[EL] CCP v. Harris

Rick Hasen rhasen at law.uci.edu
Mon Nov 9 17:51:40 PST 2015


Sean,
It is a great question but I'm afraid I've reached significantly 
diminishing marginal returns for continuing this discussion on the 
listserv.  At some point I might invest more time in the question. I do 
recall thinking about it a lot in relation to the McConnell disclosure 
provisions, which went even broader than electioneering communications.

Rick


On 11/9/15 5:37 PM, Sean Parnell wrote:
>
> Then, if you don’t mind, what definition of political activity would 
> you like to see applied? For example:
>
> 1.Lobbying
>
> 2.Any communication published by a c3 that references a candidate, 
> such as “/So Sen. McCain, who has gotten a great deal of positive 
> press over the years with his crusade for campaign finance "reform" 
> and repeatedly denounced the so-called "special interests" represented 
> by lobbyists, must now explain how he can be friends with people who, 
> as has so indelicately put it in the past, "corrupt" the government by 
> representing their clients./”*
>
> 3.Any communication published by a c3 that, while it does not directly 
> reference a candidate by name, addresses policy positions that are 
> closely identified with particular candidates (say, McCain-Feingold or 
> the flat tax in 1996).
>
> There are other possibilities as well of course, these are just a few 
> that come to mind.
>
> Sean Parnell
>
> President, Impact Policy Management, LLC
>
> 571-289-1374 (c)
>
> sean at impactpolicymanagement.com
>
> Alexandria, Virginia
>
> *This is from a piece I wrote on CCP’s blog back in 2008, here 
> <http://www.campaignfreedom.org/2008/02/23/perhaps-an-update-to-im-just-a-bill-is-in-order/>. 
> Judging by some of the past campaign finance regulations I’ve seen 
> proposed in the past, it seems like the sort of thing that might be 
> considered “political” by some.
>
> *From:*Rick Hasen [mailto:rhasen at law.uci.edu]
> *Sent:* Monday, November 09, 2015 7:08 PM
> *To:* Smith, Brad; Sean Parnell; law-election at department-lists.uci.edu
> *Subject:* Re: [EL] CCP v. Harris
>
> I believe it depends upon what one considers to be political activity, 
> which does not have to match either the IRS's stated definition or its 
> actual enforcement practices
>
> On 11/9/15 3:59 PM, Smith, Brad wrote:
>
>     C3 groups do not, by definition, engage in politics. And that is
>     this case, CCP v. Harris.
>
>     Now if you wish to change the traditionally understood definition
>     of politics to include a whole bunch more stuff (and note, for IRS
>     –i.e. 990—purposes it is already much broader than it is for
>     FEC/political reporting) then go at it. But that’s asking for a
>     quite a change in the law.
>
>     In short, by supporting the state here, you have already announced
>     your support for “public disclosure of the information of c3
>     groups that do not engage in political activities.”
>
>     /Bradley A. Smith/
>
>     /Josiah H. Blackmore II/Shirley M. Nault /
>
>     /  Professor of Law/
>
>     /Capital University Law School/
>
>     /303 East Broad Street/
>
>     /Columbus, OH 43215/
>
>     /(614) 236-6317/
>
>     /bsmith at law.capital.edu <mailto:bsmith at law.capital.edu>/
>
>     /http://www.law.capital.edu/faculty/bios/bsmith.asp/
>
>     *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 *Rick Hasen
>     *Sent:* Monday, November 09, 2015 6:34 PM
>     *To:* Sean Parnell; law-election at department-lists.uci.edu
>     <mailto:law-election at department-lists.uci.edu>
>     *Subject:* Re: [EL] CCP v. Harris
>
>     I think whatever is disclosed to the IRS should be disclosable to
>     the AGs for enforcement purposes, provided of course that they can
>     keep the information private (an allegation which I understand has
>     not yet been considered in the case).  I would not support public
>     disclosure of the information of c3 groups that do not engage in
>     political activities.
>
>     On 11/9/15 1:18 PM, Sean Parnell wrote:
>
>         I’m curious what you think, Rick (and any other “reformers”)
>         about the policy as a stand-alone issue, i.e. not in regards
>         to what a ruling one way or another might mean for the
>         regulation of money in an explicit campaign context, but as a
>         policy issue in and of itself should state AG’s be able to
>         require the revelation of donors to c3 entities? And what
>         would you think of a policy of mandated disclosure to the
>         public of donors/members to c3 entities?
>
>         Sean Parnell
>
>         President, Impact Policy Management, LLC
>
>         571-289-1374 (c)
>
>         sean at impactpolicymanagement.com
>         <mailto:sean at impactpolicymanagement.com>
>
>         Alexandria, Virginia
>
>         *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 *Rick Hasen
>         *Sent:* Monday, November 09, 2015 4:07 PM
>         *To:* law-election at department-lists.uci.edu
>         <mailto:law-election at department-lists.uci.edu>
>         *Subject:* Re: [EL] CCP v. Harris
>
>         I'd also look at what the trial court did in Doe v. Reed and
>         Protect Marriage, as described in my "Chill Out" piece.
>
>         On 11/9/2015 12:58 PM, Bill Maurer wrote:
>
>             Thanks, Richard, I’ve read that case numerous times. It
>             seems to prove my point that the standard is actually
>             applicable only after the harassment has already occurred.
>
>             I would also note that, in practice, the application of
>             the case has been that only the Socialist Workers Party
>             has been able to demonstrate harassment. They are a
>             pristine example of something that is truly sui generis.
>
>             Bill
>
>             *From:*Richard Winger [mailto:richardwinger at yahoo.com]
>             *Sent:* Monday, November 09, 2015 12:49 PM
>             *To:* Bill Maurer; Edward Still; Allen Dickerson
>             *Cc:* law-election at uci.edu <mailto:law-election at uci.edu>
>             *Subject:* Re: [EL] CCP v. Harris
>
>             read Brown v Socialist Workers '74 Campaign Committee, 459
>             US 87.
>
>             Richard Winger 415-922-9779 PO Box 470296, San Francisco
>             Ca 94147
>
>             ------------------------------------------------------------------------
>
>             *From:*Bill Maurer <wmaurer at ij.org <mailto:wmaurer at ij.org>>
>             *To:* Edward Still <still at votelaw.com
>             <mailto:still at votelaw.com>>; Allen Dickerson
>             <adickerson at campaignfreedom.org
>             <mailto:adickerson at campaignfreedom.org>>
>             *Cc:* "law-election at uci.edu <mailto:law-election at uci.edu>"
>             <law-election at uci.edu <mailto:law-election at uci.edu>>
>             *Sent:* Monday, November 9, 2015 12:33 PM
>             *Subject:* Re: [EL] CCP v. Harris
>
>             Rick’s commented that “There is no constitutional
>             impediment to [disclosure], except as to those groups
>             which can demonstrate a realistic threat of harassment.”
>
>             I’ve never seen a discussion of what exactly a plaintiff
>             would have to do to demonstrate a realistic threat of
>             harassment. Wouldn’t evidence of a realistic threat be
>             evidence of actual harassment (for instance, I don’t see
>             those doing the harassing sending out a pre-harassment
>             notice that they will be engaging in future harassment,
>             although I suppose someone could do that)? And what about
>             new groups with new issues? How are they supposed to
>             demonstrate the realistic threat?
>
>             In other words, I don’t see the “harassment” standard as
>             protecting much of anything going forward—it is entirely
>             backward looking and, for that reason, utterly useless as
>             a protection against harassment in the first instance.
>
>             That is exactly the point Brad made about the inadvertent
>             disclosure analysis of the Ninth Circuit. The court
>             essentially said, you can’t get protection from
>             inadvertent disclosure until the information has been
>             inadvertently disclosed. At which point, it doesn’t matter.
>
>             And what’s the standard for harassment? Is it violence or
>             coercion, because I’ve heard a number of commentators
>             (including Justice Scalia) suggest that anything short of
>             that is the price of being involved in politics? Be we
>             already have laws against violence or coercion. So, are
>             laws against assault supposed to be the things that demark
>             the outer edge of how far the government can go in
>             collecting information about those who decide to exercise
>             their fundamental rights?
>
>             Isn’t the real standard that anyone who participates in
>             political activity in this country should be aware that by
>             doing so they are opening themselves up to governmental
>             scrutiny in perpetuity with no realistic protection
>             against misuse of the information the government has
>             collected?
>
>             Of course, a legitimate response to this is “We don’t care
>             if people are harassed or their information misused.” But,
>             why not say that?
>
>             Bill
>
>             *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 *Edward Still
>             *Sent:* Monday, November 09, 2015 9:04 AM
>             *To:* Allen Dickerson
>             *Cc:* law-election at uci.edu <mailto:law-election at uci.edu>
>             *Subject:* Re: [EL] CCP v. Harris
>
>             The Questions Presented were:
>
>             QUESTIONS PRESENTED
>
>             1. Whether a state official’s demand for all significant
>             donors to a nonprofit organization, as a precondition to
>             engaging in constitutionally-protected speech, constitutes
>             a First Amendment injury.
>
>             2. Whether the “exacting scrutiny” standard applied in
>             compelled disclosure cases permits state officials to
>             demand donor information based upon generalized “law
>             enforcement” interests, without making any specific
>             showing of need.
>
>             The cert petition is at http://electionlawblog.org/?p=74940.
>
>
>             Edward Still
>             Edward Still Law Firm LLC
>
>             429 Green Springs Hwy, STE 161-304
>
>             Birmingham AL 35209
>             205-320-2882
>             still at votelaw.com <mailto:still at votelaw.com>
>             www.votelaw.com/blog <http://www.votelaw.com/blog>
>             www.edwardstill.com <http://www.edwardstill.com>
>             www.linkedin.com/in/edwardstill
>             <http://www.linkedin.com/in/edwardstill>
>
>             On Mon, Nov 9, 2015 at 10:48 AM, Allen Dickerson
>             <adickerson at campaignfreedom.org
>             <mailto:adickerson at campaignfreedom.org>> wrote:
>
>             The point was to protect CCP's donors from scrutiny and
>             potential leaks, inadvertent or otherwise, by a state AG
>             who believed she was entitled to their identities without
>             making any showing of need whatsoever. The case did not
>             address the public informational interest behind campaign
>             finance disclosure, which we couldn't do in any case
>             because that wasn't the state's stated interest. Campaign
>             finance simply wasn't involved.
>
>             (Steve: the stated governmental interest was greater
>             efficiency in exercising the AG's law enforcement duties).
>
>
>             On Nov 9, 2015, at 11:34 AM, Rick Hasen
>             <rhasen at law.uci.edu <mailto:rhasen at law.uci.edu>> wrote:
>
>                 I think this case had the potential to undermine
>                 campaign disclosure rules if successful, and I think
>                 that was the point.
>                 And yes, I absolutely would have written the same
>                 comment if it were the Brennan Center or the ACLU
>                 suing the Texas AG.
>                 Rick
>
>                 On 11/9/2015 8:08 AM, Allen Dickerson wrote:
>
>                     Rick,
>
>                     Your post seriously misinterprets CCP v. Harris, a
>                     case that has nothing to do with political
>                     activity or campaign finance. California's
>                     registration policy applies only to 501(c)(3)
>                     organizations. And CCP, like all 501(c)(3) groups,
>                     is prohibited from engaging in political activity.
>                     The informational interest undergirding campaign
>                     finance disclosure simply isn't implicated here.
>
>                     A thought experiment: would you have written the
>                     same comment if the Brennan Center or ACLU had
>                     sued the Texas AG on the same claim?
>
>                     I recognize the ever-present danger of seeing
>                     campaign finance issues everywhere when that's
>                     one's area of expertise. But our case is a very
>                     poor fit for your political disclosure narrative.
>
>                     Best,
>
>                     Allen
>
>
>                     On Nov 9, 2015, at 10:48 AM, Rick Hasen
>                     <rhasen at law.uci.edu <mailto:rhasen at law.uci.edu>>
>                     wrote:
>
>
>                             “Democracy for GrownUps”
>                             <http://electionlawblog.org/?p=77408>
>
>                         Posted on November 9, 2015 7:46 am
>                         <http://electionlawblog.org/?p=77408> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         I have written this review
>                         <http://newramblerreview.com/book-reviews/law/democracy-for-grownups> of
>                         Bruce Cain’s Democracy More or Less
>                         <http://www.amazon.com/Democracy-More-Less-Political-Cambridge/dp/1107612268> for
>                         the New Rambler Review.
>                         <http://newramblerreview.com/>  It begins:
>
>                             /Modern American democracy is often messy,
>                             increasingly polarized, sometimes
>                             stupefying, and surprisingly
>                             decentralized. Our Congress functions (or
>                             doesn’t) mainly along party lines under
>                             rules set in a Constitution more than 200
>                             years old which does not recognize
>                             political parties, and indeed was designed
>                             to stifle their emergence. Divided
>                             government in times of polarized parties
>                             has undermined accountability as each side
>                             can blame the other for policy failures,
>                             and we lurch from one potential government
>                             shutdown to another thanks in part to
>                             polarization and in part to internal
>                             fighting within the Republican Party. Much
>                             power devolves to the state and local
>                             level, where we often see one-party rule
>                             rather than the partisan stalemate of
>                             Congress./
>
>                             /State one-partyism extends even to the
>                             rules for conducting elections, where a
>                             majority of states use partisan election
>                             officials to set the rules of the game and
>                             to carry out our elections, and where
>                             state legislatures draw their own
>                             legislative districts only mildly
>                             constrained by Supreme Court one-person,
>                             one-vote requirements. Our campaign
>                             finance system is careening toward
>                             deregulation, with a series of Supreme
>                             Court decisions and partially enforceable
>                             congressional measures leading to the
>                             creation of political organizations, some
>                             of which can shield their donors’
>                             identities, allowing the wealthiest of
>                             Americans to translate their vast economic
>                             power into political power. Money spent to
>                             influence elections is complemented by
>                             money spent to influence public policy
>                             through lobbying, creating a system in
>                             which those with great wealth and
>                             organizational ability have a much better
>                             chance of having their preferences enacted
>                             in law and having their preferred
>                             candidates elected, than average Americans
>                             have./
>
>                             /It is no wonder that the reform impulse
>                             in American politics is strong. States
>                             with the initiative process have
>                             experimented with top-two primaries in
>                             which the top two vote getters, regardless
>                             of party, go to a runoff, and
>                             redistricting reform featuring either
>                             citizen commissions or substantive limits
>                             on legislative self-dealing. The National
>                             Popular Vote movement seeks an end run
>                             around the antiquated rules of the
>                             Electoral College, which violate modern
>                             accepted principles of one-person,
>                             one-vote by giving small states outsized
>                             power relative to their populations./
>
>                             /Reformers push a constitutional amendment
>                             to overturn the Supreme Court’s decision
>                             in Citizens United and other cases which
>                             hamstring the government’s ability to
>                             control money in politics. Good government
>                             groups regularly clamor for redistricting
>                             reform (often joined by the political
>                             party on the losing side of redistricting
>                             in each state), expansion of voting rights
>                             for former felons and others, and the end
>                             of corruption and patronage. Some even
>                             call for constitutional conventions with
>                             citizen participants chosen by lottery./
>
>                             /But as Bruce Cain argues in his terrific
>                             new book, the never-ending efforts at
>                             reform present tradeoffs, and attempts to
>                             achieve either pure majoritarianism or
>                             government meritocracy can have unintended
>                             and unwanted consequences. Further, many
>                             reform efforts are oversold as a cure for
>                             all that ails American democracy. Cain
>                             argues for a Goldilocks-like pluralist
>                             reform agenda which recognizes that busy
>                             citizens lack interest in governing and
>                             capacity to make complex decisions.
>                             Instead, politics is conducted through
>                             intermediaries across the range of local,
>                             state, and national governing arenas.
>                             Pluralism “prioritizes aggregation,
>                             consensus, and fluid coalitions as a means
>                             of good democratic governance.” (p. 11)/
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77408&title=%26%238220%3BDemocracy%20for%20GrownUps%26%238221%3B&description=>
>
>                         Posted in theory
>                         <http://electionlawblog.org/?cat=41>
>
>
>                             ELB Podcast Episode 6. Nate Persily: Can
>                             the Supreme Court Handle Social Science In
>                             Election Cases?
>                             <http://electionlawblog.org/?p=77303>
>
>                         Posted on November 9, 2015 7:42 am
>                         <http://electionlawblog.org/?p=77303> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         Can the Supreme Court handle social science
>                         evidence in election law cases? Will lack of
>                         good data determine the outcome of the Supreme
>                         Court’s upcoming one person, one vote decision
>                         in /Evenwel v. Abbott/? What role will and
>                         should evidence play in assessing questions
>                         such as the constitutionality of
>                         McCain-Feingold’s soft money ban or Texas’s
>                         strict voter identification law.
>
>                         On Episode 6 of the ELB Podcast, we talk to
>                         law professor and political scientist Nate
>                         Persily <http://persily.com/> of Stanford Law
>                         School, one of the country’s leading
>                         redistricting and election law experts.
>
>                         You can listen to the ELB Podcast Episode 6 on
>                         Soundcloud
>                         <https://soundcloud.com/rick-hasen/elb-podcast-episode-6-nate> or
>                         subscribe at iTunes
>                         <https://geo.itunes.apple.com/us/podcast/elb-podcast/id1029317166?mt=2>.
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77303&title=ELB%20Podcast%20Episode%206.%20Nate%20Persily%3A%20Can%20the%20Supreme%20Court%20Handle%20Social%20Science%20In%20Election%20Cases%3F&description=>
>
>                         Posted in ELB Podcast
>                         <http://electionlawblog.org/?cat=116>, Supreme
>                         Court <http://electionlawblog.org/?cat=29>
>
>
>                             “Democratic Group Called iVote Pushes
>                             Automatic Voter Registration”
>                             <http://electionlawblog.org/?p=77406>
>
>                         Posted on November 9, 2015 7:38 am
>                         <http://electionlawblog.org/?p=77406> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         NYT:
>                         <http://www.nytimes.com/2015/11/10/us/politics/democratic-group-called-ivote-pushes-automatic-voter-registration.html?ref=politics&_r=0>
>
>                             /As Republicans across the country mount
>                             an aggressive effort to tighten voting
>                             laws, a group of former aides to President
>                             Obama and President Bill Clinton is
>                             pledging to counter by spending up to $10
>                             million on a push to make voter
>                             registration automatic whenever someone
>                             gets a driver’s license./
>
>                             /The change would supercharge the 1993
>                             National Voter Registration Act
>                             <http://www.justice.gov/crt/about-national-voter-registration-act>,
>                             known as the “motor voter” law, which
>                             requires states to offer people the option
>                             of registering to vote when they apply for
>                             driver’s licenses or other identification
>                             cards. The new laws would make
>                             registration automatic during those
>                             transactions unless a driver objected./
>
>                             /The group, called iVote — which is led by
>                             Jeremy Bird
>                             <http://www.nytimes.com/2012/04/30/us/politics/obama-campaign-confronts-voter-id-laws.html>,
>                             who ran Mr. Obama’s voter turnout effort
>                             in 2012 — is betting that such laws could
>                             bring out millions of new voters who have,
>                             for whatever reason, failed to register
>                             even when they had the opportunity at
>                             motor vehicle departments…./
>
>                             /Kris W. Kobach, the secretary of state in
>                             Kansas and a Republican, who has been a
>                             leading advocate of stricter voting laws,
>                             said he opposed automatic registration
>                             because people who chose not to register
>                             were clearly not interested in voting./
>
>                             /“The assumption that by making what is
>                             already easy automatic that will somehow
>                             bring people to the polls is just
>                             erroneous,” Mr. Kobach said. “I just think
>                             it’s a bad idea. It’s not going to
>                             increase participation rates.”/
>
>                             /Mr. Kobach has pushed for some of the
>                             nation’s most restrictive voting laws,
>                             including one that requires proof of
>                             citizenship. He said automatic
>                             registration would make that kind of check
>                             impossible./
>
>                             /“You’re going to end up with aliens on
>                             the voter rolls,” Mr. Kobach said. “It’s
>                             inevitable that an automatic registration
>                             system would result in many of them
>                             getting on.”/
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77406&title=%26%238220%3BDemocratic%20Group%20Called%20iVote%20Pushes%20Automatic%20Voter%20Registration%26%238221%3B&description=>
>
>                         Posted in election administration
>                         <http://electionlawblog.org/?cat=18>, The
>                         Voting Wars
>                         <http://electionlawblog.org/?cat=60>, voter
>                         registration <http://electionlawblog.org/?cat=37>
>
>
>                             “Inside the abandoned plans of Ted Cruz’s
>                             super PACs”
>                             <http://electionlawblog.org/?p=77404>
>
>                         Posted on November 9, 2015 7:32 am
>                         <http://electionlawblog.org/?p=77404> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         Teddy Schleifer
>                         <http://www.cnn.com/2015/11/08/politics/ted-cruz-super-pac-abandoned-plans/index.html> for
>                         CNN:
>
>                             /The super PACs are staffed in part by a
>                             few individuals with no formal political
>                             experience, including Neugebauer, who has
>                             been the groups’ main fundraiser and
>                             formerly its chief executive officer — in
>                             addition to one of its lead donors. The
>                             groups have only recently begun hiring
>                             their first political professionals,
>                             including a new professional fundraiser:
>                             Campbell Smith, a finance official at the
>                             National Rifle Association, the super PACs
>                             confirmed to CNN./
>
>                             /The ditched buy is at the heart of the
>                             dispute between the campaign and the super
>                             PAC — a dispute that spilled out into the
>                             public this week, with several campaign
>                             advisers telling Politico
>                             <http://www.politico.com/story/2015/11/ted-cruz-silent-super-pacs-2016-215422> that
>                             they want to see Keep the Promise purchase
>                             advertising time immediately. Campaigns
>                             and super PACs frequently read one
>                             another’s messages in the press with a
>                             fine-toothed comb to learn thinking that
>                             they cannot legally directly share with
>                             one another./
>
>                             /It’s a reflection of the divided campaign
>                             finance world, where super PACs are
>                             allowed to raise unlimited amounts of cash
>                             (donations must still be reported to the
>                             Federal Election Commission), but the
>                             catch is that campaign and super PAC
>                             officials aren’t allowed to coordinate.
>                             Neugebauer’s pitch at The Broadmoor came
>                             without Cruz staffers in the room, for
>                             instance, a donor said./
>
>                             /And amid increasing questions about the
>                             super PAC, campaign officials are coming
>                             to the defense of Neugebauer, who left his
>                             role at the super PAC in a shake-up, and
>                             are praising his ability to incentivize
>                             two more eight-digit donations with a $10
>                             million check of his own./
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77404&title=%26%238220%3BInside%20the%20abandoned%20plans%20of%20Ted%20Cruz%26%238217%3Bs%20super%20PACs%26%238221%3B&description=>
>
>                         Posted in campaign finance
>                         <http://electionlawblog.org/?cat=10>,
>                         campaigns <http://electionlawblog.org/?cat=59>
>
>
>                             “The battle over campaign finance reform
>                             is changing. Here’s how.”
>                             <http://electionlawblog.org/?p=77402>
>
>                         Posted on November 9, 2015 7:31 am
>                         <http://electionlawblog.org/?p=77402> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         WaPo talks
>                         <https://www.washingtonpost.com/news/the-fix/wp/2015/11/07/the-battle-over-campaign-finance-reform-is-changing-heres-how/> with
>                         Josh Silver of represent.us
>                         <http://represent.us/>.
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77402&title=%26%238220%3BThe%20battle%20over%20campaign%20finance%20reform%20is%20changing.%20Here%E2%80%99s%20how.%26%238221%3B&description=>
>
>                         Posted in campaign finance
>                         <http://electionlawblog.org/?cat=10>
>
>
>                             Bauer on Justice Kennedy on Citizens
>                             United at Harvard
>                             <http://electionlawblog.org/?p=77400>
>
>                         Posted on November 9, 2015 7:23 am
>                         <http://electionlawblog.org/?p=77400> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         Bauer blogs.
>                         <http://www.moresoftmoneyhardlaw.com/2015/11/justice-kennedy-harva>
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77400&title=Bauer%20on%20Justice%20Kennedy%20on%20Citizens%20United%20at%20Harvard&description=>
>
>                         Posted in campaign finance
>                         <http://electionlawblog.org/?cat=10>, Supreme
>                         Court <http://electionlawblog.org/?cat=29>
>
>
>                             Breaking:
>                             #SCOTUS <mime-attachment.png> Political
>                             Disclosure, Denies Cert. in CCP v. Harris
>                             <http://electionlawblog.org/?p=77396>
>
>                         Posted on November 9, 2015 7:19 am
>                         <http://electionlawblog.org/?p=77396> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         The Supreme Court, without noted dissent, has
>                         denied cert.
>                         <http://www.supremecourt.gov/orders/courtorders/110915zor_4g25.pdf>in
>                         Center for Competitive Politics v. Harris.
>                         The question concerns whether CA AG Harris can
>                         have access to CCP
>                         <http://www.campaignfreedom.org/>’s donor list
>                         for law enforcement purposes (and not for
>                         public disclosure) or whether such access
>                         violates the First Amendment.
>
>                         This cert. denial follows a string of cases in
>                         which the Supreme Court has endorsed
>                         disclosure as the appropriate way to deal with
>                         political activity (rather than campaign
>                         finance limits). These cases include
>                         /McConnell v. FEC/, /Citizens United v. FEC/,
>                         and /Doe v. Reed/. Aside from Justice Thomas
>                         (and to some extent Justice Alito), the Court
>                         has a strong belief in the benefits of
>                         disclosure in providing valuable information
>                         to voters, deterring corruption, and aiding in
>                         law enforcement. It is clearJustice Kennedy is
>                         upset
>                         <http://electionlawblog.org/?p=77126>that
>                         political forces have not enhanced disclosure
>                         since /Citizens United/. There is no
>                         constitutional impediment to it, except as to
>                         those groups which can demonstrate a realistic
>                         threat of harassment.
>
>                         The claims of harassment of contributors to
>                         conservatives causes have turned out to be
>                         greatly exaggerated. I explore this most
>                         recently in Chill Out: A Qualified Defense of
>                         Campaign Finance Disclosure Laws in the
>                         Internet Age
>                         <http://ssrn.com/abstract=1948313>, 27
>                         /Journal of Law and Politics/ 557 (2012).
>
>                         This is good news, although disclosure is far
>                         from enough
>                         <http://www.amazon.com/Plutocrats-United-Campaign-Distortion-Elections/dp/0300212453/ref=la_B0089NJCR2_1_7?s=books&ie=UTF8&qid=1430416698&sr=1-7> to
>                         deal with other problems with our campaign
>                         finance system.
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77396&title=Breaking%3A%20%23SCOTUS%20%E2%9D%A4%EF%B8%8F%20Political%20Disclosure%2C%20Denies%20Cert.%20in%20CCP%20v.%20Harris&description=>
>
>                         Posted in campaign finance
>                         <http://electionlawblog.org/?cat=10>,
>                         campaigns
>                         <http://electionlawblog.org/?cat=59>, Supreme
>                         Court <http://electionlawblog.org/?cat=29>
>
>
>                             “California’s ballot could be a
>                             blockbuster next November”
>                             <http://electionlawblog.org/?p=77394>
>
>                         Posted on November 8, 2015 7:05 pm
>                         <http://electionlawblog.org/?p=77394> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         John Myers
>                         <http://www.latimes.com/politics/la-me-pol-california-ballot-measures-2016-20151108-story.html> for
>                         the LAT:
>
>                             /The list of measures is very much a work
>                             in progress. Most campaigns are still
>                             gathering voter signatures or waiting for
>                             their proposals to be vetted by state
>                             officials./
>
>                             /But political strategists have identified
>                             at least 15 — perhaps as many as 19
>                             –measures that all have a shot at going
>                             before voters next fall./
>
>                             /The last time California’s ballot was
>                             that long was in November 2004, when there
>                             were16 propositions
>                             <http://elections.cdn.sos.ca.gov/sov/2004-general/formatted_ballot_measures_detail.pdf>.
>                             The March 2000 ballot had 20
>                             <http://elections.cdn.sos.ca.gov/sov/2000-primary/measures.pdf>./
>
>                             /Here are the expected 2016 ballot
>                             initiatives
>                             <http://www.latimes.com/politics/la-me-pol-california-ballot-box-2016-20151108-story.html>/
>
>                             /A number of political forces help explain
>                             why so many are lined up now. For
>                             starters, there’s the 2011 law
>                             <http://www.leginfo.ca.gov/pub/11-12/bill/sen/sb_0201-0250/sb_202_bill_20110908_amended_asm_v97.html> that
>                             moved everything but measures written by
>                             the Legislature to the general election
>                             ballot. As a result, June primary ballots
>                             are now almost barren of contentious
>                             campaigns./
>
>                             /There is also a lingering hangover from
>                             the state’s record-low voter turnout in
>                             2014: a new and extremely low number of
>                             voter signatures needed to qualify an
>                             initiative for the ballot./
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77394&title=%26%238220%3BCalifornia%26%238217%3Bs%20ballot%20could%20be%20a%20blockbuster%20next%20November%26%238221%3B&description=>
>
>                         Posted in direct democracy
>                         <http://electionlawblog.org/?cat=62>
>
>
>                             “As Lawrence Lessig’s Long-Shot Bid Ends,
>                             What’s To Come For His Key Issue?”
>                             <http://electionlawblog.org/?p=77392>
>
>                         Posted on November 8, 2015 4:26 pm
>                         <http://electionlawblog.org/?p=77392> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         Michel Martin interviews
>                         <http://www.npr.org/2015/11/08/455243856/as-lawrence-lessigs-long-shot-bid-ends-whats-to-come-for-his-key-issue?utm_source=twitter.com&utm_campaign=politics&utm_medium=social&utm_term=nprnews>Lessig
>                         for NPR.
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77392&title=%26%238220%3BAs%20Lawrence%20Lessig%26%238217%3Bs%20Long-Shot%20Bid%20Ends%2C%20What%26%238217%3Bs%20To%20Come%20For%20His%20Key%20Issue%3F%26%238221%3B&description=>
>
>                         Posted in campaign finance
>                         <http://electionlawblog.org/?cat=10>,
>                         campaigns <http://electionlawblog.org/?cat=59>
>
>
>                             “Lawmakers Ponder New Redistricting
>                             Methods” <http://electionlawblog.org/?p=77390>
>
>                         Posted on November 8, 2015 1:03 pm
>                         <http://electionlawblog.org/?p=77390> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         CBS Miami
>                         <http://miami.cbslocal.com/2015/11/06/lawmakers-ponder-new-redistricting-methods/>:
>
>                             /Oliva, who is set to take over as speaker
>                             of the House after the 2018 elections,
>                             said in the wake of the failed session
>                             that he was ready to consider an
>                             independent redistricting commission that
>                             would recommend maps to the Legislature.
>                             The House and Senate also failed to agree
>                             on a congressional redistricting plan
>                             during an August special session./
>
>                             /“I’m for looking into it, because I
>                             certainly think that we need to have maps
>                             that aren’t disputed halfway into the next
>                             Census,” Oliva said./
>
>                             /At the same time, he pointed out some of
>                             the pitfalls for a commission./
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77390&title=%26%238220%3BLawmakers%20Ponder%20New%20Redistricting%20Methods%26%238221%3B&description=>
>
>                         Posted in citizen commissions
>                         <http://electionlawblog.org/?cat=7>,
>                         redistricting <http://electionlawblog.org/?cat=6>
>
>
>                             “‘SNL’ Gives Donald Trump Just 12 Minutes
>                             On Screen”
>                             <http://electionlawblog.org/?p=77388>
>
>                         Posted on November 8, 2015 12:59 pm
>                         <http://electionlawblog.org/?p=77388> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         Variety
>                         <http://variety.com/2015/tv/news/donald-trump-saturday-night-live-12-minutes-1201636040/>:
>
>                             /His minimal appearance on the show would
>                             suggest NBC
>                             <http://variety.com/t/nbc/> was extremely
>                             cognizant of TV’s so-called “equal time”
>                             rule, which mandates that U.S. broadcast
>                             and radio stations that grant appearances
>                             to political candidates must provide an
>                             equal amount of time to other candidates
>                             who request it….Candidates who want equal
>                             time are not guaranteed to get what Trump
>                             received. NBC could send them to various
>                             programs operated by NBC News, or to
>                             NBC-owned stations or some of the
>                             network’s affiliates. But other people
>                             striving for the office could certainly
>                             gain publicity for themselves by making
>                             the request – and bring more scrutiny to
>                             the broadcast network, which is owned by
>                             Comcast’s NBCUniversal unit./
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77388&title=%26%238220%3B%E2%80%98SNL%E2%80%99%20Gives%20Donald%20Trump%20Just%2012%20Minutes%20On%20Screen%26%238221%3B&description=>
>
>                         Posted in campaigns
>                         <http://electionlawblog.org/?cat=59>
>
>
>                             What To Do About Truthiness in Campaigns?
>                             Not Much <http://electionlawblog.org/?p=77386>
>
>                         Posted on November 8, 2015 12:54 pm
>                         <http://electionlawblog.org/?p=77386> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         The New York Times notes that truth
>                         <http://www.nytimes.com/2015/11/08/us/politics/candidates-stick-to-script-if-not-the-truth-in-2016-race.html?ref=politics>seems
>                         to be a particular casualty of the 2016 election.
>
>                         It might make one think of laws barring false
>                         campaign speech.  But there are serious
>                         constitutional impediments to such laws, as I
>                         explored recently in A Constitutional Right to
>                         Lie in Campaigns and Elections?
>                         <http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2151618>,
>                         74/Montana Law Review/ 53 (2013).
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77386&title=What%20To%20Do%20About%20Truthiness%20in%20Campaigns%3F%20Not%20Much&description=>
>
>                         Posted in campaigns
>                         <http://electionlawblog.org/?cat=59>
>
>
>                             “In Seattle, a Campaign Finance Plan That
>                             Voters Control”
>                             <http://electionlawblog.org/?p=77384>
>
>                         Posted on November 8, 2015 12:52 pm
>                         <http://electionlawblog.org/?p=77384> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         NYT editorial:
>                         <http://www.nytimes.com/2015/11/08/opinion/sunday/in-seattle-a-campaign-finance-plan-that-voters-control.html?ref=opinion&_r=0>
>
>                             /In Tuesday, Seattle voters advanced the
>                             city’s reputation for progressivism when
>                             they approved a bold and unusual campaign
>                             finance reform plan. The plan will draw on
>                             real estate taxes to give every registered
>                             voter $100 in “democracy vouchers” to
>                             spend on candidates in the next city
>                             elections./
>
>                             /The 10-year, $30 million experiment in
>                             taxpayer subsidized elections was approved
>                             by a 20 percent margin in an initiative
>                             that supporters said was a reaction to the
>                             ability of affluent donors to dominate
>                             campaigns. Under the plan, every voter
>                             will receive four $25 vouchers in every
>                             election cycle to be used only as campaign
>                             contributions to candidates in city races./
>
>                             /Candidates are free to decline the money,
>                             but those who accept it will have to
>                             observe lower campaign spending and
>                             contribution limits, and agree to
>                             participate in at least three debates
>                             against rivals. The program will be
>                             financed by a property tax levy that works
>                             out to an estimated $9 a year on a
>                             $450,000 property. The unusual initiative
>                             is being closely watched by government
>                             reform groups in other parts of the
>                             nation, some of which helped finance the
>                             effort to get the initiative approved./
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77384&title=%26%238220%3BIn%20Seattle%2C%20a%20Campaign%20Finance%20Plan%20That%20Voters%20Control%26%238221%3B&description=>
>
>                         Posted in campaign finance
>                         <http://electionlawblog.org/?cat=10>
>
>
>                             Listen to the Oral Argument in Shapiro v.
>                             McManus Case
>                             <http://electionlawblog.org/?p=77382>
>
>                         Posted on November 8, 2015 12:40 pm
>                         <http://electionlawblog.org/?p=77382> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         Here <https://www.oyez.org/cases/2015/14-990>,
>                         at Oyez.
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77382&title=Listen%20to%20the%20Oral%20Argument%20in%20Shapiro%20v.%20McManus%20Case&description=>
>
>                         Posted in redistricting
>                         <http://electionlawblog.org/?cat=6>, Supreme
>                         Court <http://electionlawblog.org/?cat=29>
>
>
>                             “Garcetti explains email endorsement
>                             mistake” <http://electionlawblog.org/?p=77380>
>
>                         Posted on November 8, 2015 12:31 pm
>                         <http://electionlawblog.org/?p=77380> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         KPCC reports.
>                         <http://www.scpr.org/news/2015/11/07/55516/garcetti-explains-email-endorsement-mistake/>
>
>                             /Los Angeles Mayor Eric Garcetti expanded
>                             Friday on an email gaffe involving his
>                             endorsement of presidential candidate
>                             Hillary Clinton./
>
>                             /The Thursday email episode made headlines
>                             around the country. Through a city email
>                             account, a communications staffer for the
>                             mayor sent out an email
>                             <http://www.scpr.org/news/2015/11/05/55483/la-mayor-endorses-clinton-in-2016-white-house-cont/> quoting
>                             Garcetti endorsing Clinton for president.
>                             Just over an hour later, that email was
>                             retracted./
>
>                             /Even later on Thursday, his campaign
>                             confirmed that Garcetti is backing Clinton./
>
>                             /At an event downtown Friday afternoon,
>                             Garcetti called the email from his office
>                             a mistake./
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77380&title=%26%238220%3BGarcetti%20explains%20email%20endorsement%20mistake%26%238221%3B&description=>
>
>                         Posted in campaigns
>                         <http://electionlawblog.org/?cat=59>
>
>
>                             “Feds investigate Gov. Susana Martinez
>                             adviser Jay McClesky, campaign funds”
>                             <http://electionlawblog.org/?p=77378>
>
>                         Posted on November 8, 2015 12:26 pm
>                         <http://electionlawblog.org/?p=77378> by *Rick
>                         Hasen* <http://electionlawblog.org/?author=3>
>
>                         Santa Fe New Mexican
>                         <http://www.santafenewmexican.com/news/local_news/federal-probe-targets-gov-s-top-adviser-mccleskey/article_6cb560e4-4c58-5b1d-b1b9-f64109f0a884.html>:
>
>                             /For the past several months, the FBI has
>                             been interviewing some state Republicans
>                             about Gov. Susana Martinez’s fundraising
>                             activities going back to her first run for
>                             governor./
>
>                             /One prominent New Mexico Republican, who
>                             spoke on the condition of anonymity,
>                             confirmed being interviewed in recent
>                             months by federal agents about funds from
>                             Martinez’s campaign, as well as money from
>                             her 2011 inauguration committee, going to
>                             the governor’s political consultant, Jay
>                             McCleskey./
>
>                             /This person also said agents asked
>                             questions about different “fundraising
>                             vehicles,” such as political action
>                             committees, used by Martinez’s political
>                             wing, though it was unclear what potential
>                             violations federal agents are investigating./
>
>                         <share_save_171_16.png>
>                         <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D77378&title=%26%238220%3BFeds%20investigate%20Gov.%20Susana%20Martinez%20adviser%20Jay%20McClesky%2C%20campaign%20funds%26%238221%3B&description=>
>
>                         Posted in campaign finance
>                         <http://electionlawblog.org/?cat=10>,
>                         chicanery <http://electionlawblog.org/?cat=12>
>
>                         -- 
>
>                         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 <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
>                         <http://electionlawblog.org/>
>
>                         _______________________________________________
>                         Law-election mailing list
>                         Law-election at department-lists.uci.edu
>                         <mailto:Law-election at department-lists.uci.edu>
>                         http://department-lists.uci.edu/mailman/listinfo/law-election
>
>                 -- 
>
>                 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 <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 <http://electionlawblog.org/>
>
>
>             _______________________________________________
>             Law-election mailing list
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>
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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 <mailto:rhasen at law.uci.edu>
>
>         hhttp://www.law.uci.edu/faculty/full-time/hasen/
>
>         http://electionlawblog.org
>
>
>
>
>     -- 
>
>     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 <mailto:rhasen at law.uci.edu>
>
>     http://www.law.uci.edu/faculty/full-time/hasen/
>
>     http://electionlawblog.org
>
>
>
> -- 
> 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 <mailto:rhasen at law.uci.edu>
> http://www.law.uci.edu/faculty/full-time/hasen/
> http://electionlawblog.org

-- 
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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