[EL] ELB News and Commentary 10/8/14

Rick Hasen rhasen at law.uci.edu
Wed Oct 8 08:09:14 PDT 2014


    "NC says it's making plans to comply with voter law"
    <http://electionlawblog.org/?p=66504>

Posted onOctober 8, 2014 8:06 am 
<http://electionlawblog.org/?p=66504>byRick Hasen 
<http://electionlawblog.org/?author=3>

WRAL 
<http://www.wral.com/judge-wants-nc-to-discuss-voting-changes/14051854/>:

    North Carolina is moving ahead with plans to comply with an appeals
    court ruling that restores same-day registration and counting
    out-of-precinct ballots for the fall election, a state attorney told
    a federal judge Tuesday.

    But members of civil rights groups that sued to restore the
    activities told U.S. District Court Judge Thomas Schroeder the State
    Board of Elections has to do a better job of letting voters know
    they will be happening.

In the meantime, we arewaiting to see 
<http://electionlawblog.org/?p=66469>if the Supreme Court undoes the 4th 
Circuit's order.

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Posted inelection administration 
<http://electionlawblog.org/?cat=18>,Supreme Court 
<http://electionlawblog.org/?cat=29>,The Voting Wars 
<http://electionlawblog.org/?cat=60>,voter id 
<http://electionlawblog.org/?cat=9>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    "10th Circuit Fuzzy on Colorado Election Law"
    <http://electionlawblog.org/?p=66502>

Posted onOctober 8, 2014 8:01 am 
<http://electionlawblog.org/?p=66502>byRick Hasen 
<http://electionlawblog.org/?author=3>

Report from oral argument 
<http://www.courthousenews.com/2014/10/08/72234.htm>in Citizens United 
disclosure case in CO.

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


    6th Circuit Denies Preliminary Injunction in Judicial Campaign
    Solicitation Case <http://electionlawblog.org/?p=66500>

Posted onOctober 8, 2014 7:56 am 
<http://electionlawblog.org/?p=66500>byRick Hasen 
<http://electionlawblog.org/?author=3>

You can read the opinionhere, 
<http://www.ca6.uscourts.gov/opinions.pdf/14a0252p-06.pdf>which says 
very little on the merits of the constitutional claim.

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Posted incampaign finance <http://electionlawblog.org/?cat=10>,campaigns 
<http://electionlawblog.org/?cat=59>,judicial elections 
<http://electionlawblog.org/?cat=19>


    Local CA Republican Parties Agree to Pay Fines for Acting as
    Conduits for Contributions <http://electionlawblog.org/?p=66498>

Posted onOctober 8, 2014 7:48 am 
<http://electionlawblog.org/?p=66498>byRick Hasen 
<http://electionlawblog.org/?author=3>

Bloomberg BNA 
<http://news.bna.com/mpdm/MPDMWB/split_display.adp?fedfid=57309061&vname=mpebulallissues&jd=a0f7c6h9m7&split=0>: 
"Three local Republican campaign committees in California and an 
apartment management company have agreed to pay a total of $65,000 in 
fines for bundling payments to candidates or failing to disclose the 
source of payments they made to state candidates as intermediaries, the 
California Fair Political Practices Commission said Oct. 6."

I was involved in litigation (and then legislation) in the City of San 
Diego aimed at stopping political parties from acting as conduits to 
allow individuals to evade individual contribution limits.

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Posted incampaign finance <http://electionlawblog.org/?cat=10>,political 
parties <http://electionlawblog.org/?cat=25>


    "Republican Challenge to Soft-Money Ban Certified for Consideration
    by D.C. Circuit" <http://electionlawblog.org/?p=66496>

Posted onOctober 8, 2014 7:45 am 
<http://electionlawblog.org/?p=66496>byRick Hasen 
<http://electionlawblog.org/?author=3>

Bloomberg BNA 
<http://news.bna.com/mpdm/MPDMWB/split_display.adp?fedfid=57309063&vname=mpebulallissues&jd=a0f7c6k3b5&split=0>:

    A Republican Party challenge to the ban on unlimited "soft money"
    contributions to political parties is now before a federal appeals
    court in Washington, following action by a lower court to certify
    constitutional questions to be addressed by the appeals court
    (Republican National Committee v. Federal Election Commission
    <http://www.bloomberglaw.com/public/document/Republican_National_Committee_et_al_v_FEC_Docket_No_1405241_DC_Ci>,
    D.C. Cir., 14-5241, certified questions submitted 10/6/14).
    The U.S. Court of Appeals for the District of Columbia Circuit on
    Oct. 6 docketed a 28-page certification order presenting questions
    the court must answer in the soft-money case. Under special rules
    for certain campaign finance cases, the case is set to be heard by
    the en banc panel of all active D.C. Circuit judges. No schedule for
    action by the appeals court has been released....

    The certified questions were advanced to the D.C. Circuit by Judge
    Christopher R. Cooper of the U.S. District Court for the District of
    Columbia. Before approving the certified question order, the judge
    in August denied a bid by the RNC and other plaintiffs to have their
    case decided by a special three-judge panel under a separate
    procedure for handling campaign finance cases, which could have
    spurred prompter consideration of the soft-money ban by the Supreme
    Court.
    Soon after the RNC's case was filed this summer, lawyers for the
    party committees and the FEC argued in court about whether the
    lawsuit challenging the soft-money ban should be heard under the
    fast-track procedures, including convening a three-judge court (3810
    Money & Politics Report, 7/25/14
    <http://news.bna.com/mpdm/display/link_res.adp?fedfid=57309063&fname=a0f3u4w2g7&vname=mpebulallissues>).
    If the case was heard by a three-judge court, that court's ruling
    could immediately be appealed to the Supreme Court without being
    considered by the D.C. Circuit.

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


    More on CPA-Zicklin Index <http://electionlawblog.org/?p=66494>

Posted onOctober 8, 2014 7:34 am 
<http://electionlawblog.org/?p=66494>byRick Hasen 
<http://electionlawblog.org/?author=3>

Motley Fool 
<http://www.fool.com/investing/general/2014/10/04/theres-a-powerful-case-for-better-corporate-politi.aspx>

Harvard Law School Forum on Corporate Governance and Financial 
Regulation 
<http://blogs.law.harvard.edu/corpgov/2014/10/07/2014-cpa-zicklin-index-of-corporate-political-disclosure/>

Corporate Counsel 
<http://www.corpcounsel.com/top-stories/id=1202672476227/More-Corporate-Political-Spending-More-Disclosure-Too?slreturn=20140907064213>

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


    "Movement at the Federal Election Commission"
    <http://electionlawblog.org/?p=66492>

Posted onOctober 8, 2014 7:27 am 
<http://electionlawblog.org/?p=66492>byRick Hasen 
<http://electionlawblog.org/?author=3>

Bob Bauer blogs. 
<http://www.moresoftmoneyhardlaw.com/2014/10/movement-federal-election-commission/>

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Posted incampaign finance <http://electionlawblog.org/?cat=10>,federal 
election commission <http://electionlawblog.org/?cat=24>


    "In Independence Institute, a Pro-Disclosure Decision---But With No
    Disclosure to Follow" <http://electionlawblog.org/?p=66490>

Posted onOctober 8, 2014 7:26 am 
<http://electionlawblog.org/?p=66490>byRick Hasen 
<http://electionlawblog.org/?author=3>

Brian Svoboda blogs 
<http://www.lawandpoliticsupdate.com/2014/10/in-independence-institute-a-pro-disclosure-decision-but-with-no-disclosure-to-follow/>.

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


    "New pro-Ernst super PAC run out of firm of Joni Ernst strategist"
    <http://electionlawblog.org/?p=66488>

Posted onOctober 8, 2014 7:25 am 
<http://electionlawblog.org/?p=66488>byRick Hasen 
<http://electionlawblog.org/?author=3>

Matea 
Gold<http://www.washingtonpost.com/blogs/post-politics/wp/2014/10/07/new-pro-ernst-super-pac-run-out-of-firm-of-joni-ernst-strategist/>for 
WaPo:

    A new super PAC launching a $1 million TV campaign against
    Democratic Senate hopeful Bruce Braley in Iowa this week is run out
    of the Des Moines consulting firm of a strategist for Braley's GOP
    opponent --- the latest example of how campaigns and their outside
    allies are operating in close proximity
    <http://www.washingtonpost.com/politics/scott-walker-case-shows-growing-closeness-between-politicians-and-wealthy-allies/2014/06/23/e8b9304e-f955-11e3-a606-946fd632f9f1_story.html>.

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


    "Court declares Virginia's congressional map unconstitutional"
    <http://electionlawblog.org/?p=66486>

Posted onOctober 7, 2014 7:53 pm 
<http://electionlawblog.org/?p=66486>byRick Hasen 
<http://electionlawblog.org/?author=3>

WaPo reports. 
<http://www.washingtonpost.com/local/virginia-politics/court-throws-out-virginia-congressional-map/2014/10/07/97fb866a-4e56-11e4-8c24-487e92bc997b_story.html?hpid=z1>

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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>


    NC Files Follow Up #SCOTUS Letter on Today's Voting Hearing in
    District Court <http://electionlawblog.org/?p=66483>

Posted onOctober 7, 2014 5:03 pm 
<http://electionlawblog.org/?p=66483>byRick Hasen 
<http://electionlawblog.org/?author=3>

Following up onthis pos <http://electionlawblog.org/?p=66469>t, North 
Carolina has filedthis letter 
<http://electionlawblog.org/wp-content/uploads/10-7ResponseLtr.pdf>with 
the Supreme Court. As anticipated, it has a much different take on what 
happened today in the trial court over the question of how onerous it 
would be to implement the 4th Circuit's order.

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Posted inelection administration 
<http://electionlawblog.org/?cat=18>,Supreme Court 
<http://electionlawblog.org/?cat=29>,The Voting Wars 
<http://electionlawblog.org/?cat=60>,voter id 
<http://electionlawblog.org/?cat=9>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    The Virginia redistricting decision
    <http://electionlawblog.org/?p=66481>

Posted onOctober 7, 2014 3:59 pm 
<http://electionlawblog.org/?p=66481>byJustin Levitt 
<http://electionlawblog.org/?author=4>

Rickmentioned <http://electionlawblog.org/?p=66456>the 
Virginiacongressional redistricting decision 
<http://thinkprogress.org/wp-content/uploads/2014/10/Virginia-Gerrymandering.pdf> earlier 
today.

I've already seen some confusion about this: the decision doesn't depend 
on /Shelby County/.  Indeed, as I read it, the decision would have been 
exactly the the same if /Shelby County/came out differently --- or 
hadn't been decided at all.

Instead, what the court found is that Virginia's deployment of race in 
the redistricting process was hamhanded rather than nuanced, and 
therefore unconstitutional.  That is, in purportedly attempting to 
comply with section 5, Virginia focused on a demographic target alone, 
without any attention to the actual "effective exercise of the electoral 
franchise" on the ground.  That kind of shorthand doesn't fly, not least 
because it shows exactly the sort of essentialism section 5 was designed 
to combat.

Unfortunately, Virginia's mistake is all too common this cycle.  As Rick 
says, this issue is also involved in theAlabama case now up before the 
Supreme Court <http://redistricting.lls.edu/cases.php#AL>.  But it's not 
just Alabama.  Versions of this same problem have cropped up in 
California, Florida, North Carolina, South Carolina, and Texas --- at least.

I've reviewed each of these cases, and the governing law --- arriving at 
essentially the same conclusion as the court in Virginia --- inthis new 
law review piece <http://ssrn.com/abstract=2487426>.  The majority cited 
no secondary source; perhaps because mine is the first I'm aware of that 
connects the dots on the overly blunt misinterpretation of the Voting 
Rights Act.  (Law Review 2Ls: it's still available!  Act now, while 
supplies last!)

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Posted inelection law and constitutional law 
<http://electionlawblog.org/?cat=55>,redistricting 
<http://electionlawblog.org/?cat=6>,Supreme Court 
<http://electionlawblog.org/?cat=29>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    The 7th Circuit denominator <http://electionlawblog.org/?p=66472>

Posted onOctober 7, 2014 3:42 pm 
<http://electionlawblog.org/?p=66472>byJustin Levitt 
<http://electionlawblog.org/?author=4>

No time like the present to start "easing in," I guess.

Others have already said quite a bit about yesterday's7th Circuit voter 
ID decision 
<http://media.ca7.uscourts.gov/cgi-bin/rssExec.pl?Submit=Display&Path=Y2014/D10-06/C:14-2058:J:Easterbrook:aut:T:fnOp:N:1429868:S:0>. 
  I've writtenmany 
<http://summaryjudgments.lls.edu/2012/10/company-at-30000-feet-plane-travel-and_2161.html>times 
<http://ssrn.com/abstract=2017228>about the ID-on-a-plane fallacy (it's 
both irrelevant and wrong), aboutusing 
<http://ssrn.com/abstract=2017228>turnout 
<http://department-lists.uci.edu/pipermail/law-election/2013-July/007405.html>to 
gauge a regulation's impact (if it's the right measure, then it's 
constitutional to disenfranchise anyone who didn't vote in a 
high-turnout year like 2008), and about theright 
<http://ssrn.com/abstract=2017228>way 
<http://www.acslaw.org/acsblog/node/12360>to interpret Crawford (it did 
not hold that Indiana's statute is "compatible with the Constitution" 
(an advisory decision that would violate the rights of all absent 
parties); it held that the evidence presented by the plaintiffs in the 
case was insufficient to show that the statute is unconstitutional, 
which is a significant difference).

I just want to add one more piece at the moment.  Judge Easterbrook said 
that the Wisconsin suit, "like /Crawford/, is a challenge to Act 23 as 
written ('on its face'), rather than to its effects ('as applied')."

No, it's not.

Let's see if the text of theactual complaint 
<http://moritzlaw.osu.edu/electionlaw/litigation/documents/firstamendedcomplaint_001.pdf>can 
clear this up: "This lawsuit seeks a declaratory judgment that the photo 
ID law is unconstitutional as applied to certain classes of eligible 
Wisconsin voters and to enjoin its enforcement with respect to these 
classes."  To be fair, the district court declined to rule on the 
certification of classes, and enjoined the implementation of the statute 
across the board.  Perhaps that confused the 7th Circuit.  But what the 
plaintiffs actually requested is a remedy tailored to the particular 
burdens theydemonstrated.  By refusing to confront the suit the 
plaintiffs actually pled, the 7th Circuit expanded the denominator for 
cognizable injury.  That is, by ignoring the true nature of the 
challenge and expanding the case to encompass all the voters in the 
state, it could make inference upon inference (or, if you prefer, 
speculation) upon what most Wisconsinites (absent from the case) could 
probably do, and ignore the actual evidence presented by the actual 
people seeking to represent similarly situated others.

(Disclosure: I contributed a bit to discussions about the complaint in 
the Wisconsin case.  I did not draft it, and did not participate in the 
litigation thereafter.)

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Posted inThe Voting Wars <http://electionlawblog.org/?cat=60>,voter id 
<http://electionlawblog.org/?cat=9>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    Justin Levitt Guest Blogging Wed Night through Oct. 18
    <http://electionlawblog.org/?p=66477>

Posted onOctober 7, 2014 3:35 pm 
<http://electionlawblog.org/?p=66477>byRick Hasen 
<http://electionlawblog.org/?author=3>

I will be on the road (which will includethese talks 
<http://electionlawblog.org/?p=66243>) beginning the close of business 
Wednesday through October 18. I will still be chiming in with commentary 
on SCOTUS election developments as I can, but follow Justin for all the 
breaking news.

If you have a tip, press release or most of all a complaint about 
something I've written, pleasesend it to Justin 
<http://www.lls.edu/aboutus/facultyadministration/faculty/facultylistl-r/levittjustin/>. 
Ortweet at him <https://twitter.com/_justinlevitt_>. Just don't clog my 
inbox when I'm on the road. I hate that.

I would feel uneasy about leaving the blog in the midst of the election 
craziness, but trust me that you are in very, very good hands.

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


    Ninth Circuit Taking Initiative Proponent Disclosure Case En Banc
    <http://electionlawblog.org/?p=66473>

Posted onOctober 7, 2014 3:29 pm 
<http://electionlawblog.org/?p=66473>byRick Hasen 
<http://electionlawblog.org/?author=3>

The order is here 
<http://electionlawblog.org/wp-content/uploads/chula-order.pdf>.

Here ismy post<http://electionlawblog.org/?p=62398>on the panel's 
original decision, a decision which is wiped out by today's grant of an 
en banc hearing:

*            Breaking: Divided 9th Circuit Strikes Down CA Law Requiring 
Identity of Ballot Measure Proponents on Face of Petition*

    Posted on June 16, 2014 9:44 am
    <http://electionlawblog.org/?p=62398> by Rick Hasen
    <http://electionlawblog.org/?author=3>

    The vote on this point in Chula Vista Citizens for Jobs v. Norris
    <http://electionlawblog.org/wp-content/uploads/Chula-Vista-opinion.pdf> was
    2-1.  I expect this issue will go en banc and perhaps to the Supreme
    Court---with a decent chance of reversal.

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    This entry was posted in direct democracy
    <http://electionlawblog.org/?cat=62>, petition signature gathering
    <http://electionlawblog.org/?cat=39> by

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Posted incampaigns <http://electionlawblog.org/?cat=59>,direct democracy 
<http://electionlawblog.org/?cat=62>


    No North Carolina Ruling from #SCOTUS Yet: What Does It Mean?
    <http://electionlawblog.org/?p=66469>

Posted onOctober 7, 2014 3:05 pm 
<http://electionlawblog.org/?p=66469>byRick Hasen 
<http://electionlawblog.org/?author=3>

It is the end of the work day on the East Coast, and the day has come 
and gone with no order from the Supreme Court on North Carolina's 
request to stop the 4th Circuit's order requiring the restoration of 
same day voter registration and the counting of out-of-precinct ballots 
which the state of NC legislature had cut in a controversial election 
bill passed by the Republican-dominated legislature.

I had expected a ruling by now, primarily because Chief Justice Roberts 
put the case on the extremely fast track for decision--requiring the 
challengers to the North Carolina law to file a response to North 
Carolina's motion by Sunday at 5 pm.  In contrast, Justice Kagan in the 
Wisconsin voter id case, gave the state of Wisconsin until Tuesday to 
file their response.

So why the delay?

There is no way to know from the outside, but here are some 
possibilities, beginning with the most likely.

1. Someone is dissenting, or at least writing something to explain the 
decision.  In the Ohio case, issued last week, the vote was 5-4 but 
there was no explanation from either the (conservative) majority or the 
(liberal) dissenters. Someone may want to say something here, either 
objecting to or explaining what the Court is doing.

2. The Court decided it wants more information and decided to wait. 
Today the trial court held a status hearing in the case and, according 
toa just-filed 
letter<http://electionlawblog.org/wp-content/uploads/14A358-10-7-Letter-from-Respondents.pdf>from 
NC challengers, the state said it would be easy to implement the 4th 
Circuit's order. The challengers promise a transcript and no doubt NC 
will object to this characterization.

3. The Court wants to decide the North Carolina and Wisconsin case 
together, or perhaps a dissenter wants to reference a potential 
inconsistent treatment of the Purcell delay issue in the two cases. That 
would mean waiting until the further briefing came in in the Wisconsin case.

We may have a better sense of which, if any, of this speculation is 
correct when the order arrives. If it comes after 5 pm Eastern tomorrow, 
however, I'll be leaving for a flight and the great Justin Levitt, who 
will be guest blogging, will provide you with all the details.  (What, 
you don't yet follow him on Twitter? Wellfix that right now 
<https://twitter.com/_justinlevitt_>!)

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Posted inelection administration 
<http://electionlawblog.org/?cat=18>,Supreme Court 
<http://electionlawblog.org/?cat=29>,The Voting Wars 
<http://electionlawblog.org/?cat=60>,voter id 
<http://electionlawblog.org/?cat=9>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    The Ed Blum Law Firm <http://electionlawblog.org/?p=66467>

Posted onOctober 7, 2014 2:02 pm 
<http://electionlawblog.org/?p=66467>byRick Hasen 
<http://electionlawblog.org/?author=3>

Tony Mauro 
<http://www.nationallawjournal.com/supremecourtbrief/id=1202672649620/ExWiley-Rein-Lawyers-Form-Appellate-Boutique?cmp=share_twitter&slreturn=20140907165623>:

    Two Wiley Rein partners from the Washington office have left the
    firm---and they are taking a Supreme Court legal clinic and parts of
    some high-profile litigation with them.

    William Consovoy and Thomas McCarthy last week launched the firm
    Consovoy McCarthy <http://consovoymccarthy.com/>. Among its clients,
    Consovoy said Monday, will be Edward Blum of the Project on Fair
    Representation, who has masterminded and funded legal challenges
    against affirmative action policies in higher education.

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


    Read Wisconsin's #SCOTUS Argument to Use Its New Voter ID Law This
    Election <http://electionlawblog.org/?p=66460>

Posted onOctober 7, 2014 12:58 pm 
<http://electionlawblog.org/?p=66460>byRick Hasen 
<http://electionlawblog.org/?author=3>

Here 
<http://images.politico.com/global/2014/10/07/14a352_response.pdf> (via 
Josh Gerstein). The brief is pretty much in line with what Wisconsin 
filed in the 7th Circuit (although of course now it has the benefit of 
theEasterbrook opinion <http://electionlawblog.org/?p=66413>on the 
merits). It continues to lead with itschutzpah-filled 
argument<http://electionlawblog.org/?p=65804>that it would cause voter 
confusion to undo the confusion caused by the 7th Circuit's surprise order.

It is funny watching Wisconsin try to argue there's no conflict over the 
meaning of section 2 of the Voting Rights Act given the 4th Circuit 
North Carolina case also pending this very moment before the Court 
reaching a totally different view of the meaning of section 2.

The one new point which I think does point in Wisconsin's favor is the 
timing of the objections to the order. Opponents of WI voter id law 
waited days before going to the 7th Circuit en banc (when they could 
have gone straight to SCOTUS) and days more before bringing the case to 
SCOTUS.

I still think given the Purcell issue the challengers arefairly likely 
<http://electionlawblog.org/?p=66198>to get a stay in this case, but I'm 
not at all certain of that.

Stay tuned.

[This post has been updated.]

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Posted inelection administration 
<http://electionlawblog.org/?cat=18>,Supreme Court 
<http://electionlawblog.org/?cat=29>,The Voting Wars 
<http://electionlawblog.org/?cat=60>,voter id 
<http://electionlawblog.org/?cat=9>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    Only 128 New Voters, Not Over 3,200, Registered in Ferguson, MO
    <http://electionlawblog.org/?p=66458>

Posted onOctober 7, 2014 12:46 pm 
<http://electionlawblog.org/?p=66458>byRick Hasen 
<http://electionlawblog.org/?author=3>

Can't wait 
<http://talkingpointsmemo.com/dc/ferguson-missouri-voter-registration-drive-didnt-happen>to 
hear how the elections board made this error.

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Posted invoter registration <http://electionlawblog.org/?cat=37>


    Breaking: Federal Court Strikes Va. Congressional Redistricting Map
    <http://electionlawblog.org/?p=66456>

Posted onOctober 7, 2014 12:24 pm 
<http://electionlawblog.org/?p=66456>byRick Hasen 
<http://electionlawblog.org/?author=3>

In a 2-1 vote, a three judge federal courthas 
rejected<http://thinkprogress.org/wp-content/uploads/2014/10/Virginia-Gerrymandering.pdf>part 
of Virginia's congressional redistricting as unconstitutional. The 
majority ruled that the redistricting involving a majority-minority 
district violated the equal protection clause as an unconstitutional 
racial gerrymander (a /Shaw v. Reno/type claim) because race was the 
predominant factor in redistricting. The state had defended its packing 
of minority voters into fewer districts to comply with Section 5 of the 
Voting Rights Act but the majority did not buy it. From the majority 
opinion:

    For the reasons that follow, we find that Plaintiffs have shown race
    predominated. We find that the Third Congressional District cannot
    survive review under the exacting standard of strict scrutiny. While
    compliance with Section 5 was a compelling interest when the
    legislature acted, the redistricting plan was not narrowly tailored
    to further that interest. Accordingly, we are compelled to hold that
    the challenged Third Congressional District violates the
    Equal Protection Clause of the Fourteenth Amendment.

The dissenting judge believed that political considerations, not race, 
predominated in the redistricting.

What happens next? AsThink Progress notes 
<http://thinkprogress.org/justice/2014/10/07/3577120/breaking-federal-court-declares-virginias-congressional-maps-unconstitutional/>, 
any new redistricting will have to be signed by the new Democratic governor.

If Virginia does appeal to the Supreme Court, I expect the case will be 
held for theAlabama redistricting cases 
<http://www.scotusblog.com/case-files/cases/alabama-democratic-conference-v-alabama/?wpmp_switcher=desktop>, 
which raise virtually the same issue. (I will be covering this case for 
SCOTUSBlog.)

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

-- 
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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