[EL] ELB News and Commentary7/16/15

Rick Hasen rhasen at law.uci.edu
Thu Jul 16 09:19:52 PDT 2015


    “Hillary Clinton Lags in Engaging Grass-Roots Donors”
    <http://electionlawblog.org/?p=74375>

Posted onJuly 16, 2015 9:18 am 
<http://electionlawblog.org/?p=74375>byRick Hasen 
<http://electionlawblog.org/?author=3>

NYT 
<http://www.nytimes.com/2015/07/16/us/politics/hillary-clinton-lags-in-engaging-grass-roots-donors.html?ref=politics>:

    Of the $47.5 million that Mrs. Clinton has raised, less than
    one-fifth has come from donations of $200 or less. That is a far
    smaller proportion than that of her Democratic and Republican rivals
    who have excited grass-roots donors on the left and right, such as
    Senators Bernie Sanders of Vermont and Ted Cruz of Texas. While Mr.
    Sanders raised far less than Mrs. Clinton over all — about $15
    million, including money transferred from his Senate account — about
    four-fifths of that amount came from smaller donors.

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


    “Lobbyists bundle $2 million for Hillary Clinton”
    <http://electionlawblog.org/?p=74373>

Posted onJuly 16, 2015 9:16 am 
<http://electionlawblog.org/?p=74373>byRick Hasen 
<http://electionlawblog.org/?author=3>

WaPo reports 
<http://www.washingtonpost.com/news/powerpost/wp/2015/07/16/lobbyists-bundle-2-million-for-hillary-clinton/>.

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Posted incampaign finance <http://electionlawblog.org/?cat=10>,lobbying 
<http://electionlawblog.org/?cat=28>


    “The Latest Gerrymander: Voters Instead of People”
    <http://electionlawblog.org/?p=74371>

Posted onJuly 16, 2015 9:08 am 
<http://electionlawblog.org/?p=74371>byRick Hasen 
<http://electionlawblog.org/?author=3>

Alan Morrison on Evenwel. 
<http://www.huffingtonpost.com/alan-b-morrison/the-latest-gerrymander-vo_b_7800942.html>

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


    “Presidential campaign donors hedge bets; Some key contributors help
    bankroll two, four — even six candidates”
    <http://electionlawblog.org/?p=74369>

Posted onJuly 16, 2015 8:54 am 
<http://electionlawblog.org/?p=74369>byRick Hasen 
<http://electionlawblog.org/?author=3>

CPI reports. 
<http://www.publicintegrity.org/2015/07/16/17680/presidential-campaign-donors-hedge-bets>

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


    “Elections board member resigns under fire”
    <http://electionlawblog.org/?p=74367>

Posted onJuly 16, 2015 8:53 am 
<http://electionlawblog.org/?p=74367>byRick Hasen 
<http://electionlawblog.org/?author=3>

WRAL 
<http://www.wral.com/elections-board-member-resigns-under-fire/14776281/>:

    Hours after Gov. Pat McCrory called on him to step down and after
    initially refusing to do so, Paul Foley resigned from the State
    Board of Elections following disclosures he pressed for details in
    an investigation that involved one of his law firm’s clients.

    Elections board Chairman Josh Howard announced Foley’s resignation
    early Thursday.

    In a statement, Foley said he hoped his resignation would help
    “avoid distractions from the important work of the board.”

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


    California Appeals Court Lets New City Move from District to
    At-Large Elections <http://electionlawblog.org/?p=74365>

Posted onJuly 16, 2015 8:47 am 
<http://electionlawblog.org/?p=74365>byRick Hasen 
<http://electionlawblog.org/?author=3>

SeeBridges v. City of Widomar 
<http://www.courts.ca.gov/opinions/documents/E059890.PDF>.

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


    Analysis of Wisconsin John Doe Ruling: Bad News for Campaign Finance
    Laws <http://electionlawblog.org/?p=74355>

Posted onJuly 16, 2015 7:36 am 
<http://electionlawblog.org/?p=74355>byRick Hasen 
<http://electionlawblog.org/?author=3>

Today’s lengthy and contentious 4-2 ruling 
<http://www.wicourts.gov/sc/opinion/DisplayDocument.html?content=html&seqNo=144526> dividing 
the Court on partisan/ideological lines, from the Wisconsin Supreme 
Court ending the so-called “John Doe” probe, is significant for three 
reasons: (1) it removes a cloud from the Scott Walker presidential 
campaign; (2) it guts, perhaps for years, the effectiveness of the state 
of Wisconsin’s campaign finance laws, and (3) it reenforces conservative 
beliefs that they are the victims of frightening harassment, a belief 
which is likely to lead conservative judges to strike more campaign 
laws.  The case also raises significant questions about judicial recusal 
which go unanswered, and provide one of two potential bases to seek U.S. 
Supreme Court review in this case. Still, high court review seems unlikely.

I will not spend any time on the effects of the case on the Scott Walker 
candidacy, as this is an obvious benefit.

Nor will I review the background of this convoluted set of cases.  For 
more, seemy earlier Slate piece 
<http://www.slate.com/articles/news_and_politics/jurisprudence/2014/06/the_scott_walker_case_in_wisconsin_could_shred_the_remaining_limits_on_influencing.html?wpsrc>, 
as well as early coverage of today’s ruling in theNY Times 
<http://www.nytimes.com/2015/07/17/us/wisconsin-court-to-rule-on-inquiry-involving-scott-walkers-2012-campaign.html?hp&action=click&pgtype=Homepage&module=first-column-region&region=top-news&WT.nav=top-news>,Milwaukee 
Journal-Sentinel, 
<http://www.jsonline.com/news/statepolitics/wisconsin-supreme-court-ends-john-doe-probe-into-scott-walkers-campaign-b99535414z1-315784501.html>andWisconsin 
State Journal 
<http://host.madison.com/wsj/news/local/govt-and-politics/supreme-court-ends-john-doe-probe-that-threatened-scott-walker/article_50f22c3b-27c9-5906-92e8-ded75ed50954.html>. 
So let me focus on the remaining two points, and the potential for Court 
review.

*Gutting of campaign finance. *The conservatives on the Court have held 
that Wisconsin’s existing campaign finance laws violate the First 
Amendment to the extent they limit coordination between a candidate and 
/any group/, even a 501c4 group not disclosing its donors, on campaigns 
to support that candidate. The only thing the nominally outside group 
has to do is to avoid words of express advocacy or their functional 
equivalent.  Avoiding express advocacy while vigorously supporting a 
candidate, as we know from the federal period before McCain-Feingold, is 
child’s play. That is, a candidate can now direct unlimited 
contributions to a nominally outside group and tell that group what ads 
to run, when, and how.  If you think it is a problem for someone to be 
able to give millions of dollars directly to a candidate to support that 
candidate’s campaign, then this should be very troubling to you. It was 
a theory of coordination strongly rejected by the 7th Circuit in the 
federal version of the John Doe case. And there’s no prospect that the 
Wisconsin legislature, dominated by Republicans and already weakening 
campaign finance law, will fix this.  This applies only to Wisconsin 
elections (and not federal elections in Wisconsin) but is very, very bad 
news. (More analysis inmy earlier /Slate/piece.) 
<http://www.slate.com/articles/news_and_politics/jurisprudence/2014/06/the_scott_walker_case_in_wisconsin_could_shred_the_remaining_limits_on_influencing.html?wpsrc>

*Conservative harassment.*For months, conservatives have been sending me 
stories for ELB purporting to show the horrors of the investigation 
(late night raids, etc.)  However, these stories were never fully 
verified. As the Milwaukee-Journal Sentineleditorialized 
<http://www.jsonline.com/news/opinion/open-john-doe-investigation-of-gov-scott-walker-to-the-public-b99491741z1-302162641.html> about 
the selling of this story: “A breathless articlein the conservative 
National Review 
<http://www.nationalreview.com/article/417155/wisconsins-shame-i-thought-it-was-home-invasion-david-french>. 
An equally breathless reportby Megyn Kelly on Fox News 
<http://www.foxnews.com/transcript/2015/04/24/scott-walker-supporters-claim-police-raided-homes-over-politics/>.Tart 
comments from Gov. Scott 
Walker<https://www.youtube.com/watch?v=cuuGYGWoaC0>on the campaign trail 
in Iowa…. onservatives targeted by the John Doe investigation for more 
than a year have declined to discuss their concerns with the Journal 
Sentinel or other independent news outlets that will seek out all sides 
to a story. They have told their stories only to partisan outlets that 
share their political agenda, such as Fox News, the National Review 
andThe Wall Street Journal’s editorial page 
<http://www.wsj.com/articles/another-john-doe-disclosure-1402265159>(not 
its news staff).”  Now the conservatives on the Supreme Court have 
validated this version of events, and without full transparency the 
stories cannot be fully investigated. One Justice even went so far as to 
reach the issue of the constitutionality of the nighttime raids even 
though the issue was not before the Court. (I would love that Justice to 
ride along with police in the poorer parts of Milwaukee at night and 
perhaps gain some appreciation of what others face from law enforcement 
every day.) In the meantime, they fit into a conservative meme of 
persecution for conservative ideas. Expect this to lead to calls for 
even more laws to be struck down out of fear of persecution, fearswhich 
generally do not stand up to scrutiny 
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1948313>.

*Recusal?*We know that one of the prosecutors in the case asked at least 
one of the Justices who decided the case to recuse because the Justice 
may have been supported by some of the campaign spending in the case. As 
the dissenting Justice Abrahamson notes, the majority did not even 
respond to the issue. It seems to me that this at least deserves a 
response as to why recusal is not warranted.

*U.S. Supreme Court review?*The dissent notes that under the U.S. 
Supreme Court’s /Caperton /decision/, /the failure to recuse in this 
case could be a due process violation. At least theoretically, that’s an 
issue which could go to the U.S. Supreme Court. The Court could also 
potentially consider the First Amendment holding about coordinated issue 
advocacy. My guess is that the Court will decline review in this case, 
and frankly, given this Supreme Court on campaign finance issues, I’d be 
very afraid of having this issue before this Supreme Court. I mean I 
think Justice Kennedy would consider coordinated issue advocacy to be 
regulable, but I don’t know that I’d be the entire country’s campaign 
finance system on it.

In all, this is anunsurprising partisan holding 
<http://electionlawblog.org/?p=74299>on a partisan court about a 
campaign finance investigation with partisan implications. (True, 
Justice Crooks who dissented campaigned as a conservative, but started 
as a Democrat. So I guess there’s that to argue this is not fully a 
partisan decision.) The Wisconsin Supreme Court has been among the most 
bitterly divided along partisan lines. I doubt that after this they will 
move on. This will just further entrench things.  A bad day for campaign 
finance, and a worse day for Wisconsin.

[/This post has been updated and edited./]

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Posted incampaign finance <http://electionlawblog.org/?cat=10>,chicanery 
<http://electionlawblog.org/?cat=12>


    “The Disappearance of John Doe” <http://electionlawblog.org/?p=74352>

Posted onJuly 15, 2015 6:51 pm 
<http://electionlawblog.org/?p=74352>byRick Hasen 
<http://electionlawblog.org/?author=3>

This item 
<http://www.prwatch.org/news/2015/07/12885/disappearance-john-doe>appears at 
PR Watch.

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Posted incampaign finance <http://electionlawblog.org/?cat=10>,chicanery 
<http://electionlawblog.org/?cat=12>


    “Trial court breaks silence on redistricting schedule — orders Sept.
    25 deadline” <http://electionlawblog.org/?p=74348>

Posted onJuly 15, 2015 3:40 pm 
<http://electionlawblog.org/?p=74348>byRick Hasen 
<http://electionlawblog.org/?author=3>

The 
latest<http://miamiherald.typepad.com/nakedpolitics/2015/07/trial-court-breaks-the-silence-on-redistricting-schedule-orders-sept-25-deadline.html?utm_source=twitterfeed&utm_medium=twitter>from 
Fla.

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Posted inredistricting <http://electionlawblog.org/?cat=6>


    “Lawmakers Introduce Solution to Wall Street Conflicts of Interest;
    New Public Citizen Report Highlights Extent of Problem”
    <http://electionlawblog.org/?p=74346>

Posted onJuly 15, 2015 2:55 pm 
<http://electionlawblog.org/?p=74346>byRick Hasen 
<http://electionlawblog.org/?author=3>

Release <http://www.citizen.org/pressroom/pressroomredirect.cfm?ID=5593>:

    In an effort to rein in conflicts of interest and revolving door
    abuses within financial regulatory agencies, U.S. Sen. Tammy Baldwin
    (D-Wisc.) and Rep. Elijah Cummings (D-Md.) today introduced the
    Financial Services Conflict of Interest Act – a desperately needed
    package of ethics reforms for those who regulate Wall Street.

    At a press conference to announce the legislation, Public
    Citizenreleased a report (PDF)
    <http://www.citizen.org/documents/financial-services-conflict-of-interest-act-report.pdf>highlighting
    the extent of the problem the bill is designed to address. The
    report contains new data comparing the number of Wall Street and
    other business executives hired by the Obama, Bush and Clinton
    administrations that created potential conflicts of interest.

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Posted incampaign finance <http://electionlawblog.org/?cat=10>,conflict 
of interest laws <http://electionlawblog.org/?cat=20>,ethics 
investigations <http://electionlawblog.org/?cat=42>


    NC Gov. Calls on NC Election Board Member Foley to Resign Following
    Controversy <http://electionlawblog.org/?p=74344>

Posted onJuly 15, 2015 2:51 pm 
<http://electionlawblog.org/?p=74344>byRick Hasen 
<http://electionlawblog.org/?author=3>

Video clip <https://instagram.com/p/5K3NoUCExv/>.

Earlier coverage <http://electionlawblog.org/?p=74308>.

Update: I had thought the controversy had to do with a vote related to 
student voting, butthis story 
<http://www.wral.com/mccrory-looks-to-remove-elections-board-member/14775528/>explains 
it had to do with a potential conflict of interest:

    “Gov. McCrory will be taking appropriate action by statute to remove
    him form the board,” said McCrory Communication Director Josh Ellis.
    “The governor did this because of serious issues involving his
    conduct as a board member.”

    Foley is a Winston-Salem lawyer and, like the governor, a
    Republican. McCrory says he will rely on statutes that allow him to
    remove a board member for cause. In this case, McCrory says, Foley
    has created at least the appearance of a conflict of interest.

    The board met in Raleigh Wednesday to hear a report on a case
    involvingdonations from video sweepstakes gambling companies to the
    campaigns of North Carolina politicians
    <http://www.wral.com/sweepstakes-investigation-shines-light-into-campaign-finance/14774983/>,
    including McCrory. That investigation stemmed from a 2013 complaint
    by Democracy North Carolina and involved the sweepstakes company IIT
    and its owner, Chase Burns.

    According to a report released by the Attorney General’s Office
    earlier this month, Foley officially recused himself from the
    investigation but frequently pressured state board investigators for
    updates and early copies of the report at the same time his firm
    represented Burns and IIT.

    “I never attempted to, and hand no reason to, influence the outcome
    of the investigation,” Foley said in a brief statement read by
    telephone at the beginning of Wednesday’s board meeting.

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


    Jeb Bush to Release Bundler Names <http://electionlawblog.org/?p=74342>

Posted onJuly 15, 2015 2:50 pm 
<http://electionlawblog.org/?p=74342>byRick Hasen 
<http://electionlawblog.org/?author=3>

NYT 
reports.<http://www.nytimes.com/politics/first-draft/2015/07/15/jeb-bush-to-release-names-of-his-fund-raisers/> But 
not Rubio.

As for Bush—this doesn’t let him off the hook asJeb the Destroyer. 
<http://www.slate.com/articles/news_and_politics/politics/2015/04/jeb_bush_destroying_campaign_finance_rules_his_tactics_will_be_the_future.html>

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<http://electionlawblog.org/?cat=59>


    Kimberly Robinson on #SCOTUS Term, @UCILaw Term-in-Review
    <http://electionlawblog.org/?p=74340>

Posted onJuly 15, 2015 12:34 pm 
<http://electionlawblog.org/?p=74340>byRick Hasen 
<http://electionlawblog.org/?author=3>

Here at Bloomberg BNA. 
<http://www.bna.com/supreme-courts-left-b17179933568/>

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


    “Expert: N.C.’s election law places burdens on black, Hispanic
    voters” <http://electionlawblog.org/?p=74338>

Posted onJuly 15, 2015 11:57 am 
<http://electionlawblog.org/?p=74338>byRick Hasen 
<http://electionlawblog.org/?author=3>

The latest 
<http://www.journalnow.com/news/local/expert-n-c-s-election-law-places-burdens-on-black/article_c8d2dbd8-2b1b-11e5-bb65-7b8d56f39f60.html>from 
the NC voting trial.

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


    NASS Stinks <http://electionlawblog.org/?p=74334>

Posted onJuly 15, 2015 9:29 am 
<http://electionlawblog.org/?p=74334>byRick Hasen 
<http://electionlawblog.org/?author=3>

Boo!  The National Association of Secretaries of States has renewed its 
deplorable and indefensible call to stop funding the U.S. Election 
Assistance Commission. The EAC is no panacea but it can do some very 
helpful work on issues of voting technology and promulgating rules for 
best practices. This is a turf war, it is a fear of a slightly larger 
federal role in elections, and it disgusts me. (I discuss this much more 
in my book, /The Voting Wars 
<http://www.amazon.com/Voting-Wars-Florida-Election-Meltdown/dp/0300182031/ref=tmm_hrd_swatch_0?_encoding=UTF8&sr=&qid=>/. 
<http://www.amazon.com/Voting-Wars-Florida-Election-Meltdown/dp/0300182031/ref=tmm_hrd_swatch_0?_encoding=UTF8&sr=&qid=>)

    Doug Chapin
    <http://editions.lib.umn.edu/electionacademy/2015/07/15/nass-reauthorizes-three-elections-resolutions-at-2015-summer-meeting/>has
    the details:

    3. Resolution Reaffirming the NASS Position on Funding and
    Authorization of the U.S. Election Assistance Commission
    <http://www.nass.org/component/docman/?task=doc_download&gid=1722&Itemid=>:

    /WHEREAS, the National Association of Secretaries of State (NASS),
    on February 6, 2005, voted to approve a resolution by a substantial
    majority asking Congress not to reauthorize or fund the U.S.
    Election Assistance Commission (EAC) after the conclusion of the
    2006 federal election, by which date all the states were required to
    fully implement the mandates of the Help America Vote Act; and/

    /WHEREAS, the 2005 resolution was passed to help prevent the EAC
    from eventually evolving into a regulatory body, contrary to the
    spirt of the Help America Vote Act; and/

    /WHEREAS, that action was meant to preserve the state’ ability to
    serve as laboratories of change through successful experiments and
    innovation in election reform; and/

    /WHEREAS, each resolution passed at a NASS conference sunsets after
    five years unless reauthorized by a vote of the members; and/

    /WHEREAS, the NASS position on funding and authorization of the U.S.
    Election Assistance Commission was renewed by the membership on July
    20, 2010;/

    /NOW THEREFORE BE IT RESOLVED that the National Association of
    Secretaries of State, expressing their continued consistent position
    in 2015, reaffirm their resolution of 2005 and 2010 and encourage
    Congress not to reauthorize or fund the U.S. Election Assistance
    Commission./

    This one was contentious (passed largely but not exclusively on a
    party-line vote); it reflects ongoing skepticism about the expanded
    federal role post-HAVA in election administration as well aspartisan
    concerns in Congress
    <http://editions.lib.umn.edu/electionacademy/2015/03/02/even-after-return-congressiona/>about
    the wisdom and desirability of expending federal funds on the EAC.
    Reports from the meeting suggest that there were pleas to let the
    new Commissioners do their work but that the longstanding concerns
    about federal oversight eventually carried the day. It is notable,
    however, that the new resolution essentially preserves the uneasy
    compromise that characterizes the/status quo/.

UPDATE: NASSresponds 
<https://twitter.com/NASSorg/status/621382523084513280>on Twitter: “It 
wasn’t a simple vote@*NASSorg* <https://twitter.com/NASSorg>had a 
respectful dialogue w opinions on both sides. Roll call vote w 
reshttp://bit.ly/1e0V4ph<http://t.co/H4qvqyqbJA>“

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Posted inelection administration 
<http://electionlawblog.org/?cat=18>,Election Assistance Commission 
<http://electionlawblog.org/?cat=34>,The Voting Wars 
<http://electionlawblog.org/?cat=60>


    “What Campaign Filings Don’t Show: Super PACs’ Growing Sway”
    <http://electionlawblog.org/?p=74332>

Posted onJuly 15, 2015 8:25 am 
<http://electionlawblog.org/?p=74332>byRick Hasen 
<http://electionlawblog.org/?author=3>

NYT reports. 
<http://www.nytimes.com/2015/07/16/us/politics/election-2016-fundraising-campaign-filings.html?ref=politics>

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


    “The Past Goes On Trial in North Carolina”
    <http://electionlawblog.org/?p=74330>

Posted onJuly 15, 2015 8:24 am 
<http://electionlawblog.org/?p=74330>byRick Hasen 
<http://electionlawblog.org/?author=3>

David Graham 
<http://www.theatlantic.com/politics/archive/2015/07/nc-voting-case/398447/>for 
the Atlantic.

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


    “Witnesses: Changes in N.C.’s election law caused voting hardships”
    <http://electionlawblog.org/?p=74328>

Posted onJuly 15, 2015 8:22 am 
<http://electionlawblog.org/?p=74328>byRick Hasen 
<http://electionlawblog.org/?author=3>

Winston-Salem Journal report. 
<http://www.journalnow.com/news/elections/local/witnesses-changes-in-n-c-s-election-law-caused-voting/article_211553c0-2a9f-11e5-be10-17c46a0392df.html>

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Posted inelection administration 
<http://electionlawblog.org/?cat=18>,The Voting Wars 
<http://electionlawblog.org/?cat=60>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    “Democrats Pick An Attack Against Scott Walker: Voter ID”
    <http://electionlawblog.org/?p=74326>

Posted onJuly 15, 2015 8:20 am 
<http://electionlawblog.org/?p=74326>byRick Hasen 
<http://electionlawblog.org/?author=3>

BuzzFeed reports. 
<http://www.buzzfeed.com/darrensands/democrats-pick-an-attack-against-scott-walker-voter-id#.hunRNLMjr>

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Posted inThe Voting Wars <http://electionlawblog.org/?cat=60>


    “FEC Draft Rejects Issue-Based Contribution”
    <http://electionlawblog.org/?p=74324>

Posted onJuly 15, 2015 8:15 am 
<http://electionlawblog.org/?p=74324>byRick Hasen 
<http://electionlawblog.org/?author=3>

Bloomberg BNA 
<http://news.bna.com/mpdm/MPDMWB/split_display.adp?fedfid=72770690&vname=mpebulallissues&jd=a0g9v8j3c1&split=0>:

    The Federal Election Commission is set to deny a request from
    Democracy Rules Inc., a nonprofit organization that wants to collect
    online contributions from people favoring various issue positions
    and provide contributions to candidates favoring those positions.
    The FEC released a draft advisory opinion (AO 2015-03) on theagenda
    <http://www.fec.gov/agenda/2015/agenda20150716.shtml>for the FEC
    commissioners’ open meeting July 16, which would deny the bid from
    Democracy Rules.

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


-- 
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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