[EL] Reason to worry about Evenwel? (ELB News and Commentary 12/3/15)
Rick Hasen
rhasen at law.uci.edu
Fri Dec 4 11:12:51 PST 2015
Yeah Marty I agree that Roberts or Alito or someone else could use the
case as a time bomb for the next case, or a Roberts two-step. Both Nate
Persily and Dan Tokaji have flagged that as a possibility.
I guess I just don't see it happening here, in part because I think the
Court will recognize the practical difficulties of doing that, and the
new litigation it would spawn.
I also think that if legislators in places like Texas thought this was
feasible (politically and legally defensible based on the data), they
would have tried it already.
On 12/4/15 9:21 AM, Marty Lederman wrote:
> Two quick responses to Rick's column about whether (and why or why
> not) to worry about /Evenwel/.
>
> First, I agree that it's unlikely the Court will rule for the
> appellants, mostly for the reasons Rick canvasses. But the real
> action is on the question of whether and how it will take up
> /Texas's/ invitation to hold (even though the case doesn't require the
> Court to opine on it) that states /can /exclude nonvoting populations,
> including, most importantly, noncitizens, in drawing districts for
> state office. Will the Court endeavor to send a strong signal to
> state legislatures to go that route, even absent any concrete
> circumstances in which to assess whether and why and how a particular
> state would do so? That, IMHO, is one big thing to watch for in Evenwel.
>
> Second, when he was Deputy SG, John Roberts did not argue that "it
> would be quite anomalous . . . [to hold] that the Constitution
> /requires/ the use of total population in apportioning congressional
> districts*among the states* (that’s in the 14th Amendment) but it
> /forbids/ the use of total population in drawing congressional (or
> state) districts within states."
>
> He argued, instead, that it would be quite anomalous to hold that the
> Constitution /requires/ the use of total population *in drawing
> congressional (or state) districts within states *(a proposition for
> which he cited /Wesberry/), and yet /forbids/ such use of total
> population in drawing *state* districts.
>
> (See my post, citing his BIO, here:
> http://balkin.blogspot.com/2015/05/the-curious-result-urged-by-appellants.html)
>
> And in this respect, the other very significant thing to watch for in
> /Evenwel/ is what, if anything, the Court says or implies about the
> required population base for intrastate /congressional /districting.
> In their reply brief, petitioners actually argue that the premise of
> Deputy SG Roberts's argument "is flawed." They argue that neither
> /Wesberry /nor any other case has decided that question yet . . .
> thereby sending a clear signal that it's next in their sights,
> assuming the Court holds either that legislatures must or can exclude
> noncitizens in state-house districting. As for the merits of the
> question on congressional districts, they say only this:
>
> The Court need not resolve that question here. Appellants
> do not challenge a congressional map, and congressional and
> state-level districting, while not “wholly inapposite,” are “based
> on different constitutional considerations and [are] addressed to
> rather distinct problems.” Reynolds, 377 U.S. at 560.
>
>
> Therefore I think the other important thing-- perhaps the /most
> /important thing-- to watch for at argument next week, and in the
> opinion, is whether and how the Justices describe the constitutional
> requirements for /congressional /district line-drawing, because that
> is, I think, the proverbial two-ton gorilla in the middle of the
> room. The Justices would be wise to let it lie; but whether they will
> do so? . . .
>
> On Thu, Dec 3, 2015 at 11:19 AM, Rick Hasen <rhasen at law.uci.edu
> <mailto:rhasen at law.uci.edu>> wrote:
>
>
> Why I’m Optimistic About Evenwel, #SCOTUS One Person, One Vote
> Case <http://electionlawblog.org/?p=77988>
>
> Posted onDecember 3, 2015 8:18 am
> <http://electionlawblog.org/?p=77988>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> Regular readers of ELB know that I’m often sounding the alarm
> about Supreme Court cases with the potential to hurt our
> democracy. For example,I recently wrote
> <http://electionlawblog.org/?p=77857>of big procedural victory for
> campaign finance opponents which makes it fairly likely the
> Supreme Court will strike down the soft money provisions of the
> McCain-Feingold law within a few years. Indeed,in a current draft
> <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2639902>which
> I’ll be presenting at a/Stanford Law Review/symposium in February,
> I ask the question why the Roberts Court, despite cases such
> as/Citizens United/and/Shelby County/, has not moved even further
> to the right asI had predicted
> <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=850544>when
> the Roberts Court began in 2006.
>
> So I’m somewhat surprised myself that I am not all that worried
> about what the Court is going to do in theEvenwel v. Abbott
> <http://www.scotusblog.com/case-files/cases/evenwel-v-abbott/?wpmp_switcher=desktop>one
> person, one vote case, being heard next week at the Supreme Court.
> In /Evenwel/, plaintiffs ask for the Court to declare that the
> only proper basis to fulfill the Court’s ruling cases such as
> /Reynolds v. Sims/requiring creation of equipopulous legislative
> districts is to draw such districts with the same number of
> (eligible or registered?) voters, rather than people. If the
> argument is successful, it would radically change the way most
> states conduct their elections, and it would shift power in state
> (and likely congressional) elections away from Democratic and
> Latino areas (which tend to have larger Latino non-citizen
> populations) and toward Republican and rural ones. Indeed, I have
> argued inSlate
> <http://www.slate.com/articles/news_and_politics/jurisprudence/2015/05/evenwel_v_abbott_supreme_court_case_state_districts_count_voters_or_total.html>and
> atSCOTUSBlog
> <http://www.scotusblog.com/2015/07/symposium-ideology-partisanship-and-the-new-one-person-one-vote-case/>that
> the best way to understand this lawsuit is not as a principled
> conservative argument, but as an attempted Republican power grab.
>
> So why am I optimistic?
>
> First, I don’t think the Court wanted to take this case. I’ve
> explained this a lot in my earlier writings on this case, so I’ll
> be brief here. The Court has had the chance to hear this issue a
> number of times, and refused. In 2001, only Justice Thomas
> dissented from a cert. denial where this issue was raised. But Ed
> Blum managed to get this case heard before a three-judge court,
> with direct appeal to the Supreme Court. The Court feels a much
> greater obligation to take these cases, because a decision not to
> hear the case (unlike a cert denial) is a ruling on the merits.
> Here’s Chief Justice Robertsspeaking at oral argument
> <http://electionlawblog.org/?p=77284>in another case earlier in
> the term on the three judge courts:
>
> CHIEF JUSTICE ROBERTS: I mean, the other
> alternative is it’s a three-judge district court, and
> then we have to take it on the merits.
> Imean, that’s aserious problem because there are a lot of cases that
> come up in three-judge district courts that would be the
> kind of case – I speak for myself, anyway–
> that wemight deny cert in, to let the issue percolate.
> And now with the three judge district court, no, we have to
> decide it on the merits…
>
> So I don’t think the Court particularly wanted to take this case.
> And I expect only Justice Thomas, and Justice Alito,who expressed
> doubts about the one person one vote rule many decades ag
> <https://electionlawblog.org/?p=72780>o, are likely to be in play.
>
> Second, this issue seems like it was already settled in the 1966
> case/Burns v. Richardson
> <https://scholar.google.com/scholar_case?case=900318815708885571&hl=en&as_sdt=6&as_vis=1&oi=scholarr>.
> /There, the Court approved Hawaii’s use of total registered voters
> rather than total population, saying that the issue of what to use
> as the denominator in drawing equal districts resided in the
> states, at least when total voters does not sway too much from
> total population. So precedent is on Texas’s side.
>
> Third, it would be quite anomalous (as Chief Justice Roberts
> argued when he was a lawyer in the 9th Circuit Garza case), that
> the Constitution /requires/the use of total population in
> apportioning congressional districts among the states (that’s in
> the 14th Amendment) but it /forbids/the use of total population in
> drawing congressional (or state) districts within states. To the
> extent that the 14th Amendment is silent, certainly it would be
> odd to think the 14th amendment would have these two wildly
> different rules in these cases.
>
> Fourth, and related to the third point, there’s no strong
> originalist argument for this position. It is certainly possible
> to take a principled conservative position that these cases should
> have remained non-justiciable (that is, to argue /Baker v.
> Carr/was wrong) or that the 14th amendment does not require any
> kind of equality in the drawing of districts (that is, to argue
> /Reynolds/and the cases which followed it are wrong), but it is
> not a principled conservative position to argue that the 14th
> amendment /must/be interpreted to take discretion away from the
> states. This argument isnot trolling
> <http://electionlawblog.org/?p=77967>, as Andrew Grossman
> suggested. It is a recognition that it will be hard to attract
> conservative Justices to a position which is supported neither by
> originalist interpretation nor by principles of federalism.
>
> Fifth, and perhaps most importantly:Nate Persily
> <http://www.washingtonpost.com/news/in-theory/wp/2015/10/19/theres-nothing-conservative-about-destabilizing-our-election-system/>had
> made what I consider to bethe ironclad case
> <http://electionlawblog.org/wp-content/uploads/evenwel-persily-Brief.pdf>that
> actually putting a total voter standard into practicewould be
> <http://electionlawblog.org/?p=77303>very, very difficult.We do
> not have good data
> <https://soundcloud.com/cac-constitution/evenwel-v-abbott-telebriefing-1222015>,
> and we don’t come close to having good data, on voters as opposed
> to people in districts. Is the Court going to order that the
> census try collecting these data, or allow districts to be drawn
> based upon sample data, which is not up to date? It is hard to
> imagine.
>
> OK, so I may eat my words after oral argument. But this case
> (unlike others) is not causing me to lose sleep at night (yet).
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77988&title=Why%20I%26%238217%3Bm%20Optimistic%20About%20Evenwel%2C%20%23SCOTUS%20One%20Person%2C%20One%20Vote%20Case&description=>
> Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme
> Court <http://electionlawblog.org/?cat=29>
>
>
> “Evenwel and the Next Case” <http://electionlawblog.org/?p=77990>
>
> Posted onDecember 3, 2015 8:15 am
> <http://electionlawblog.org/?p=77990>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> Dan Tokaji: <https://www.acslaw.org/acsblog/evenwel-and-the-next-case>
>
> Although I’m generally loath to predict outcomes, I expect the
> Court to reject the appellants’ argument that the Constitution
> requires equalization of eligible voters among districts.
> But/how/it rejects this argument is very much up in the air.
> If/Evenwel/relies mainly on the principle of representational
> equality, it will tend to preserve the status quo in which
> state legislative districts are drawn based on total
> population. On the other hand, if the Court relies primarily
> on federalism, it will invite states to stop counting
> children, non-citizens, and other non-voters when drawing
> districts. Blue states will surely continue to draw districts
> based on total population, but we can expect red states to
> choose a narrower metric, one that diminishes the voting
> strength of minority communities and others with large
> non-voting populations. Those states might not even wait until
> the next census, given that the Court opened the door to
> mid-decade redistricting in another case from Texas,/LULAC v.
> Perry/ <https://www.law.cornell.edu/supct/html/05-204.ZS.html>.
>
> In sum, the issue before the Court in/Evenwel/is less
> difficult than the question whether states must equalize total
> population in drawing legislative districts. But/Evenwel/is
> still very important, because what the Court says in this case
> will affect, if not determine, the result of the next case.
> The decision will also affect how states – especially those
> controlled by Republicans – will draw districts after the 2020
> census, and possibly whether they’ll redraw their current
> districts before then.
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77990&title=%26%238220%3BEvenwel%20and%20the%20Next%20Case%26%238221%3B&description=>
> Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme
> Court <http://electionlawblog.org/?cat=29>
>
>
> “National Political Groups Ran More Ads in State Races This
> Year” <http://electionlawblog.org/?p=77986>
>
> Posted onDecember 3, 2015 7:41 am
> <http://electionlawblog.org/?p=77986>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> CPI <http://time.com/4134259/campaign-finance-state-ads/>:
>
> In total, 33 outside groups poured more than $32 million into
> their own political ads this year, accounting for more than
> one-third of the estimated $86 million inbroadcast TV ad
> spending in the seven states
> <https://www.publicintegrity.org/2015/10/01/18101/2015-state-ad-wars-tracker>with
> major races, according to aCenter for Public Integrity
> <https://www.publicintegrity.org/>analysis of data from media
> tracking firm Kantar Media/CMAG.
>
> That represents more than 1 in 4 political spots aired,
> compared with fewer than 1 in 5 ads in both 2011 when the same
> states had comparable races and in 2014 when major races
> occurred in45 states
> <https://www.publicintegrity.org/2014/09/22/15623/state-ad-wars-tracker>.
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77986&title=%26%238220%3BNational%20Political%20Groups%20Ran%20More%20Ads%20in%20State%20Races%20This%20Year%26%238221%3B&description=>
> Posted incampaign finance
> <http://electionlawblog.org/?cat=10>,campaigns
> <http://electionlawblog.org/?cat=59>
>
>
> “David Cohen, Pioneer of Public Interest Lobbying, Dies at 79”
> <http://electionlawblog.org/?p=77984>
>
> Posted onDecember 3, 2015 7:39 am
> <http://electionlawblog.org/?p=77984>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> Sad news
> <http://www.nytimes.com/2015/12/03/us/politics/david-cohen-pioneer-of-public-interest-lobbying-dies-at-79.html?ref=politics&_r=0>from
> the NYT:
>
> David Cohen, a self-styled Washington white-hat lobbyist who
> as the president of Common Cause successfully fought for
> post-Watergate laws on ethics, campaign financing and public
> disclosure, died on Sunday in Westport, Conn. He was 79.
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77984&title=%26%238220%3BDavid%20Cohen%2C%20Pioneer%20of%20Public%20Interest%20Lobbying%2C%20Dies%20at%2079%26%238221%3B&description=>
> Posted inelection law biz <http://electionlawblog.org/?cat=51>
>
>
> “U.S. Attorney reviewing voting rights lawsuit filed against
> Alabama” <http://electionlawblog.org/?p=77982>
>
> Posted onDecember 3, 2015 7:37 am
> <http://electionlawblog.org/?p=77982>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> Al.com:
> <http://www.al.com/news/birmingham/index.ssf/2015/12/us_attorney_reviewing_voting_r.html>
>
> The top federal prosecutor in North Alabama says she is
> reviewing alawsuit filed Wednesday
> <http://www.al.com/news/birmingham/index.ssf/2015/12/greater_birmingham_ministries.html>by
> groups challenging Alabama’s law requiring people to present
> photo identification before they can vote.
>
> “We received a copy of the lawsuit … We are certainly reading
> the lawsuit with great interest,” said U.S. Attorney Joyce Vance.
>
> But Vance said it was “too speculative” at this point on
> whether the U.S. Department of Justice would get involved in
> the issue. But, she added, “we are acutely concerned with
> protecting the right to vote.”
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77982&title=%26%238220%3BU.S.%20Attorney%20reviewing%20voting%20rights%20lawsuit%20filed%20against%20Alabama%26%238221%3B&description=>
> Posted inelection administration
> <http://electionlawblog.org/?cat=18>,The Voting Wars
> <http://electionlawblog.org/?cat=60>,voter id
> <http://electionlawblog.org/?cat=9>,Voting Rights Act
> <http://electionlawblog.org/?cat=15>
>
>
> “Who’s Behind the Ghost Companies Funding Jeb Bush’s
> Super-PAC?” <http://electionlawblog.org/?p=77980>
>
> Posted onDecember 3, 2015 7:31 am
> <http://electionlawblog.org/?p=77980>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> Russ
> Choma<http://www.motherjones.com/politics/2015/11/ghost-companies-funding-jeb-bush-super-pac-right-to-rise>for
> Mother Jones:
>
> In February, a limited liability company called TH Holdings
> LLC donated $100,000 to Right to Rise, the super-PAC
> supporting Jeb Bush’s bid for the GOP presidential nomination.
> That’s not extraordinary; quite a few LLCs have donated to the
> super-PAC, which has so far raised more than $103 million. But
> TH Holdings is a special case—one that represents the
> worst-case scenario in the post-/Citizens United/campaign
> finance landscape: untraceable corporations shoveling
> untraceable cash into the political system. Beyond this
> six-figure contribution, the company appears to have no
> history of doing business anywhere. And its incorporation
> records reveal no owners, managers, or officers.
>
> As far as the public record goes, this looks like a ghost
> company. So who is behind this contribution?
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77980&title=%26%238220%3BWho%26%238217%3Bs%20Behind%20the%20Ghost%20Companies%20Funding%20Jeb%20Bush%26%238217%3Bs%20Super-PAC%3F%26%238221%3B&description=>
> Posted incampaign finance
> <http://electionlawblog.org/?cat=10>,campaigns
> <http://electionlawblog.org/?cat=59>
>
>
> “Liberals, conservatives battle McConnell on plan to boost
> political parties” <http://electionlawblog.org/?p=77978>
>
> Posted onDecember 3, 2015 7:25 am
> <http://electionlawblog.org/?p=77978>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> Fredreka
> Schouten<http://www.usatoday.com/story/news/politics/2015/12/02/liberals-conservatives-battle-mcconnell/76686414/>for
> USA Today:
>
> Despite the resistance from House conservatives and liberal
> watchdogs, the push to strengthen political parties is gaining
> traction from establishment Republicans and Democrats.
>
> The liberal-leaning Brennan Center for Justice recently
> released a report that proposed easing, or dismantling
> altogether, candidate-party coordination limits.
>
> Some Democratic lawyers also want to loosen those restrictions.
>
> “In light of everything that has happened in the last five
> years on campaign finance, including the unleashing of super
> PACs, it’s time to revisit the effect that McCain-Feingold has
> had on parties, especially state and local parties,” said Neil
> Reiff, a Washington election lawyer who represents Democrats.
>
> There’s precedent for rewriting campaign-finance laws in
> year-end funding bills. Last year, lawmakers tripled the
> amount of money a single donor could give to all party
> committees. The provision appeared on page 1,599 of a
> 1,603-page, $1 trillion spending bill.
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77978&title=%26%238220%3BLiberals%2C%20conservatives%20battle%20McConnell%20on%20plan%20to%20boost%20political%20parties%26%238221%3B&description=>
> Posted incampaign finance
> <http://electionlawblog.org/?cat=10>,campaigns
> <http://electionlawblog.org/?cat=59>
>
>
> “How Far Will The Supreme Court Go In The Big New Voting
> Rights Case?” <http://electionlawblog.org/?p=77976>
>
> Posted onDecember 3, 2015 7:23 am
> <http://electionlawblog.org/?p=77976>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> Tierney Sneed reports
> <http://talkingpointsmemo.com/dc/evenwel-supreme-court-texas>on
> Evenwel for TPM.
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77976&title=%26%238220%3BHow%20Far%20Will%20The%20Supreme%20Court%20Go%20In%20The%20Big%20New%20Voting%20Rights%20Case%3F%26%238221%3B&description=>
> Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme
> Court <http://electionlawblog.org/?cat=29>
>
>
> “Supreme Court Blocks Native Hawaiian Vote Count”
> <http://electionlawblog.org/?p=77973>
>
> Posted onDecember 2, 2015 7:06 pm
> <http://electionlawblog.org/?p=77973>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> AP reports.
> <http://hosted.ap.org/dynamic/stories/U/US_NATIVE_HAWAIIAN_ELECTION?SITE=AP&SECTION=HOME&TEMPLATE=DEFAULT>
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77973&title=%26%238220%3BSupreme%20Court%20Blocks%20Native%20Hawaiian%20Vote%20Count%26%238221%3B&description=>
> Posted inSupreme Court <http://electionlawblog.org/?cat=29>,voting
> <http://electionlawblog.org/?cat=31>
>
>
> “Supreme Court Temporarily Blocks Vote Limited to Native
> Hawaiians” <http://electionlawblog.org/?p=77971>
>
> Posted onDecember 2, 2015 7:03 pm
> <http://electionlawblog.org/?p=77971>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> Jess Bravin reports
> <http://www.wsj.com/articles/supreme-court-temporarily-blocks-vote-limited-to-native-hawaiians-1449103992>for
> the WSJ.
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77971&title=%26%238220%3BSupreme%20Court%20Temporarily%20Blocks%20Vote%20Limited%20to%20Native%20Hawaiians%26%238221%3B&description=>
> Posted inSupreme Court <http://electionlawblog.org/?cat=29>,voting
> <http://electionlawblog.org/?cat=31>
>
>
> CAC Telebriefing on Evenwel Case
> <http://electionlawblog.org/?p=77969>
>
> Posted onDecember 2, 2015 6:58 pm
> <http://electionlawblog.org/?p=77969>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> Listen
> <https://soundcloud.com/cac-constitution/evenwel-v-abbott-telebriefing-1222015>:
>
> On December 2, 2015, Constitutional Accountability Center
> hosted a telebriefing on the case of Evenwel v. Abbott – due
> to be argued at the Supreme Court on the morning of December
> 8. The call featured insights from:
>
> * CAC Civil Rights Director David Gans
> * University of California at Irvine Law Professor Rick Hasen
> * Stanford Law Professor Nathaniel Persily
> * MALDEF President and General Counsel Thomas Saenz
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77969&title=CAC%20Telebriefing%20on%20Evenwel%20Case&description=>
> Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme
> Court <http://electionlawblog.org/?cat=29>
>
>
> “Evenwel v. Abbott: What Does One Person, One Vote Really
> Mean?” <http://electionlawblog.org/?p=77967>
>
> Posted onDecember 2, 2015 6:57 pm
> <http://electionlawblog.org/?p=77967>byRick Hasen
> <http://electionlawblog.org/?author=3>
>
> Andrew Grossman has writtenthis
> report<http://www.heritage.org/research/reports/2015/12/evenwel-v-abbott-what-does-one-person-one-vote-really-mean#_ftn31>for
> the Heritage Foundation. Here is a summary:
>
> /The greatest hope of those committed to the one-person,
> one-vote status quo seems to be that in deciding/Evenwel v.
> Abbott/, the Supreme Court will simply leave it alone if they
> raise enough random objections. Infused in that view is a
> great deal of dismissiveness about the merits of
> the/Evenwel/litigation and a great deal of angst over its
> potential political effects. If the Court is true to its
> precedents, it will act to enforce Sue Evenwel’s and Edward
> Pfenninger’s right to cast votes of the same weight as those
> of their fellow Texans. If it does not do that, its decision
> will mark a real break in the law of OPOV and, as a practical
> matter, could even spell the beginning of the end of the
> doctrine. That is the choice the Court faces./
>
> Don’t miss text accompanying n. 31, in which I’m accused of trolling.
>
> Share
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77967&title=%26%238220%3BEvenwel%20v.%20Abbott%3A%20What%20Does%20One%20Person%2C%20One%20Vote%20Really%20Mean%3F%26%238221%3B&description=>
> 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 <tel:949.824.3072> - office
> 949.824.0495 <tel:949.824.0495> - fax
> rhasen at law.uci.edu <mailto:rhasen at law.uci.edu>
> hhttp://www.law.uci.edu/faculty/full-time/hasen/
> <http://www.law.uci.edu/faculty/full-time/hasen/>
> http://electionlawblog.org
>
>
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--
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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