[EL] ELB News and Commentary 3/19/15

Rick Hasen rhasen at law.uci.edu
Thu Mar 19 08:10:54 PDT 2015


    DOJ’s Silence on the Wisconsin Voter ID Case Before SCOTUS
    <http://electionlawblog.org/?p=71116>

Posted onMarch 19, 2015 8:09 am 
<http://electionlawblog.org/?p=71116>byRick Hasen 
<http://electionlawblog.org/?author=3>

Linda Greenhouse 
<http://www.nytimes.com/2015/03/19/opinion/the-supreme-courts-identity-crisis-on-voting-rights.html?ref=opinion>joins 
thechorus <http://electionlawblog.org/?p=70220>of people calling for the 
Supreme Court to agree to hearFrank v. Walker 
<http://www.supremecourt.gov/search.aspx?filename=/docketfiles/14-803.htm>, 
the Wisconsin voter id case,up for a Supreme Court conference 
<http://electionlawblog.org/?p=70903> vote on Friday. (I think it is 
very unlikely we will hear anything Monday, when the Court next issues 
orders.  If the court is seriously considering the case, it has been 
taking two conferences to vet the cases to make sure they are 
appropriate vehicles to hear issues. If there is a cert. denial, I would 
expect a dissent from that decision, given Justice Ginsburg’s earlier 
strong dissent 
<http://www.slate.com/articles/news_and_politics/jurisprudence/2014/10/ginsburg_s_dissent_in_texas_voter_id_law_supreme_court_order.html>in 
the Texas case).

But conspicuously absent from theset of filings 
<http://advancementproject.org/pages/wi-scotus-amici-curiae> from amici 
calling for the Supreme Court to hear the case is the United States 
Department of Justice. DOJ’s failure to support the cert. petition 
stands in sharp contrast to the Texas voter id case and the challenge to 
North Carolina’s strict voting case, where DOJ is an active participant 
beginning at he level of the trial court. It is also in contrast with 
DOJ filing anamicus 
brief<http://moritzlaw.osu.edu/electionlaw/litigation/documents/Frank41.pdf>in 
the 7th Circuit in the Wisconsin case, urging the 7th Circuit to affirm 
a lower court holding that Wisconsin’s law violated both Section 2 of 
the Voting Rights Act and the Constitution’s equal protection clause.

What explains DOJ’s silence? Within the voting rights community, the 
decision to seek cert. in the Wisconsin case is controversial. To win, 
it requires the Court to either expand the scope of the Voting Rights 
Act section 2 in thevote denial case 
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=896786>s or to 
reinvigorate the equal protection clause in the context of voting rights 
beyond that which the Court did in the /Crawford v. Marion County/case.

Crawford, like Frank, came up from the 7th Circuit as a horrible opinion 
from a Seventh Circuit judge. I wrote anoped in the /Washington 
Post/<http://www.washingtonpost.com/wp-dyn/content/article/2007/09/18/AR2007091801572.html>urging 
the Supreme Court to take the case. It did, and the Supreme Court made 
things worse. Crawford was essentially a green light for ever more 
restrictive voter id laws.

Why should now be different? The Frank decision is also horrible. But 
the judge who wrote the horrible Crawford opinion in the Seventh 
Circuit,Judge Posner, 
<http://www.thedailybeast.com/articles/2013/10/23/why-judge-posner-is-right-on-voter-id-laws.html>had 
a revelation that voter id laws were about voter suppression rather than 
fraud prevention. Judge Posner wrote a fiery dissent in the Wisconsin 
case now, and the 5th circuit divided 5-5 on whether to rehear the 
Wisconsin case en banc. Those supporting the cert. petition in the 
Wisconsin case, like Linda Greenhouse, are betting that Justice Kennedy 
and/or Chief Justice Roberts will have a similar revelation on voter id. 
That’s a big, big bet.

Compare that to Texas. In the Texas voter id case, now pending before 
the 5th Circuit, we have a holding that Texas’s passage of the voter id 
law was the product of intentional racial discrimination. That’s a 
finding which should be very hard to reverse on appeal. it provides an 
easier constitutional path for the Supreme Court to strike down Texas’s 
voter id law. The upside of that would be a Supreme Court decision 
striking down a voter id law on constitutional grounds. The downside is 
that other cases, like Wisconsin, do not involve intentional 
discrimination and so a Texas holding might not help very much outside 
of Texas. It would be an outer bound of what’s allowed and forbidden.

But before this Supreme Court, DOJ may have calculated it will take what 
it can get.

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Posted inDepartment of Justice 
<http://electionlawblog.org/?cat=26>,election administration 
<http://electionlawblog.org/?cat=18>,Supreme Court 
<http://electionlawblog.org/?cat=29>,The Voting Wars 
<http://electionlawblog.org/?cat=60>,voter id 
<http://electionlawblog.org/?cat=9>,Voting Rights Act 
<http://electionlawblog.org/?cat=15>


    “2016 Candidates Thumb Their Noses At Campaign Finance Rules”
    <http://electionlawblog.org/?p=71114>

Posted onMarch 19, 2015 7:46 am 
<http://electionlawblog.org/?p=71114>byRick Hasen 
<http://electionlawblog.org/?author=3>

Paul Bluenthal reports 
<http://www.huffingtonpost.com/2015/03/18/2016-election-campaign-finance_n_6886908.html>for 
HuffPo.

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


    Senator Durbin Plays the Race Card <http://electionlawblog.org/?p=71112>

Posted onMarch 19, 2015 7:39 am 
<http://electionlawblog.org/?p=71112>byRick Hasen 
<http://electionlawblog.org/?author=3>

I usually am skeptical of claims that someone is improperly injecting 
race into a political issue. But I findSenator Durbin’s comments 
<http://www.washingtonpost.com/politics/sen-dick-durbin-gets-historical-in-his-advocacy-for-loretta-lynch/2015/03/18/29152c2e-cdb3-11e4-8c54-ffb5ba6f2f69_story.html>about 
Republican obstructionism (and it is obstructionism) on the nomination 
of Loretta Lynch to be attorney general to be an improper injection of 
race into a purely political issue:

    “And so,*Loretta Lynch*, the first African American woman nominated
    to be attorney general, is asked to sit in the back of the bus when
    it comes to the Senate calendar,” Durbin said on the Senate floor
    Wednesday morning. “That is unfair. It’s unjust. It is beneath the
    decorum and dignity of the United States Senate. This woman deserves
    fairness.”

    Durbin, of course, was comparing Lynch to*Rosa Parks*, the civil
    rights icon who in 1955 refused to give up her bus seat to a white
    passenger.

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


    “A mighty fundraising operation awaits Clinton, as well as financial
    hurdles” <http://electionlawblog.org/?p=71110>

Posted onMarch 19, 2015 7:36 am 
<http://electionlawblog.org/?p=71110>byRick Hasen 
<http://electionlawblog.org/?author=3>

Must-read 
<http://www.washingtonpost.com/politics/a-mighty-fundraising-operation-awaits-clinton-as-well-as-financial-hurdles/2015/03/19/c405a162-cd74-11e4-8a46-b1dc9be5a8ff_story.html>Matea 
Gold at WaPo.

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


    “AG to prosecute voter fraud case” <http://electionlawblog.org/?p=71108>

Posted onMarch 19, 2015 7:35 am 
<http://electionlawblog.org/?p=71108>byRick Hasen 
<http://electionlawblog.org/?author=3>

Texas case 
<http://www.brownsvilleherald.com/news/local/article_996416b6-cdea-11e4-9e1a-97e9e292bde0.html>involving 
stealing and marking others’ absentee ballots.

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Posted inchicanery <http://electionlawblog.org/?cat=12>,election 
administration <http://electionlawblog.org/?cat=18>


    “‘Shoot the gays’ initiative likely to be circulated”
    <http://electionlawblog.org/?p=71106>

Posted onMarch 19, 2015 7:33 am 
<http://electionlawblog.org/?p=71106>byRick Hasen 
<http://electionlawblog.org/?author=3>

Bob Egelko reports 
<http://blog.sfgate.com/nov05election/2015/03/18/shoot-the-gays-initiative-apparently-headed-for-circulation/>for 
the /SF Chronicle./

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Posted indirect democracy <http://electionlawblog.org/?cat=62>


    “Super PAC Men: How Political Consultants Took a Texas Oilman on a
    Wild Ride” <http://electionlawblog.org/?p=71104>

Posted onMarch 19, 2015 7:27 am 
<http://electionlawblog.org/?p=71104>byRick Hasen 
<http://electionlawblog.org/?author=3>

ProPublica reports. 
<http://www.propublica.org/article/super-pac-men-how-political-consultants-took-texas-oilman-on-wild-ride>

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


    “Identity Crisis: The Supreme Court’s Identity Crisis on Voting
    Rights” <http://electionlawblog.org/?p=71102>

Posted onMarch 19, 2015 7:26 am 
<http://electionlawblog.org/?p=71102>byRick Hasen 
<http://electionlawblog.org/?author=3>

Linda Greenhouse 
<http://www.nytimes.com/2015/03/19/opinion/the-supreme-courts-identity-crisis-on-voting-rights.html?_r=0>in 
the NYT:

    But I have a sense now that those dots are getting connected. Not
    only was Selma’s 50th anniversary — the real one, not my imaginary
    one of two years ago — a stirring national event, but in Ferguson
    itself, residents areturning to the ballot box
    <http://www.nytimes.com/2015/03/15/us/politics/city-council-races-offer-change-in-ferguson-after-months-of-upheaval.html>as
    the path to reform. I hope it’s not a fantasy to imagine that the
    Supreme Court — yes, the Roberts court — will seize the opportunity
    that the Wisconsin case provides to send a message different from
    the one it sent two years ago, an affirmative message the country
    now urgently needs to hear.

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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>


    “Oregon’s Automatic Registration is Law: Now What?”
    <http://electionlawblog.org/?p=71100>

Posted onMarch 19, 2015 7:24 am 
<http://electionlawblog.org/?p=71100>byRick Hasen 
<http://electionlawblog.org/?author=3>

A ChapinBlog. 
<http://blog.lib.umn.edu/cspg/electionacademy/2015/03/oregons_automatic_registration.php>

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Posted inelection administration 
<http://electionlawblog.org/?cat=18>,voter registration 
<http://electionlawblog.org/?cat=37>


    “U.S. appeals court says Texas should not pay legal fees in voting
    case” <http://electionlawblog.org/?p=71096>

Posted onMarch 18, 2015 4:15 pm 
<http://electionlawblog.org/?p=71096>byRick Hasen 
<http://electionlawblog.org/?author=3>

Anyone have details onthis 
<http://www.reuters.com/article/2015/03/18/us-usa-texas-voterid-idUSKBN0ME01B20150318>? 
  I cannot find an order at the 5th Circuit website.

UPDATE:Here 
<http://www.ca5.uscourts.gov/opinions/pub/14/14-50042-CV0.pdf>is the 
decision. It is section 5 Texas redistricting litigation, not the voter 
id litigation, as was initially erroneously reported (and it was not a 
$3 million award affirmed, it was a $300,000 award reversed).

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


    “IRS may broaden rule to police political nonprofits”
    <http://electionlawblog.org/?p=71094>

Posted onMarch 18, 2015 4:03 pm 
<http://electionlawblog.org/?p=71094>byRick Hasen 
<http://electionlawblog.org/?author=3>

Politico Pro witha big story 
<https://www.politicopro.com/story/tax/?id=44964>(albeit behind the 
paywall):

    The IRS may broaden a looming controversial rule to police political
    nonprofits to include political parties and political action
    committees, the IRS chief said Wednesday.

    IRS Commissioner John Koskinen said the agency may expand a
    yet-to-be-released rule governing 501(c)(4), “social welfare”
    groups, to include political groups known as 527s, which focus on
    elections. It could require them both — as well as other types of
    tax-exempt groups — to operate under the same definition of
    “political activity.”

It is really hard to assess the implications of all of this without 
seeing a draft rule.

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Posted incampaign finance <http://electionlawblog.org/?cat=10>,tax law 
and election law <http://electionlawblog.org/?cat=22>


    “The Coordination Fallacy” <http://electionlawblog.org/?p=71092>

Posted onMarch 18, 2015 4:00 pm 
<http://electionlawblog.org/?p=71092>byRick Hasen 
<http://electionlawblog.org/?author=3>

Michael Gilbert and Brian Barnes have postedthis draft 
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2579296>on SSRN 
(forthcoming FSU Law Review).  Here is the abstract:

    This symposium piece tackles an important issue in campaign finance:
    the relationship between coordinated expenditures and corruption.
    Only one form of corruption, the quid pro quo, is constitutionally
    significant, and it has three logical elements: (1) an actor, such
    as an individual or corporation, conveys value to a politician, (2)
    the politician conveys value to the actor, and (3) a bargain links
    the two. Campaign finance regulations aim to deter quid pro quos by
    impeding the first or third element. Limits on contributions, for
    example, fight corruption by capping the value an actor can convey
    to a politician. What about limits on coordinated expenditures? By
    preventing coordination on large expenditures like television ads,
    the law turns very useful support into less useful support, reducing
    the value an actor can convey. But actors can surmount this with
    more money: $1 million spent on less useful ads can convey a lot of
    value, often more than smaller amounts spent on very useful ads or
    contributions. Limits on coordination may also inhibit bargaining,
    the third element of a quid pro quo, but again, sophisticated actors
    can surmount this: they can bargain without discussing the substance
    of any expenditures. So coordination regulations cannot deter much
    corruption, at least not when wealthy and sophisticated actors are
    involved, the very actors who cause the most concern. Consequently,
    coordination regulations may violate the Constitution. This is not
    because coordinated expenditures do not corrupt but because the
    regulations do not deter. Solving this problem requires more than a
    broader set of regulations. It requires confronting a fallacy at the
    heart of campaign finance: the belief that coordination relates in
    any operational way to corruption.

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


    No Election Law Video Games <http://electionlawblog.org/?p=71090>

Posted onMarch 18, 2015 2:17 pm 
<http://electionlawblog.org/?p=71090>byRick Hasen 
<http://electionlawblog.org/?author=3>

Hartford Courant 
<http://www.courant.com/opinion/editorials/hc-ed-rowland-sentenced-20150318-story.html>:

    There are no video games about election law violations, that we know
    of, and the subject rarely comes up in television crime dramas. But
    clean elections are the bedrock of a representative democracy, and
    the laws that support the elective process must be enforced.

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Posted inbribery <http://electionlawblog.org/?cat=54>,campaign finance 
<http://electionlawblog.org/?cat=10>,chicanery 
<http://electionlawblog.org/?cat=12>


    “Obama Floats Idea for Mandatory Voting in the US”
    <http://electionlawblog.org/?p=71088>

Posted onMarch 18, 2015 2:16 pm 
<http://electionlawblog.org/?p=71088>byRick Hasen 
<http://electionlawblog.org/?author=3>

AP reports. 
<http://abcnews.go.com/Politics/wireStory/obama-floats-idea-mandatory-voting-us-29735579>

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Posted invoting <http://electionlawblog.org/?cat=31>


    “Kobach: New registration law in Oregon likely to increase vote
    fraud” <http://electionlawblog.org/?p=71086>

Posted onMarch 18, 2015 9:42 am 
<http://electionlawblog.org/?p=71086>byRick Hasen 
<http://electionlawblog.org/?author=3>

Brian Lowry reports. 
<http://www.kansas.com/news/politics-government/article15225749.html>

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Posted infraudulent fraud squad <http://electionlawblog.org/?cat=8>

-- 
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
hhttp://www.law.uci.edu/faculty/full-time/hasen/
http://electionlawblog.org

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