[EL] ELB News and Commentary 9/24/14

Rick Hasen rhasen at law.uci.edu
Thu Sep 25 14:09:44 PDT 2014


    Breaking: Ohio Seeks #SCOTUS Emergency Stay in Early Voting Case
    <http://electionlawblog.org/?p=65883>

Posted onSeptember 25, 2014 2:07 pm 
<http://electionlawblog.org/?p=65883>byRick Hasen 
<http://electionlawblog.org/?author=3>

You can read the petitionat this link. 
<http://electionlawblog.org/wp-content/uploads/Ohio-election-stay-application-9-25-14.pdf> Given 
thecontroversial and expansive nature 
<http://electionlawblog.org/?p=65853>of the Sixth Circuit'sruling, 
<http://electionlawblog.org/wp-content/uploads/6th-early.pdf>a stay from 
the Supreme Court is certainly possible but not guaranteed.  Thelast 
time 
<http://www.slate.com/articles/news_and_politics/politics/2012/10/campaign_2012_will_obama_win_ohio_thanks_to_bush_v_gore.html>one 
of the emergency petitions went up on Ohio's early voting rules, in 
2012, the Supreme Court  stayed out. 
<http://www.slate.com/articles/news_and_politics/politics/2012/10/if_the_supreme_court_cuts_early_voting_in_ohio_it_could_swing_the_state.html>

Share 
<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D65883&title=Breaking%3A%20Ohio%20Seeks%20%23SCOTUS%20Emergency%20Stay%20in%20Early%20Voting%20Case&description=>
Posted inelection administration 
<http://electionlawblog.org/?cat=18>,The Voting Wars 
<http://electionlawblog.org/?cat=60>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    Ohio Files Petition for En Banc Review in Early Voting Case
    <http://electionlawblog.org/?p=65881>

Posted onSeptember 25, 2014 11:52 am 
<http://electionlawblog.org/?p=65881>byDan Tokaji 
<http://electionlawblog.org/?author=5>

The petition 
<http://moritzlaw.osu.edu/electionlaw/litigation/documents/EmergencyAppealEnBanc.pdf>challengesyesterday's 
Sixth Circuit ruling 
<http://moritzlaw.osu.edu/electionlaw/litigation/documents/Opinion092414.pdf>and 
seeks and immediate stay of the court's order regarding the period for 
same day registration and early voting, which is scheduled to begin on 
Tuesday of next week.

Share 
<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D65881&title=Ohio%20Files%20Petition%20for%20En%20Banc%20Review%20in%20Early%20Voting%20Case&description=>
Posted inabsentee ballots <http://electionlawblog.org/?cat=53>,voter 
registration <http://electionlawblog.org/?cat=37>


    Nudging in the Right Direction: A Response to Bob Bauer
    <http://electionlawblog.org/?p=65878>

Posted onSeptember 25, 2014 10:52 am 
<http://electionlawblog.org/?p=65878>byHeather Gerken 
<http://electionlawblog.org/?author=6>

/Authored by Heather Gerken, Wade Gibson, and Webb Lyons/

Bob Bauer'srecent post 
<http://www.moresoftmoneyhardlaw.com/2014/09/nudge-theory-gerken-disclosure-proposal/>on 
our"nondisclosure disclosure" proposal 
<http://electionlawblog.org/?p=60198>offers yet-another reminder why he 
was treated as an honorary member of the academic tribe long before he 
started teaching at Yale and NYU.  It's not just because Bauer's 
argument was smart and incisive.  It's because his post embodies the 
best of scholarly values:  Bauer offers the most generous account of our 
proposal before criticizing it.  It seems almost churlish to respond 
given that Bauer was kind enough to suggest we're taking 
campaign-finance reform in a new direction.  But his argument so cleanly 
and clearly sets up the central question about "soft law" reform like 
our own that we thought we'd offer our own take on the answer.

For those late to the conversation,in an editorial in the Washington 
Post 
<http://www.washingtonpost.com/opinions/rerouting-the-flow-of-dark-money-into-political-campaigns/2014/04/03/1517ac6e-b906-11e3-9a05-c739f29ccb08_story.html>, 
we suggest that any advertisement funded directly or indirectly by an 
organization that does not disclose its donors must acknowledge that 
fact with a simple and truthful disclaimer:  "This ad was paid for by 
'X,' which does not disclose the identity of its donors."   As Bob 
notes, because our proposal regulates the ad, not the organization, it 
helps solves what we called the "whack-a-mole" program -- the dilemma 
Congress and the FEC face in keeping up with the emergence of new 
institutional players in each election cycle.

Bauer worries that that the government may be "effectively weighing in 
on the credibility of a political message."  He asks whether there is "a 
material difference between the government mandating disclosure of 
facts, and the government inviting inferences in the absence of facts, 
in the First Amendment realm---particularly where the government is 
doing indirectly what it could, if it chose to do so, accomplish more 
directly by legislative mandate?"

We take Bauer's concerns seriously and agree with him that it's not 
enough for a state-mandated disclosure to be truthful for it to 
withstand scrutiny. There's a great example from a voting-rights case 
decided during the 1960s.  TheCourt invalidated 
<http://scholar.google.com/scholar_case?case=7236892496537838281&hl=en&as_sdt=6&as_vis=1&oi=scholarr>a 
Louisiana law requiring that the photos of candidates appear on the 
ballot, recognizing it as a patent effort to invite voters to 
discriminate on the basis of race.  We're especially grateful that Bauer 
has pushed on this point rather than let us simply invoke truth as a 
constitutional shield.  His prodding has made us think harder and frame 
our constitutional argument more precisely.

We still disagree with Bauer as to whether our proposal raises the First 
Amendment concerns he suggests, and here we think the doctrine is 
emphatically on our side.  The Court has made clear that 
transparency/is/an issue on which the government may provide voters 
information. /Citizens United/ 
<http://www2.bloomberglaw.com/public/desktop/document/Citizens_United_v_Federal_Election_Commission_130_S_Ct_876_175_L_>, 
for instance, offered a ringing endorsement of transparency rules 
precisely because voters can and should find them useful.  If the 
government can mandate disclosure for these entities, then surely it can 
require entities to disclose the truthful fact of nondisclosure.  If the 
government can mandate disclaimers and "stand by your ad" rules, surely 
it can require entities to acknowledge when its donors aren't standing 
by their ads.  Indeed, the fact that the government can mandate 
regulation in the first place is premised on the idea that it's 
acceptable for citizens to have a view on transparency.  In light of 
that constitutional backdrop, we see little difference between this rule 
and other truthful nudges, like states' routine practice of identifying 
which candidates are Democrats and Republicans on the ballot.

Bauer rightly notes that a lot depends on the background "architecture." 
Many of the"Nudge" 
<http://books.google.com/books/about/Nudge.html?id=mzZV9jFLltwC>proposals, 
for instance, are enacted against a backdrop of pervasive government 
regulation, where the government must choose one default or another and 
the only real question is which is the right default.   It's worth 
remembering, however, that our "nudge" would also be enacted against a 
backdrop of pervasive government regulation.  It's a regime in which the 
government requires the vast majority of entities running political ads 
to disclose their donors.  When a voter watches an ad, in other words, 
he has had good reason to assume it's been funded by transparent 
sources.  Our proposal simply alerts voters that this is not the case 
for ads being funded by dark money. The government, then, is helping 
ensure that citizens don't make a mistake.  You might even imagine an 
FDA analogy.  When consumers take a drug off the shelf, they assume that 
the drug has met FDA standards because the FDA pervasively subjects 
drugs to testing.  If the FDA were to exempt certain drugs from that 
regime, surely it would be constitutional for the FDA to require the 
manufacturers at least to acknowledge that fact.

Bauer worries about the government being "an active participant in 
political debates," and rightly so.  But the government is no more or 
less an active participant in this debate here than it is when it 
mandates disclosures and disclaimers generally.  In each of these 
instances, as with our proposal, the government isn't telling voters 
what to think.  It's simply giving voters the tool to make up their own 
minds.  That's precisely why the Supreme Court, which is deeply 
skeptical of government involvement in this arena, ruled 8 to 1 in favor 
of allowing government to provide citizens this important information. 
If our proposal works, then, it won't be because the government is 
drawing an inference; it's because voters are drawing one.

Share 
<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D65878&title=Nudging%20in%20the%20Right%20Direction%3A%20%20A%20Response%20to%20Bob%20Bauer&description=>
Posted incampaign finance <http://electionlawblog.org/?cat=10>,election 
law and constitutional law 
<http://electionlawblog.org/?cat=55>,Uncategorized 
<http://electionlawblog.org/?cat=1>


    "Wisconsin's new voter ID law could keep me from voting at age 87?
    <http://electionlawblog.org/?p=65874>

Posted onSeptember 24, 2014 3:56 pm 
<http://electionlawblog.org/?p=65874>byRick Hasen 
<http://electionlawblog.org/?author=3>

Ruthelle Frank Guardian oped 
<http://www.theguardian.com/commentisfree/2014/sep/24/wisconsin-new-voter-id-law-woman-denied-right-87?CMP=twt_gu>.

Share 
<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D65874&title=%E2%80%9CWisconsin%E2%80%99s%20new%20voter%20ID%20law%20could%20keep%20me%20from%20voting%20at%20age%2087%E2%80%B3&description=>
Posted inUncategorized <http://electionlawblog.org/?cat=1>


    "Kobach seeks to intervene in Kansas Senate dispute"
    <http://electionlawblog.org/?p=65872>

Posted onSeptember 24, 2014 3:54 pm 
<http://electionlawblog.org/?p=65872>byRick Hasen 
<http://electionlawblog.org/?author=3>

AP reports. 
<http://www.kansas.com/news/politics-government/election/article2232722.html>

Share 
<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D65872&title=%E2%80%9CKobach%20seeks%20to%20intervene%20in%20Kansas%20Senate%20dispute%E2%80%9D&description=>
Posted inballot access <http://electionlawblog.org/?cat=46>


    "This Candidate Will Pay For Your Gas to Smash a Toy Train"
    <http://electionlawblog.org/?p=65870>

Posted onSeptember 24, 2014 3:36 pm 
<http://electionlawblog.org/?p=65870>byRick Hasen 
<http://electionlawblog.org/?author=3>

TIME reports. 
<http://time.com/3425598/california-kashkari-crazy-train-gas-card/>

Share 
<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D65870&title=%E2%80%9CThis%20Candidate%20Will%20Pay%20For%20Your%20Gas%20to%20Smash%20a%20Toy%20Train%E2%80%9D&description=>
Posted invoting <http://electionlawblog.org/?cat=31>


    "Sixth Circuit finds Ohio has held illegal elections for over 200
    years" <http://electionlawblog.org/?p=65868>

Posted onSeptember 24, 2014 3:31 pm 
<http://electionlawblog.org/?p=65868>byRick Hasen 
<http://electionlawblog.org/?author=3>

Important postfrom Derek the Muller. 
<http://excessofdemocracy.com/blog/2014/9/sixth-circuit-finds-ohio-has-held-illegal-elections-for-over-200-years>

Share 
<https://www.addtoany.com/share_save#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D65868&title=%E2%80%9CSixth%20Circuit%20finds%20Ohio%20has%20held%20illegal%20elections%20for%20over%20200%20years%E2%80%9D&description=>
Posted inelection administration 
<http://electionlawblog.org/?cat=18>,The Voting Wars 
<http://electionlawblog.org/?cat=60>,voting 
<http://electionlawblog.org/?cat=31>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


-- 
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

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://webshare.law.ucla.edu/Listservs/law-election/attachments/20140925/5bbc4baf/attachment.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: share_save_171_16.png
Type: image/png
Size: 1504 bytes
Desc: not available
URL: <http://webshare.law.ucla.edu/Listservs/law-election/attachments/20140925/5bbc4baf/attachment.png>


View list directory