[EL] dark money

JBoppjr at aol.com JBoppjr at aol.com
Fri Oct 10 10:19:33 PDT 2014


I am in Europe with little time so I had a modest goal in my post, to point 
 out what some are calling "hypocrisy" with the Dem's position on this  
issue.  See
 
 
_Click  here: Big donor secrecy: ‘Irony, but it’s not hypocrisy’ - Kenneth 
P. Vogel -  POLITICO.com_ 
(http://www.politico.com/story/2014/04/big-donor-secrecy-campaigns-fundraising-democrats-106186.html)  

 
But on the merits of this, neither the FEC nor the courts have agreed with  
Trevor that politician fundraising for SuperPACs and other independent  
groups means that their independent expenditures are inherently "coordinated"  
with candidates so as to be deemed a contribution to them.
 
Trevor is just trotting out the old "gratitude" form of "corruption," which 
 he and his group doesn't really believe in anyway.  The Campaign Legal  
Center gave millions of dollars of free legal services to Senator McCain, by  
representing him as an intervenor in McConnell v. FEC, as well  as to Rep 
Van Hollen and others in other cases.  I bet those  politicians have fallen 
all over themselves with gratitude to this "dark money"  group. And so as to 
spread this gratitude around, the CLC does reveal some  of their corporate 
donors, in order, I guess, for these politicians to also be  grateful to them 
as well.
 
But gratefulness is just an unlimited concept that would allow the  
"reformers" to get government to crack down on all political speech and  
involvement, including newspaper editorials, etc, etc.
 
Fortunately, this Court has rejected that approach.  Jim Bopp
 
 
In a message dated 10/10/2014 12:43:08 P.M. Eastern Daylight Time,  
tpotter at capdale.com writes:

 
So  the fact that both parties have supposedly independent SuperPacs and  
non-profits that hold meetings  with candidates, officeholders and “fat  cat 
donors” , thereby providing an opportunity for candidates to know who the  
funders are of even non-disclosing groups, and for candidates/officeholders 
to  express their gratitude, simply means that the problem is bipartisan. 
Glad Jim  has pointed that out.  
The  problem, of course, is that such close contact between “independent” 
spending  groups, their major donors, and the officeholders and candidates 
they support  provides many of the ingredients for corruption that the 
Supreme Court has  claimed would be absent from independent expenditure activities 
“wholly”  totally” completely” independent of parties and  candidates.. 
Trevor  Potter 
 
 
From:  law-election-bounces at department-lists.uci.edu  
[mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of  JBoppjr at aol.com
Sent: Friday, October 10, 2014 12:33  PM
To: sandler at sandlerreiff.com; holman at aol.com; Tom at tomcares.com;  
Law-election at department-lists.uci.edu
Subject: Re: [EL] dark  msoney

 
Wow, Joe.   Right from the DNC's latest talking points.   
 

 
So to add a little  bipartisan flavor on this, see:
 

 
 
_Click here: As Democratic donors gather in Chicago,  GOP takes aim - 
Chicago Sun-Times_ 
(http://www.suntimes.com/news/sweet/27055776-452/as-democratic-donors-gather-in-chicago-gop-takes-aim.html#.VDgIx5t6D7c)  
 

 
Dem fat cats meeting  with Dem politicians to raise money for liberal "dark 
money"  groups.  
 

 
Joe, please give us a  break from hyper partisanship, at least on this list 
serve.  Jim  Bopp

 

 
 
In a message dated  10/9/2014 5:59:46 P.M. Eastern Daylight Time, 
_sandler at sandlerreiff.com_ (mailto:sandler at sandlerreiff.com)   writes:


 
Thomas-- 
The  June summit of donors held by the Koch Brothers is a good example-- it 
was  attended by  Republican  Members of Congress and candidates who  got 
to see first hand, literally in front of them, in person,  the  donors to the 
Koch Brothers dark money  c4/c6 organizations-- but the  summit was locked 
down with public and press kept out (although a tape of  some of the 
proceedings was leaked to one journalist 
http://www.thenation.com/article/181363/caught-tape-what-mitch-mcconnell-complained-about-roomful-billionaires-exclusiv
e  ) 
. 
So  these candidates absolutely know the source of the dark money 
benefiting  them but the public does not.  (Even the leaked proceedings did not  
identify any of the donors who attended). That's the significant problem  with 
dark money for just the reason you set out.  
Joseph  E. Sandler 
Sandler  Reiff Lamb Rosenstein & Birkenstock PC 
1025  Vermont Ave NW  Suite 300 
Washington   DC 20005 
Tel:  202 479 1111 
CELL   202  607  0700 
Fax   202 479 1115 
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 Craig Holman
Sent: Thursday, October 09, 2014  5:37 PM
To: _Tom at tomcares.com_ (mailto:Tom at tomcares.com) ; 
_Law-election at department-lists.uci.edu_ (mailto:Law-election at department-lists.uci.edu) 
Subject:  Re: [EL] dark money 
Hi  Thomas:  
 

 
Selectively  and discreetly informing lawmakers of the political spending 
decisions of a  corporation, union or other organization is part and parcel 
of what us  lobbyists do.
 

 
Unfortunately,  as a lobbyist for Public Citizen, this type of leverage is 
not so readily  available to me.
 
 
Craig  Holman, Ph.D.
Government Affairs Lobbyist
Public Citizen
215  Pennsylvania Avenue SE
Washington, D.C. 20003
T-(202)  454-5182
C-(202) 905-7413
F-(202) 547-7392
_Holman at aol.com_ (mailto:Holman at aol.com) 
 
-----Original  Message-----
From: Thomas J. Cares <_Tom at tomcares.com_ (mailto:Tom at tomcares.com) >
To: Election  Law <_Law-election at department-lists.uci.edu_ 
(mailto:Law-election at department-lists.uci.edu) >
Sent:  Thu, Oct 9, 2014 5:21 pm
Subject: Re: [EL] dark  money 
 
Probably  not the type of thing one could collect empirical data on, but - 
if anyone  thinks they have general insight - do you figure candidates are 
generally  cognizant of the original source of dark money?  
 

 
The  biggest harm with dark money would seem to be that the public can't 
discover  conflicts of interest.
 

 
I'm  familiar with an instance where a legislator wouldn't support 
something that  was fairly popular with the overwhelming majority of those effected 
as well  as electeds in the effected city, because he feared it could have a 
 slight adverse effect on the value of real estate he  owns.
 

 
At  least I know that reason. At least the mayor of that city knows the 
reason.  We're not scratching our heads as to why he wouldn't support it, and 
we can  judge him for making that decision on that basis, and that's  
appropriate.
 

 
But  what if the reason was that a corporation who supported his election 
with  $100k in dark money might have their property value adversely effected, 
and  he knew that and wanted similar repeated support from that source for  
reelection... But the public never knows it and is left to assume he had a  
better-faith reason.
 

 
In  the absence of laws mandating disclosure, might the next best thing be 
a  buildup of public intolerance for electeds who probably know the source  
of dark money, but won't reveal it and therein make conflicts of  interest 
undetectable?
 

 
(But  yes, for this reason, it seems a great shame that disclosure is not  
more-thoroughly mandated by statute. If it averages 3%, that's not very  
comforting - that's $60k out of every $2m, plenty to create a signficantly  
harmful recurrence of unknown conflicts of interest throughout a legislative  
body).
 

 
-Thomas  Cares

On Thursday, October 9, 2014, Justin Levitt <_levittj at lls.edu_ 
(mailto:levittj at lls.edu) >  wrote: 
 
 
I'll  see your "whoa" and raise you an "easy, easy."

I've made the same  comment with respect to the estimates of pro-"reform" 
groups too.  The  underlying piece I linked to is _here_ 
(http://summaryjudgments.lls.edu/2014/05/the-drunkards-search-for-money-in.html) .  In it,  I 
explain the sort of money that's not included in either of these  calculations 
(from pro-reform groups or the CCP), as far as I can  tell.  "If an entity 
does not have the election or defeat of candidates  as its primary purpose, 
spending that is neither expressing advocacy nor on  the air as an election 
approaches is entirely outside of the current  electoral disclosure regime. 
. . . Labor spends millions on pre-election  canvassers to discuss candidates
’ records on union pensions? A pro-choice  group spends millions on 
pre-election mailers touting candidates’ support  for abortion? A conglomerate puts 
up a TV ad 31 days before the primary  railing against a candidate’s sexual 
peccadilloes? For the FEC, this is  terra incognita. Here be dragons."

Immediately after that, I say "To  be clear, I am not advocating for full 
disclosure of all of this activity. I  am, however, advocating for more 
frequent acknowledgment of these known  unknowns, particularly in empirical 
analysis of the changes that changes in  the legal regime have wrought."  Because 
I thought that point might get  lost in the morning's post, I said it 
again: "That’s not itself an  argument for disclosing all the rest."   I'm not 
sure how you  can draw from that that I've "called for a more massive 
expansion of the  compulsory disclosure regime."  I'm just pointing out the limits 
of the  numbers we have. -- for those who are quoting the size of spending 
without  disclosure, both from the reform community and not.

Finally, I agree  with you that I'm not sure (as in, we just don't know) 
about the size of the  change ... my comment wasn't linked to any notion that 
the number had  changed.  One of the things I've been pointing out is that 
the "growth"  of spending may be a result of the fact that definitions have 
changed.   Again, from the underlying piece: "Legal requirements for 
reporting data  with respect to [electioneering communications] only arose in 2002. 
When you  see a jump in the amount of electioneering communications in 2004, 
that does  not indicate a sudden appearance of brand-new 
Levitt-hates-puppies ads. It  meant that, for the first time, such ads fell under the 
streetlight. How  much spending was there on ads in 1998 or 2000 or 2002 that would 
now meet  the definition of 'electioneering communications'? FEC data leave 
no  idea."

So please understand, my comment was meant to say only what it  actually 
said: that we really don't know that over 95% of campaign spending  is funded 
by groups that publicly disclose their donor information.   That's different 
from saying that we should know about some or all of the  rest, or that the 
number has gotten relatively bigger over time.   

-- 
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_ (mailto:justin.levitt at lls.edu) 
_ssrn.com/author=698321_ (http://ssrn.com/author=698321) 
On  10/9/2014 4:55 AM, Smith, Brad wrote:

Justin writes:
"CCP in The 
Hill_<http://thehill.com/blogs/congress-blog/politics/219926-dark-money-still-a-bit-player>_ 
(http://thehill.com/blogs/congress-blog/politics/219926-dark-money-still-a-bit-player) : What would you call an election 
in which over 95 percent of campaign spending is funded by groups that 
publicly disclose the names and addresses of their donors to the Federal Election 
Commission, along with information on donors’ employers and occupations?
 
"Though the point is valid, this op-ed assumes that spending disclosed to 
the FEC is the relevant denominator, and focuses on the portion with (some) 
donors disclosed.  But remember, some campaign spending is not disclosed to 
the FEC at 
all_<http://summaryjudgments.lls.edu/2014/05/the-drunkards-search-for-money-in.html>_ 
(http://summaryjudgments.lls.edu/2014/05/the-drunkards-search-for-money-in.html) , and we have no idea whether that number is large 
or small.  That’s not itself an argument for disclosing all the rest.  But it
’s important to keep in mind the spending nobody knows about before 
trumpeting transparency based on what’s visible under the streetlight."
 
Whoa. Beep beep beep. Back up. We calculate these numbers by taking the 
estimates of good pro-"reform" groups railing against "dark money," such as the 
Center for Responsive Politics, as to the total amount of "dark money." 
Then we divide by spending reported by the FEC.
 
To the extent that more money is spent that is not reported to the FEC, 
that increases the denominator by one dollar for every such dollar spent. But 
what money aren't the reform groups including in the numerator? Some of this 
would appear to be money that is not reported to the FEC. If that is correct 
(these organizations are quite thin about how they calculate the number, 
witness James Bopp's recent exchange with the Wesleyan Project), then the 
percentage of "dark money" is actually lower, not higher.
 
To the extent that "dark money" is not included in either the numerator or 
the denominator, we don't know the ultimate change in its percentage of 
political spending. But wait a minute - what spending is included as dark money 
that is not reported to the FEC? It would have to be information that was 
never reported to the FEC - that is, issue advocacy, but not including 
electioneering communications. Is there any reason to believe that issue advocacy 
that is not an electioneering communication is on the rise? No. In fact, it 
is almost certainly in decline since organizations once restricted to issue 
advocacy can now make independent expenditures and electioneering 
communications. So if we want to include issue advocacy (and where, exactly, is the 
line on what we would then call "dark money" - spending on research reports 
(like Elizabeth Warren wants reported, at least if it doesn't support her ideas 
of good public policy)? spending on TV documentaries like "The Roosevelts?" 
S!
 pending 
on TV commercial programming like the upcoming Tea Leoni series about a 
gutsy, heroic, (entirely fictional, no resemblance to any person living or dead 
is intended) Secretary of State?  Voter registration drives by c3 
organizations such as Public Citizen? 
 
To the extent Justin would include any of these things in "dark money," he 
has just expanded the term beyond any prior definition I've heard of "dark 
money," and called for a more massive expansion of the compulsory disclosure 
regime than anything I've seen before. 
 
In short, we use the definition used by the groups that are acting most 
alarmed about so-called "dark money" as our numerator. Our denominator is, if 
anything, too small, to the extent that some of what these groups call "dark 
money" is not reported to the FEC.
 
Dark money? The hokum scare of our modern elections, and perhaps the single 
biggest obstacle to serious discussion of disclosure reform.
 
Bradley A. Smith
 
Josiah H. Blackmore II/Shirley M. Nault
 
   Professor of Law
 
Capital University Law School
 
303 E. Broad St.
 
Columbus, OH 43215
 
614.236.6317
 
http://law.capital.edu/faculty/bios/bsmith.aspx
 
________________________________________
From: _law-election-bounces at department-lists.uci.edu_ 
(mailto:law-election-bounces at department-lists.uci.edu)  
[law-election-bounces at department-lists.uci.edu] on behalf of Justin Levitt [levittj at lls.edu]
Sent: Thursday, October 09, 2014 6:01 AM
To: _law-election at UCI.EDU_ (mailto:law-election at UCI.EDU) 
Subject: [EL]  ELB News and Commentary 10/9/14
 
Theory to Practice: The Democracy Facts Label Goes 
Live_<http://electionlawblog.org/?p=66562>_ (http://electionlawblog.org/?p=66562) 
Posted on October 9, 2014 2:56 am_<http://electionlawblog.org/?p=66562>_ 
(http://electionlawblog.org/?p=66562)  by Justin 
Levitt_<http://electionlawblog.org/?author=4>_ (http://electionlawblog.org/?author=4) 
 
Yesterday, Rick linked_<http://electionlawblog.org/?p=66517>_ 
(http://electionlawblog.org/?p=66517)  to a press release from the San Francisco Ethics 
Commission, announcing the launch of a great new campaign finance 
dashboard_<http://www.sfethics.org/ethics/2014/09/about-the-2014-campaign-finance-dashbo
ards.html>_ 
(http://www.sfethics.org/ethics/2014/09/about-the-2014-campaign-finance-dashboards.html) .  The site has a few different tools to get 
campaign finance information, and more important, to visualize it in different 
ways so that the morass of data is more meaningful.  There are maps for 
contributions by 
location_<http://www.sfethics.org/ethics/2013/12/board-of-supervisors-district-2-dashboard-november-4-2014-election.html>_ 
(http://www.sfethics.org/ethics/2013/12/board-of-supervisors-district-2-dashboard-november-4-20
14-election.html) !
 , and c<
a class="moz-txt-link-rfc2396E" 
href="http://www.sfethics.org/ethics/2014/09/general-purpose-committee-activity.html"><http://www.sfethics.org/ethics/20
14/09/general-purpose-committee-activity.html>harts for sorting big PACs 
from small 
ones_<http://www.sfethics.org/ethics/2014/09/general-purpose-committee-activity.html>_ 
(http://www.sfethics.org/ethics/2014/09/general-purpose-committee-activity.html) ; there are graphs for 
lobbyist_<http://www.sfethics.org/ethics/2014/08/political-contributions-made-arranged-or-delivered-by-lo
bbyists-to-candidates-for-local-office-in-20.html>_ 
(http://www.sfethics.org/ethics/2014/08/political-contributions-made-arranged-or-delivered-by-lobbyi
sts-to-candidates-for-local-office-in-20.html)  
contributions_<http://www.sfethics.org/ethics/2014/08/political-contributions-made-arranged-or-delivered
-by-lobbyists-to-candidates-for-local-office-in-20.html>_ 
(http://www.sfethics.org/ethics/2014/08/political-contributions-made-arranged-or-delivered-by-
lobbyists-to!%20-candidates-for-local-office-in-20.html)  and infographics 
of major 
donors_<http://www.sfethics.org/ethics/2014/09/major-donors-2014.html>_ (http://www.sfethics.org/ethics/2014/09/major-donors-2014.html) .
 
[cid:part12.01070100.05000607 at lls.edu]_<http://electionlawblog.org/archives/
DemocracyFacts.jpg>_ 
(http://electionlawblog.org/archives/DemocracyFacts.jpg) But the piece I’m most proud of is the 
interface_<http://www.sfethics.org/ethics/democracyfacts.html>_ 
(http://www.sfethics.org/ethics/democracyfacts.html)  for quickly communicating information about the funding profile and 
major funders of ballot measures.  It’s modeled after my proposal for a “
Democracy Facts” label, described in this 
paper_<http://ssrn.com/abstract=1676108>_ (http://ssrn.com/abstract=1676108)  and highlighted in this blog 
post_<http://electionlawblog.org/archives/017415.html>_ 
(http://electionlawblog.org/archives/017415.html)  almost exactly 4 yea!
 rs ago. 
 The idea is to borrow the familiar design of the Nutrition Facts labels, 
focusing on the few most important campaign funding facts real people 
actually might want to know, in readily digestible and comparable fashion.
 
The individual pieces of information on the label can be tailored to local 
needs and desires; there are lots of potential variations.  The San 
Francisco Ethics Commission chose the info that suited them best.
 
And the technical wizards on the implementation team improved on the idea 
in many different ways.  Among the upgrades: given the web interface, each 
individual major donor is clickable, and linked to a Google search providing a 
bit more context about the person or entity involved.  Community feedback, 
I understand, has thus far been profoundly positive.
 
Last year, Heather Gerken_<http://www.law.yale.edu/faculty/HGerken.htm>_ 
(http://www.law.yale.edu/faculty/HGerken.htm)  had the opportunity to see her 
Democracy Index_<http://www.law.yale.edu/faculty/democracyindex.htm>_ 
(http://www.law.yale.edu/faculty/democracyindex.htm)  come to life, when Pew 
released its Elections Performance 
Index_<http://www.pewstates.org/research/reports/elections-performance-index-85899445029>_ 
(http://www.pewstates.org/research/reports/elections-performance-index-85899445029) .  She 
wrote_<http://electionlawblog.org/?p=47114>_ (http://electionlawblog.org/?p=47114)  about 
the experience of watching the real-life realization of her powerful policy 
proposal to render information about the electoral environment more accessible 
and relevant, and thereby more meaningful.
 
She was right.  It feels great.
 
[Share]_<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblo
g.org%2F%3Fp%3D66562&title=Theory%20to%20Practice%3A%20The%20Democracy%20Fac
ts%20Label%20Goes%20Live&description=>_ 
(https://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=66562&title=Theory%20to%20Practice:%20The
%20Democracy%20Facts%20Label%20Goes%20Live&description=) 
Posted in campaign finance_<http://electionlawblog.org/?cat=10>_ 
(http://electionlawblog.org/?cat=10) 
Edit_<http://electionlawblog.org/wp-admin/post.php?post=66562&action=edit>_ 
(http://electionlawblog.org/wp-admin/post.php?post=66562&action=edit) 
10/9 FEC Meeting: Citizens United, McCutcheon & 
More_<http://electionlawblog.org/?p=66559>_ (http://electionlawblog.org/?p=66559) 
Posted on October 9, 2014 2:49 am_<http://electionlawblog.org/?p=66559>_ 
(http://electionlawblog.org/?p=66559)  by Justin 
Levitt_<http://electionlawblog.org/?author=4>_ (http://electionlawblog.org/?author=4) 
 
Late Wednesday, the FEC posted several drafts of rules to be considered at 
a meeting Thursday.  One of the 
drafts_<http://www.fec.gov/agenda/2014/documents/mtgdoc_14-53-a.pdf>_ 
(http://www.fec.gov/agenda/2014/documents/mtgdoc_14-53-a.pdf)  implements the Supreme Court’s decision in Citizens United, 
removing prohibitions on labor and corporate spending on independent political 
activity; it would also allow corporations and labor organizations to 
contribute to others engaging in independent political activity, including 
SuperPACs and regular PACs with separate independent-expenditure accounts.
 
Another_<http://www.fec.gov/agenda/2014/documents/mtgdoc_14-51-a.pdf>_ 
(http://www.fec.gov/agenda/2014/documents/mtgdoc_14-51-a.pdf)  implements the 
Supreme Court’s decision in McCutcheon, removing the aggregate limits on 
contributing to candidates, party committees, and PACs.  Still 
another_<http://www.fec.gov/agenda/2014/documents/mtgdoc_14-52-a.pdf>_ 
(http://www.fec.gov/agenda/2014/documents/mtgdoc_14-52-a.pdf)  announces an upcoming rulemaking to 
consider further refinement in light of McCutcheon, including potential 
adjustments to existing earmarking, affiliation, and disclosure rules to help 
prevent circumvention of the existing base limits on contributions.
 
The FEC also released two draft advisory opinions.  The first is an AO 
requested by the DNC and RNC about whether they can fundraise separately for the 
2016 presidential nomination conventions, in addition to limits on 
donations to the party committees generally.  Here’s the “yes” 
option_<http://www.fec.gov/agenda/2014/documents/mtgdoc_14-50-b.pdf>_ 
(http://www.fec.gov/agenda/2014/documents/mtgdoc_14-50-b.pdf) ; here’s the “no” 
option_<http://www.fec.gov/agenda/2014/documents/mtgdoc_14-50-a.pdf>_ 
(http://www.fec.gov/agenda/2014/documents/mtgdoc_14-50-a.pdf) .
 
The second is an AO requested by the two dueling Randolph-Macon College 
professors looking to replace Eric Cantor, about whether the college can 
continue paying fringe benefits while the candidates are on leave.  For those 
convinced that the FEC is hopelessly divided based on rank partisanship for 
every possible issue (I’ve got doubts_<http://ssrn.com/abstract=2239491>_ 
(http://ssrn.com/abstract=2239491) ), I look forward to a 3-3 deadlock with the 3 
Republican nominees voting to allow the college to pay the Republican 
candidate, and a 3-3 deadlock with the 3 Democratic nominees voting to allow the 
same college to pay the Democratic candidate.
 
[Share]_<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblo
g.org%2F%3Fp%3D66559&title=10%2F9%20FEC%20Meeting%3A%20Citizens%20United%2C%
20McCutcheon%20%26%20More&description=>_ 
(https://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=66559&title=10/9%20FEC%20Meeting:%20Citi
zens%20United,%20McCutcheon%20&%20More&description=) 
Posted in campaign finance_<http://electionlawblog.org/?cat=10>_ 
(http://electionlawblog.org/?cat=10) , federal election 
commission_<http://electionlawblog.org/?cat=24>_ (http://electionlawblog.org/?cat=24) 
Edit_<http://electionlawblog.org/wp-admin/post.php?post=66559&action=edit>_ 
(http://electionlawblog.org/wp-admin/post.php?post=66559&action=edit) 
On Party Fundraising for 2016 
Conventions_<http://electionlawblog.org/?p=66554>_ (http://electionlawblog.org/?p=66554) 
Posted on October 9, 2014 2:48 am_<http://electionlawblog.org/?p=66554>_ 
(http://electionlawblog.org/?p=66554)  by Justin 
Levitt_<http://electionlawblog.org/?author=4>_ (http://electionlawblog.org/?author=4) 
 
About those AOs up later today:  the Campaign Legal Center and Democracy 21 
have_<http://www.campaignlegalcenter.org/index.php?option=com_content&view=a
rticle&id=2628:october-8-2014-watchdogs-urge-fec-to-reject-rnc-a-dnc-request
-to-open-soft-money-loophole-for-convention-funds&catid=63:legal-center-pres
s-releases&Itemid=61>_ 
(http://www.campaignlegalcenter.org/index.php?option=com_content&view=article&id=2628:october-8-2014-watchdogs-urge-fec-to-reject
-rnc-a-dnc-request-to-open-soft-money-loophole-for-convention-funds&catid=63
:legal-center-press-releases&Itemid=61)  
opinions_<http://www.campaignlegalcenter.org/images/CLC_D21_Comments_on_Draft_AO_2014_12.pdf>_ 
(http://www.campaignlegalcenter.org/images/CLC_D21_Comments_on_Draft_AO_2014_12.pdf) .
 
Bauer_<http://www.moresoftmoneyhardlaw.com/2014/10/facts-theories-campaign-f
inance-argument-convention-financing-matter-fec/>_ 
(http://www.moresoftmoneyhardlaw.com/2014/10/facts-theories-campaign-finance-argument-convention-fina
ncing-matter-fec/)  does too, highlighting that the conventions are about 
more than just the nominee.  As every bar in the host city can confirm.
 
[Share]_<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblo
g.org%2F%3Fp%3D66554&title=On%20Party%20Fundraising%20for%202016%20Conventio
ns&description=>_ 
(https://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=66554&title=On%20Party%20Fundraising%20for%202016%20Conventions
&description=) 
Posted in campaign finance_<http://electionlawblog.org/?cat=10>_ 
(http://electionlawblog.org/?cat=10) , federal election 
commission_<http://electionlawblog.org/?cat=24>_ (http://electionlawblog.org/?cat=24) 
Edit_<http://electionlawblog.org/wp-admin/post.php?post=66554&action=edit>_ 
(http://electionlawblog.org/wp-admin/post.php?post=66554&action=edit) 
“Rules for Provisional Ballots All Over the Map”
_<http://electionlawblog.org/?p=66552>_ (http://electionlawblog.org/?p=66552) 
Posted on October 9, 2014 2:46 am_<http://electionlawblog.org/?p=66552>_ 
(http://electionlawblog.org/?p=66552)  by Justin 
Levitt_<http://electionlawblog.org/?author=4>_ (http://electionlawblog.org/?author=4) 
 
Pam Fessler tries to make sense of the provisional ballot 
landscape_<http://www.npr.org/blogs/itsallpolitics/2014/10/09/354534487/rules-
for-provisional-ballots-all-over-the-map>_ 
(http://www.npr.org/blogs/itsallpolitics/2014/10/09/354534487/rules-for-provisional-ballots-all-over-the-map)  for NPR.
 
[Share]_<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblo
g.org%2F%3Fp%3D66552&title=%E2%80%9CRules%20for%20Provisional%20Ballots%20Al
l%20Over%20the%20Map%E2%80%9D&description=>_ 
(https://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=66552&title=“
Rules%20for%20Provisional%20Ballots%20All%20Over%20the%20Map”&description=) 
Posted in provisional ballots_<http://electionlawblog.org/?cat=67>_ 
(http://electionlawblog.org/?cat=67) 
Edit_<http://electionlawblog.org/wp-admin/post.php?post=66552&action=edit>_ 
(http://electionlawblog.org/wp-admin/post.php?post=66552&action=edit) 
Right Questions, Wrong Answers in Voter ID 
Decision_<http://electionlawblog.org/?p=66549>_ (http://electionlawblog.org/?p=66549) 
Posted on October 9, 2014 2:46 am_<http://electionlawblog.org/?p=66549>_ 
(http://electionlawblog.org/?p=66549)  by Justin 
Levitt_<http://electionlawblog.org/?author=4>_ (http://electionlawblog.org/?author=4) 
 
Prof. Chris Elmendorf_<https://law.ucdavis.edu/faculty/elmendorf/>_ 
(https://law.ucdavis.edu/faculty/elmendorf/) , over at the Election Law @ 
Moritz_<http://moritzlaw.osu.edu/election-law/article/?article=12965>_ 
(http://moritzlaw.osu.edu/election-law/article/?article=12965)  site, dives 
deep_<http://moritzlaw.osu.edu/election-law/article/?article=12965>_ 
(http://moritzlaw.osu.edu/election-law/article/?article=12965)  on the 7th Circuit’s WI voter ID 
decision_<http://moritzlaw.osu.edu/electionlaw/litigation/documents/Frank72.p
df>_ 
(http://moritzlaw.osu.edu/electionlaw/litigation/documents/Frank72.pdf) .  It begins:
 
Earlier this week Rick Hasen blasted Judge Easterbook’s opinion upholding 
Wisconsin’s voter ID requirement as cavalier with the facts and “heartless 
and dismissive” in tone. But in one respect the opinion is extremely helpful: 
it asks the right questions.
 
Three questions foregrounded by Easterbook are particularly important to 
the future of the Voting Rights Act:
 
What limiting principle keeps the Section 2 “results test” from obligating 
every state to tinker with its election machinery until rates of voter 
participation by race have been equalized? Insofar as Section 2 conditions state 
obligations on past or present societal discrimination, how does this 
square with the 14th and 15th Amendments, which by their terms reach only state 
action? To what extent are the “fact” questions in Section 2 cases questions 
that district judges should try to answer on the basis of expert testimony, 
as opposed to questions of belief, faith, or policy that ought to be 
settled by appellate courts as a matter of law?
 
As this post will explain, Judge Easterbook’s answers to these questions 
are not convincing. But unless proponents of robust voting rights protections 
come forth with better answers—answers that a conservative judge can 
appreciate—Easterbook’s opinion is likely to prove a harbinger of things to come 
at the Supreme Court.
 
[Share]_<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblo
g.org%2F%3Fp%3D66549&title=Right%20Questions%2C%20Wrong%20Answers%20in%20Vot
er%20ID%20Decision&description=>_ 
(https://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=66549&title=Right%20Questions,%20Wrong%20Answer
s%20in%20Voter%20ID%20Decision&description=) 
Posted in election law and constitutional 
law_<http://electionlawblog.org/?cat=55>_ (http://electionlawblog.org/?cat=55) , voter 
id_<http://electionlawblog.org/?cat=9>_ (http://electionlawblog.org/?cat=9) , Voting Rights 
Act_<http://electionlawblog.org/?cat=15>_ (http://electionlawblog.org/?cat=15) 
Edit_<http://electionlawblog.org/wp-admin/post.php?post=66549&action=edit>_ 
(http://electionlawblog.org/wp-admin/post.php?post=66549&action=edit) 
Roundup on the GAO Report on Voter 
ID_<http://electionlawblog.org/?p=66547>_ (http://electionlawblog.org/?p=66547) 
Posted on October 9, 2014 2:44 am_<http://electionlawblog.org/?p=66547>_ 
(http://electionlawblog.org/?p=66547)  by Justin 
Levitt_<http://electionlawblog.org/?author=4>_ (http://electionlawblog.org/?author=4) 
 
Politico_<http://www.politico.com/story/2014/10/voter-id-laws-minorities-111
721.html>_ 
(http://www.politico.com/story/2014/10/voter-id-laws-minorities-111721.html) , Natl 
Journal_<http://www.nationaljournal.com/domesticpolicy/voter-id-laws-can-decrease-minority-and-youth-turnout-20141008>_ 
(http://www.nationaljournal.com/domesticpolicy/voter-id-laws-can-decrease-minority-and-yo
uth-turnout-20141008) , the Wall St. 
Journal_<http://blogs.wsj.com/washwire/2014/10/08/gao-study-finds-voter-id-laws-reduced-turnout-in-tennessee-kansas
/>_ 
(http://blogs.wsj.com/washwire/2014/10/08/gao-study-finds-voter-id-laws-reduced-turnout-in-tennessee-kansas/) , and the Washington 
Times_<http://www.washingtontimes.com/news/2014/oct/8/p!_ 
(http://www.washingtontimes.com/news/2014/oct/8/photo-id-laws-do-hurt-voter-turnout-study/) 
_ hoto-id-_ 
(http://www.washingtontimes.com/news/2014/oct/8/photo-id-laws-do-hurt-voter-turnout-study/) 
_laws-do-hurt-voter-turnout-study/>_ 
(http://www.washingtontimes.com/news/2014/oct/8/photo-id-laws-do-hurt-voter-turnout-study/)  discuss the GAO 
report; Sec. Kobach 
responds_<http://www.kansas.com/news/politics-government/article2629693.html>_ 
(http://www.kansas.com/news/politics-government/article2629693.html) .
 
[Share]_<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblo
g.org%2F%3Fp%3D66547&title=Roundup%20on%20the%20GAO%20Report%20on%20Voter%20
ID&description=>_ 
(https://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=66547&title=Roundup%20on%20the%20GAO%20Report%20on%20Voter%20ID
&description=) 
Posted in The Voting Wars_<http://electionlawblog.org/?cat=60>_ 
(http://electionlawblog.org/?cat=60) , voter id_<http://electionlawblog.org/?cat=9>_ 
(http://electionlawblog.org/?cat=9) 
Edit_<http://electionlawblog.org/wp-admin/post.php?post=66547&action=edit>_ 
(http://electionlawblog.org/wp-admin/post.php?post=66547&action=edit) 
Redistricting Made Simple_<http://electionlawblog.org/?p=66545>_ 
(http://electionlawblog.org/?p=66545) 
Posted on October 9, 2014 2:43 am_<http://electionlawblog.org/?p=66545>_ 
(http://electionlawblog.org/?p=66545)  by Justin 
Levitt_<http://electionlawblog.org/?author=4>_ (http://electionlawblog.org/?author=4) 
 
Change IL_<http://www.changeil.org/>_ (http://www.changeil.org/)  has a 
great new animated digital 
tool_<http://app.newsbound.com/stacks/redistrict/redistrict_il/public>_ 
(http://app.newsbound.com/stacks/redistrict/redistrict_il/public)  explaining how redistricting works.  Even those who don’t like 
redistricting commissions have 18 slides to love.
 
[Share]_<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblo
g.org%2F%3Fp%3D66545&title=Redistricting%20Made%20Simple&description=>_ 
(https://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=66545&tit
le=Redistricting%20Made%20Simple&description=) 
Posted in redistricting_<http://electionlawblog.org/?cat=6>_ 
(http://electionlawblog.org/?cat=6) 
Edit_<http://electionlawblog.org/wp-admin/post.php?post=66545&action=edit>_ 
(http://electionlawblog.org/wp-admin/post.php?post=66545&action=edit) 
“Dark Money Still a Bit Player”_<http://electionlawblog.org/?p=66543>_ 
(http://electionlawblog.org/?p=66543) 
Posted on October 9, 2014 2:43 am_<http://electionlawblog.org/?p=66543>_ 
(http://electionlawblog.org/?p=66543)  by Justin 
Levitt_<http://electionlawblog.org/?author=4>_ (http://electionlawblog.org/?author=4) 
 
CCP in The 
Hill_<http://thehill.com/blogs/congress-blog/politics/219926-dark-money-still-a-bit-player>_ 
(http://thehill.com/blogs/congress-blog/politics/219926-dark-money-still-a-bit-player) : What would you call an election in 
which over 95 percent of campaign spending is funded by groups that 
publicly disclose the names and addresses of their donors to the Federal Election 
Commission, along with information on donors’ employers and occupations?
 
Though the point is valid, this op-ed assumes that spending disclosed to 
the FEC is the relevant denominator, and focuses on the portion with (some) 
donors disclosed.  But remember, some campaign spending is not disclosed to 
the FEC at 
all_<http://summaryjudgments.lls.edu/2014/05/the-drunkards-search-for-money-in.html>_ 
(http://summaryjudgments.lls.edu/2014/05/the-drunkards-search-for-money-in.html) , and we have no idea whether that number is large 
or small.  That’s not itself an argument for disclosing all the rest.  But it’
s important to keep in mind the spending nobody knows about before 
trumpeting transparency based on what’s visible under the streetlight.
 
[Share]_<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblo
g.org%2F%3Fp%3D66543&title=%E2%80%9CDark%20Money%20Still%20a%20Bit%20Player%
E2%80%9D&description=>_ 
(https://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=66543&title=“Dark%20Money%20Still%20a%20Bit%20Player”
&description=) 
Posted in campaign finance_<http://electionlawblog.org/?cat=10>_ 
(http://electionlawblog.org/?cat=10) 
Edit_<http://electionlawblog.org/wp-admin/post.php?post=66543&action=edit>_ 
(http://electionlawblog.org/wp-admin/post.php?post=66543&action=edit) 
“How Campaign Finance Laws Make Florida Governor’s Race Unique”
_<http://electionlawblog.org/?p=66540>_ (http://electionlawblog.org/?p=66540) 
Posted on October 9, 2014 2:42 am_<http://electionlawblog.org/?p=66540>_ 
(http://electionlawblog.org/?p=66540)  by Justin 
Levitt_<http://electionlawblog.org/?author=4>_ (http://electionlawblog.org/?author=4) 
 
On Miami public 
radio_<http://wlrn.org/post/how-campaign-finance-laws-make-florida-governors-race-unique>_ 
(http://wlrn.org/post/how-campaign-finance-laws-make-florida-governors-race-unique) .  According to the Campaign for 
Public Integrity, the campaigns of Charlie Crist and Rick Scott are responsible 
for about 3 percent of the spending in the race.
 
[Share]_<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblo
g.org%2F%3Fp%3D66540&title=%E2%80%9CHow%20Campaign%20Finance%20Laws%20Make%2
0Florida%20Governor%E2%80%99s%20Race%20Unique%E2%80%9D&description=>_ 
(https://www.addtoany.com/share_save#url=http://electionlawblog.org/?p=66540&title
=“How%20Campaign%20Finance%20Laws%20Make%20Florida%20Governor’
s%20Race%20Unique”&description=) 
Posted in campaign finance_<http://electionlawblog.org/?cat=10>_ 
(http://electionlawblog.org/?cat=10) 
 
--
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<mailto:justin.levitt at lls.edu_ 
(mailto:justin.levitt at lls.edu<mailto:justin.levitt at lls.edu) >
_ssrn.com/author=698321_ (http://ssrn.com/author=698321) 





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