3:47 pm 
<http://electionlawblog.org/?p=68365>byRick Hasen 
<http://electionlawblog.org/?author=3>

Sabato's Crystal Ball 
<http://www.centerforpolitics.org/crystalball/articles/14-from-14-quick-takes-on-the-midterm/>:


      6. Outside groups didn't buy the election

    /Crystal Ball/ Senior Columnist Alan Abramowitz ran a regression
    analysis to see what effect outside spending had on the Senate
    races. The correlation between the Democratic and Republican outside
    spending difference and the Democratic margin was .23, which is not
    statistically significant. In contrast, the correlation between the
    Democratic margin and incumbency status was a more significant .76,
    and the correlation between the Democratic Senate margin in 2014 and
    the Democratic presidential vote margin in 2012 was an even more
    significant .89.

    In other words, partisanship in a polarized era, represented by the
    '12 presidential vote margin, was by far the strongest predictor of
    2014's Senate vote. Naturally, incumbency status is also
    significant. But the difference between amounts of outside spending
    by groups affiliated with both parties has surprisingly little
    effect, perhaps because both sides spent so much that the money from
    Republicans neutralized the cash from Democrats, and vice versa.

(h/tPolitical Wire 
<http://politicalwire.com/2014/11/13/outside-spending-didnt-buy-the-election/>)

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Posted incampaign finance <http://electionlawblog.org/?cat=10>


    Is Justice Thomas Gently Chiding CJ Roberts and J. Alito on Same Sex
    Marriage Cases? <http://electionlawblog.org/?p=68362>

Posted onNovember 13, 2014 1:48 pm 
<http://electionlawblog.org/?p=68362>byRick Hasen 
<http://electionlawblog.org/?author=3>

Important Josh Blackman post. 
<http://joshblackman.com/blog/2014/11/13/thomas-weighs-in-on-denial-of-stays-in-ssm-cases-our-recent-practice-however-gives-me-little-reason-to-be-optimistic/> "Thomas 
Weighs In On Denial Of Stays in SSM Cases: 'Our recent practice, 
however, gives me little reason to be optimistic.'"Justic

So this suggests that Scalia and Thomas have been voting to hear the 
same sex marriage cases, but they are not being joined by (most likely) 
Alito and Roberts.

Here's whatI wrote last year<http://electionlawblog.org/?p=57627>(in 
what has proven to be partially wrong, or premature), about why I 
expected a cert. grant in the same sex marriage cases:

    It takes only four votes to grant a cert. petition, and it is hard
    for me to imagine Justices Scalia, Thomas and Alito not wanting to
    take one of the cases coming up, such as the Utah case
    <http://www.buzzfeed.com/chrisgeidner/appeals-court-refuses-to-halt-utah-marriages-for-same-sex-co>,
    in which a federal court held that the state's ban on same-sex
    marriage violates both equal protection and due process guarantees,
    or the Ohio case
    <http://www.volokh.com/2013/12/23/limited-nature-ohio-sex-marriage-decision/>,
    where a federal judge indicated he's quite likely to reach that same
    result as to Ohio's law.  If lower courts are going to start siding
    with same-sex marriage proponents, and start legalizing same-sex
    marriage as a result of court order in places such as conservative
    Utah, then it seems hard to imagine Scalia, Thomas, and Alito not
    urging the Court to take the case.

    So where's the fourth vote?  I think Adam is right that Kennedy
    would rather let the issue percolate for a while (witness his
    convoluted opinion in /Windsor/
    <http://www.scotusblog.com/case-files/cases/windsor-v-united-states-2/>not
    addressing the issue more straightforwardly). But Chief Justice
    Roberts is a different story.  He appears in /Windsor/ to oppose
    judicial imposition of same sex marriage.  That's where his
    sympathies are. The question is whether he pulls the trigger or not
    and votes to take one of these cases. Strategically, he could decide
    it is better not to vote to take the cases if he thinks, as many
    thoughtful observers do, that if Kennedy had to decide the issue, he
    would side with the right to same-sex marriage.

    But that same strategic calculation which might lead the Chief not
    to vote to grant cert. could lead one of the four Court liberals to
    vote to take the case. That is, they too may want to force Kennedy's
    hand, if they are confident in his vote.  If it only takes one of
    the four to join in a vote for cert., I think it is pretty likely to
    happen. The way it might not happen happen is if Alito, Scalia and
    Thomas all decide to vote strategically not to hear these cases. 
    I'm guessing they won't be able to resist.

Of course, with the new Sixth Circuit opinion creating a Circuit split, 
I think it inevitable the Court will take up the issue very soon.

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Posted inSupreme Court <http://electionlawblog.org/?cat=29>


    "Most Americans Support Giving Congress More Power To Limit Campaign
    Spending" <http://electionlawblog.org/?p=68360>

Posted onNovember 13, 2014 1:22 pm 
<http://electionlawblog.org/?p=68360>byRick Hasen 
<http://electionlawblog.org/?author=3>

HuffPo: 
<http://www.huffingtonpost.com/2014/11/13/campaign-finance-poll_n_6153630.html?1415910964>"Most 
Americans say they think the billions of dollars spent on campaigns 
<http://www.huffingtonpost.com/2014/11/12/2014-election-big-business_n_6135914.html> affected 
the outcomes of the 2014 elections, and they support changing the 
Constitution to allow for more limits on spending, according to a new 
HuffPost/YouGov poll 
<https://today.yougov.com/news/2014/11/11/poll-results-spending/>."

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Posted incampaign finance <http://electionlawblog.org/?cat=10>


    "Longtime Massey Energy CEO Don Blankenship indicted"
    <http://electionlawblog.org/?p=68358>

Posted onNovember 13, 2014 1:19 pm 
<http://electionlawblog.org/?p=68358>byRick Hasen 
<http://electionlawblog.org/?author=3>

He <http://www.wvgazette.com/article/20141113/GZ01/141119629/1104>, 
ofCaperton v. Massey 
<http://scholar.google.com/scholar_case?case=12433246201492395798&hl=en&as_sdt=6&as_vis=1&oi=scholarr>.

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Posted injudicial elections <http://electionlawblog.org/?cat=19>,Supreme 
Court <http://electionlawblog.org/?cat=29>


    "Podcast: The Supreme Court considers racial gerrymandering"
    <http://electionlawblog.org/?p=68356>

Posted onNovember 13, 2014 1:18 pm 
<http://electionlawblog.org/?p=68356>byRick Hasen 
<http://electionlawblog.org/?author=3>

National Constitution Center 
<http://blog.constitutioncenter.org/2014/11/podcast-the-supreme-court-considers-racial-gerrymandering/>:

    Rick Hasen from the UC-Irvine School of Law and Roger Clegg from the
    Center for Equal Opportunity join our Jeffrey Rosen to discuss one
    of the biggest Supreme Court cases this term, about the roles of
    race and party in determining election districts.

    This week, the U.S. Supreme Court heard oral arguments in two
    combined cases from Alabama that asked the Justices to parse out the
    process of gerrymandering.

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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court 
<http://electionlawblog.org/?cat=29>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    Wow, NOM Urging KS Governor to Ignore Order of Federal Court on Same
    Sex Marriage <http://electionlawblog.org/?p=68354>

Posted onNovember 13, 2014 12:56 pm 
<http://electionlawblog.org/?p=68354>byRick Hasen 
<http://electionlawblog.org/?author=3>

Chris Geidner 
<https://twitter.com/chrisgeidner/status/532999384469098496>has the 
press release. This is quite an escalation toward civil disobedience.

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Posted inUncategorized <http://electionlawblog.org/?cat=1>


    "Loretta Lynch on Voting Rights, Terror Trials and the Press"
    <http://electionlawblog.org/?p=68352>

Posted onNovember 13, 2014 12:42 pm 
<http://electionlawblog.org/?p=68352>byRick Hasen 
<http://electionlawblog.org/?author=3>

Mike Sacks for BLT 
<http://www.nationallawjournal.com/legaltimes/id=1202676333213/Loretta-Lynch-on-Voting-Rights-Terror-Trials-and-the-Press?cmp=share_twitter&slreturn=20141013153532>.

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Posted inDepartment of Justice <http://electionlawblog.org/?cat=26>,The 
Voting Wars <http://electionlawblog.org/?cat=60>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    "Voting rights battles will continue before 2016?
    <http://electionlawblog.org/?p=68350>

Posted onNovember 13, 2014 12:24 pm 
<http://electionlawblog.org/?p=68350>byRick Hasen 
<http://electionlawblog.org/?author=3>

USA Today: 
<http://www.usatoday.com/story/news/politics/2014/11/13/voting-rights-legal-challenge/18955055/>"Supreme 
Court rulings forced last-minute changes in state voting procedures for 
the midterm elections across the country, but the battle over voting 
rules is far from over. Courts are still hearing arguments over voter ID 
and early voting laws, legal challenges that could reshuffle voting 
rules again before 2016, when a presidential election will probably 
increase voter turnout and long lines at polls."

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


    "After takeover, Nevada GOPers ready voter ID"
    <http://electionlawblog.org/?p=68348>

Posted onNovember 13, 2014 10:36 am 
<http://electionlawblog.org/?p=68348>byRick Hasen 
<http://electionlawblog.org/?author=3>

MSNBC 
<http://www.msnbc.com/msnbc/after-takeover-nevada-gopers-ready-voter-id>: "Yet 
another Republican-controlled state is looking to impose a voter ID law 
just in time for the 2016 elections. GOP state lawmakers in Nevada are 
readying ID bills for early next year, Secretary of State-Elect Barbara 
Cegavske told msnbc in an interview. Cegavske said she knew of two 
separate bills that might end up being merged together."

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


    "News Analysis: The kids are alright Millennials stayed away, but
    young people worked hard Nov. 4? <http://electionlawblog.org/?p=68346>

Posted onNovember 13, 2014 10:33 am 
<http://electionlawblog.org/?p=68346>byRick Hasen 
<http://electionlawblog.org/?author=3>

That's the lead story 
<http://www.electionline.org/index.php/electionline-weekly>in this 
week's Electionline Weekly.

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Posted inelection administration <http://electionlawblog.org/?cat=18>


    "Behind the Ballot Box: How Do You Run an Election When the Rules
    Keep Changing?" <http://electionlawblog.org/?p=68344>

Posted onNovember 13, 2014 10:33 am 
<http://electionlawblog.org/?p=68344>byRick Hasen 
<http://electionlawblog.org/?author=3>

Extensive Abby Rapoport 
report<http://www.nationaljournal.com/magazine/the-epic-2014-frenzy-voters-never-saw-20141107>in 
the National Journal on litigation just before the election, some of 
which made it to the Supreme court.

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Posted inelection administration 
<http://electionlawblog.org/?cat=18>,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
http://www.law.uci.edu/faculty/full-time/hasen/
http://electionlawblog.org

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