[EL] ELB News and Commentary 9/29/15
Rick Hasen
rhasen at law.uci.edu
Tue Sep 29 07:55:51 PDT 2015
“Kris Kobach, his views spark intense reactions – from supporters,
opponents (+videos)” <http://electionlawblog.org/?p=76268>
Posted onSeptember 29, 2015 7:53 am
<http://electionlawblog.org/?p=76268>byRick Hasen
<http://electionlawblog.org/?author=3>
Bryan Lowry
<http://www.kansas.com/news/politics-government/article36718005.html>for
the Wichita Eagle:
Kobach has had “a devastating impact on voting rights in the state
of Kansas and, for that matter, across the country,” says Micah
Kubic, executive director of the American Civil Liberties Union of
Kansas.
Kobach championed a proof-of-citizenship requirement to register to
vote, a policy that has left thousands of prospective voters in
suspended registration status since January 2013. Beginning this
week, his office will remove any names that have been on the
suspended list for more than 90 days.
He says this will save local election offices money, but the ACLU
says it is primarily meant to relieve Kobach of the political
embarrassment of having nearly 37,000 prospective voters in
suspended registration status. He calls that ridiculous.
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Posted inelection administration
<http://electionlawblog.org/?cat=18>,fraudulent fraud squad
<http://electionlawblog.org/?cat=8>,The Voting Wars
<http://electionlawblog.org/?cat=60>
The Roberts Court at 10: Election Law
<http://electionlawblog.org/?p=76266>
Posted onSeptember 29, 2015 7:47 am
<http://electionlawblog.org/?p=76266>byRick Hasen
<http://electionlawblog.org/?author=3>
With today’s 10 year anniversary of John Roberts’ joining the Supreme
Court as Chief Justice of the United States. here’s another link to my
paper in progress,Election Law’s Path in the Roberts Court’s First
Decade: A Sharp Right Turn But with Speed Bumps and Surprising Twists
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2639902>. Abstract:
The first decade of election law cases at the Supreme Court under
the leadership of Chief Justice Roberts brought election law down a
strong conservative path. Citizens United v. Federal Election
Commission freed corporate money in U.S. candidate elections and
opened up a deregulatory era increasingly dominated by nominally
independent “Super PACs.” Shelby County v. Holder eviscerated the
congressional regime codified in Section 5 of the Voting Rights Act
under which Congress required states and localities with a history
of racial discrimination in voting to obtain federal permission
before making a change in voting rules by proving that the change
would not make minority voters worse off. In its wake,
previously-covered jurisdictions have adopted a number of election
changes which no doubt have made minority voters worse off. In
Crawford v. Marion County Election Board the Court gave the green
light for state voter identification laws, despite a lack of
evidence that such laws are necessary to deter fraud or instill
voter confidence. Republican states have increasingly tightened
voting rules in Crawford’s wake. Finally, the Court will soon
consider whether to place new restrictions on application of the one
person, one vote rule which would hurt Latino representation and
strengthen rural and Republican power. The Court took the case,
Evenwel v. Abbott, despite having apparently resolved the legal
question it presents in 1966.
Nonetheless, the Roberts Court, while dominated by a majority of
five conservative Justices, has not gone as far right as it could
have or as some, including I, had predicted. In the campaign finance
arena, the Court has thus far refused to take cases to strike down
the ban on direct corporate contributions to candidates, or to
reopen the ability of political parties to take large “soft money”
contributions. It has not eliminated individual contribution limits,
even as Super PACs and other campaign groups undermine them. In the
voting rights arena, the Court so far has declined cases which would
further limit the scope of, or find unconstitutional, Section 2 of
the Voting Rights Act, a key remaining protection for minority
voters, and it has revived the racial gerrymandering cause of action
in a way which can help minority plaintiffs fight Republican
gerrymanders. Most recently, the Court surprisingly rejected the
opportunity to use the Elections Clause to kill independent
commission-based congressional redistricting and other electoral
reforms, and it upheld against First Amendment challenge a rule
barring judicial candidates from personally soliciting campaign
contributions.
In this Essay I describe the path of election law jurisprudence in
the Roberts Court and then consider two questions. First, what
explains why the Court, while shifting in a strongly conservative
direction, has not moved more extremely to the right? Second, what
options has the Court left for election reformers who are unhappy
with the strongly conservative, although not maximally conservative,
status quo?
On the first question, a combination of factors appears to explain
the trajectory and speed of the Roberts Court’s election law
decisions. The Roberts Court is fundamentally conservative, but for
jurisprudential, temperamental, or strategic reasons Justices
holding the balance of power appear to prefer incrementalism to
radical change. Mandatory appellate jurisdiction appears the best
way to force the Roberts’ Court’s hand, and it often but not always
leads to a conservative result. Nearly half of the Roberts Court’s
election cases came on mandatory jurisdiction. Progressives
meanwhile have limited the number of cases they present for Court
review to avoid adverse precedent. Finally, the five conservative
Justices are not monolithic in their views and are capable of
surprise, as evidenced by the recent Arizona redistricting decision,
in which Justice Kennedy joined with the Court’s liberals, and the
recent judicial elections case, in which Chief Justice Roberts
joined with the Court’s liberals.
On the second question, the Court has left very limited space for
reform in certain areas, such as campaign finance. Where the Court
has greatly constrained choice, only minor improvements are possible
absent a change in the Supreme Court’s personnel. In these areas,
the problem is not that reformers have a “romanticized” vision of
democracy; it is that the structural impediments erected by the
Court have hobbled meaningful reform efforts. In contrast, in areas
in which the Court has mostly left room for decentralized election
law approaches, such as in the arena election administration,
election fights are becoming both legal and political. Polarization
and decentralization have led to the emergence of “red state
election law” and “blue state election law,” with voting
restrictions increasingly enacted in many Republican-leaning states
but not Democratic-leaning states or states with mixed control.
Part I briefly describes the path of election law in the Roberts era
across key election law areas including campaign finance, voting
rights, and election administration. Part II explains why the
Roberts Court is deeply conservative but not consistently
maximalist. Part III considers the space for election reform in the
Roberts Court era and beyond.
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Posted incampaign finance <http://electionlawblog.org/?cat=10>,Supreme
Court <http://electionlawblog.org/?cat=29>,The Voting Wars
<http://electionlawblog.org/?cat=60>,Voting Rights Act
<http://electionlawblog.org/?cat=15>
“10 Ways Super PACs and Campaigns Coordinate, Even Though They’re
Not Allowed To” <http://electionlawblog.org/?p=76264>
Posted onSeptember 29, 2015 7:41 am
<http://electionlawblog.org/?p=76264>byRick Hasen
<http://electionlawblog.org/?author=3>
National Journal reports.
<http://www.nationaljournal.com/s/73881/10-ways-super-pacs-campaigns-coordinate-even-though-theyre-not-allowed?mref=home>
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Posted incampaign finance <http://electionlawblog.org/?cat=10>,campaigns
<http://electionlawblog.org/?cat=59>
“Big Donors Seek Larger Roles in Presidential Campaigns”
<http://electionlawblog.org/?p=76262>
Posted onSeptember 29, 2015 7:37 am
<http://electionlawblog.org/?p=76262>byRick Hasen
<http://electionlawblog.org/?author=3>
NYT reports.
<http://www.nytimes.com/2015/09/30/us/politics/big-donors-seek-larger-roles-in-presidential-campaigns.html?hp&action=click&pgtype=Homepage&module=photo-spot-region®ion=top-news&WT.nav=top-news&_r=1>
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Posted incampaign finance <http://electionlawblog.org/?cat=10>
“Doubts about new redistricting case”
<http://electionlawblog.org/?p=76260>
Posted onSeptember 28, 2015 4:57 pm
<http://electionlawblog.org/?p=76260>byRick Hasen
<http://electionlawblog.org/?author=3>
Lyle
Denniston<http://www.scotusblog.com/2015/09/doubts-about-new-redistricting-case/>for
SCOTUSBlog:
The Supreme Court on Monday afternoon told lawyers involved in a new
case on the constitutionality of a congressional election district
in Virginia to file new briefs on whether the case can go forward in
the Court. In aone-paragraph order
<http://www.scotusblog.com/wp-content/uploads/2015/09/14-1504-order-for-new-brief-9-28-15.docx>issued
along with two other procedural orders after the first Conference in
advance of the new Term, the Court questioned whether current and
former members of the House had a legal right to pursue their
appeal. The Court has not yet agreed to hear the case, but it is in
a form that would require the Court to act on it if it were properly
filed…..
When the voters who had filed the original lawsuit challenging
District 3 answered the new appeal in the Supreme Court, they argued
that the present and former lawmakers could not show that they had
been injured by the new District 3 and therefore lacked “standing”
to pursue their appeal under the Constitution’s Article III.
The situation appears to parallel what the Supreme Court
confronted two years ago in a California case involving the same-sex
marriage issue. After a federal judge had struck down California’s
“Proposition 8” ban on such marriages, and that ruling had been
upheld by a federal appeals court, Proposition 8’s sponsors — who
had intervened in the case — took it to the Supreme Court. The
state did not pursue an appeal on its own. The Court in that
case,/Hollingsworth v. Perry/, ruled that the sponsors of the ban
did not have standing to appeal when state officials had failed to
do so.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
“FEC employees: a bedraggled lot; Staffers at federal election
regulator give own agency low marks”
<http://electionlawblog.org/?p=76258>
Posted onSeptember 28, 2015 4:41 pm
<http://electionlawblog.org/?p=76258>byRick Hasen
<http://electionlawblog.org/?author=3>
Consistent with what I hear
<http://www.publicintegrity.org/2015/09/28/18078/fec-employees-bedraggled-lot>.
It is really too bad because there are some wonderful people who work
at the agency.
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Posted inelection law biz <http://electionlawblog.org/?cat=51>,federal
election commission <http://electionlawblog.org/?cat=24>
“Of Judges and ‘Wannabes'” <http://electionlawblog.org/?p=76255>
Posted onSeptember 28, 2015 1:46 pm
<http://electionlawblog.org/?p=76255>byRick Hasen
<http://electionlawblog.org/?author=3>
Kate Berry <https://www.brennancenter.org/blog/judges-and-wannabes>at
the Brennan Center:
Should all judicial candidates be treated equally? This question
gripped the Ninth Circuit during/en banc/oral argument
<http://www.ca9.uscourts.gov/media/view_video.php?pk_vid=0000008193>earlier
this month in/Wolfson v. Concannon/.* Plaintiff Randolph Wolfson is
an Arizona lawyer who ran unsuccessfully for judicial office in both
2006 and 2008. Wolfson’s suit alleges that the ethical rules
governing his campaign, found in the Arizona Code of Judicial
Conduct, place unconstitutional restrictions on speech. The trial
court upheld all of the challenged rules, finding in favor of
Defendant the Arizona Commission on Judicial Conduct, but a
three-judge panel of the Ninth Circuitreversed
<http://cdn.ca9.uscourts.gov/datastore/opinions/2014/05/09/11-17634.pdf>.
Defendant successfully sought rehearing/en banc/, which took place
after a stay pending the Supreme Court’s resolution
of/Williams-Yulee v. The Florida//Bar/last spring.
In/Williams-Yulee/, the Courtupheld
<http://www.supremecourt.gov/opinions/14pdf/13-1499_d18e.pdf>Florida’s
ethical rule prohibiting judicial candidates from personally
soliciting campaign contributions.
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Posted injudicial elections <http://electionlawblog.org/?cat=19>
“Remembering Bill Crawford” <http://electionlawblog.org/?p=76253>
Posted onSeptember 28, 2015 1:45 pm
<http://electionlawblog.org/?p=76253>byRick Hasen
<http://electionlawblog.org/?author=3>
Here is a guest post fromJosh Douglas:
<http://law.uky.edu/directory/joshua-a-douglas>
I was saddened to learn of Rep. Bill Crawford’sdeath
<http://electionlawblog.org/?p=76220>last week. I had the
opportunity — and pleasure — to interview Rep. Crawford this past
summer for research for a new book chapter on/The Story of Crawford
v. Marion County Election Board,/which will appear next year
in/Election Law Stories/(Foundation Press 2016). Rep. Crawford, the
lead plaintiff in the voter ID case that went to the Supreme Court,
was gracious, generous with his time, humble, and extremely helpful
for my research. He left quite a legacy.
For those who want to learn more about him, below are several
(draft) paragraphs from the forthcoming chapter that tell the story
of his life and his involvement in the voter ID case.
It is no surprise that William (Bill) Crawford became the lead
plaintiff in the fight over Indiana’s new restrictive photo ID
requirement, particularly given the racial overtones of the debate
and the argument that racial minorities would suffer most under the
law. Crawford was a long-serving Democratic member of the Indiana
House of Representatives who represented the 98^th District, an area
notorious for being one of the poorest in the state. He retired in
2012 after being elected to twenty consecutive terms, leaving the
Indiana House after forty years as the longest-serving black state
lawmaker in U.S. history.
**
Crawford did not foresee dedicating his life to politics. Upon
graduation from high school, the lifelong Indianapolis resident
joined the U.S. Navy, a period of his life that left him “proud to
serve his country, but affected by the blatant racism that was still
prevalent in the military at the time.” Although the U.S. military
was officially desegregated in 1948, opportunities for minority
advancement remained minimal when Crawford joined in 1954. Two
formative experiences involving race occurred during Crawford’s
service. Once, while leading a ship, Crawford “pulled the sleeves on
his uniform up to the elbow, in violation of official protocol,” and
two white men of lesser rank working with Crawford commanded him to
roll them down, an order that Crawford refused. As a result, a Navy
officer ordered a court-martial for Crawford in August 1955 and
handed down a thirty-day stint in the brig in South Carolina – a
sentence Crawford never served.
A few years later, Crawford, who had advanced to the rank of a
Radarman Third Class, traveled to Norfolk, Virginia to sit for the
second-class status exam. Prior to the assessment, an officer
remarked to Crawford, “I don’t think blacks can lead whites . . . .
I’m not going to allow you to take the test.” Crawford appealed the
rejection to a captain, who agreed that the decision was wrong but
supported the offending officer’s refusal anyway. Crawford left the
Navy shortly after this incident, claiming that his experience in
the military and the racism he encountered “helped frame [his]
commitment to protest” and “taught [him] discrimination [and] . . .
. the rules of the game and how to fight and that fighting is done
in the right way.”
After leaving the U.S. Navy in 1958, Crawford joined the U.S. Postal
Service, where he was in charge of handling sensitive cargo and mail
transported by train. Crawford was still working as a mail carrier
in 1968 when civil rights leader Martin Luther King, Jr. was
assassinated. King’s death was “a very traumatic experience” for
Crawford, and the then thirty-two-year-old military veteran, who was
simultaneously working and attending the Indiana College of Business
and Technology under the GI Bill, dropped out of school and left the
post office to become involved in various community organizations.
Activist Charles “Snookie” Hendricks hired Crawford to work at the
Radical Black Action Bookstore, which sold materials aimed at
empowering the black community.
Additionally, Crawford joined an urban union of black activists,
through which he became acquainted with then-state representative
and future Congresswoman Julia Carson. In 1972, on the last day of
filing for candidacy, Carson called Crawford to ask him to run for
state representative because a lawyer slotted to run for one of the
three seats given to Indianapolis districts at that time had backed
out. Crawford agreed and was elected to the Indiana House after
running on a platform of accountability, justice, and neighborhood
development.
Shortly after taking office in 1973, Crawford was assigned to the
budget-writing House Ways and Means Committee. Although Crawford’s
primary role on this committee was to protect the state’s fiscal
health, he focused in particular on meeting the needs of the state’s
underserved populations. For instance, he was proud of his ability
to direct the allocation of over $30 million in state funds to
research minority health issues.
Outside of his appointment to the Ways and Means Committee, Crawford
made various other contributions to minority groups and other
underrepresented constituencies. In the 1970s, Crawford secured
restitution from the state budget for two men who served time in
prison after being wrongly convicted. In 1976, Crawford introduced
legislation that called for the creation of district-specific seats
on the Board of Commissioners for Indianapolis Public Schools.
Crawford’s law resulted in the board having two at-large seats and
five from districts around the city – which had the effect of
providing greater geographic diversity and more opportunities for
minority candidates to win a seat. In 1987, Crawford championed a
bill that instituted a minority teacher scholarship program. Two
years later he authored legislation that created the Low Income
Housing Trust Fund. In 1993, he succeeded in passing the Minority
Teacher’s Scholarship Fund, which provided a grant of up to $16,000
for African-American and Latino teachers who agreed to work locally
in Indiana. Crawford also authored legislation, of which he is “most
proud,” that helped make Indiana the thirteenth state to prohibit
the execution of mentally ill individuals.
In addition to his legislative duties, Crawford also led major
cultural institutions, twice serving as the president of the Indiana
Black Expo. He was also the manager of outreach for Ivy Tech
Community College of Indiana. Ivy Tech provides higher education
opportunities to non-traditional students who do not immediately go
to college after high school, minority groups, and those with
financial difficulties. It now educates more African-American
students than any other institution in Indiana; over half of all
African-Americans who attend post-secondary school in Indiana go to
an Ivy Tech campus. Crawford believed that education was important
to civil rights and that “empowerment of people is the greatest
thing you can do for economic development.” As Jeff Terp, a Senior
Vice President at Ivy Tech, noted, “He sees every day that there are
those that are poor and minority that don’t have equal access, and
he want[s] equal access.”
With respect to the photo ID law, Crawford, as a civil rights
advocate, considered Indiana’s bill to be “patently offensive.” He
agreed to serve as the lead plaintiff in the lawsuit because, as he
put it, “I was willing and involved in the debate in the House. So I
was simply the right person at the time.” During the litigation
itself, Crawford remained engaged by rallying support and finding
individuals and organizations that would file amicus briefs on his
behalf.
As Joe Simpson, the other lead plaintiff, said of Crawford’s
involvement, “Someone had to step up to the plate, and
Representative Crawford was the right person to do it. He had no
fear of speaking up for those who could not speak for themselves.”
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Posted inThe Voting Wars <http://electionlawblog.org/?cat=60>,voter id
<http://electionlawblog.org/?cat=9>
More Evenwel Amicus Briefs <http://electionlawblog.org/?p=76248>
Posted onSeptember 28, 2015 1:39 pm
<http://electionlawblog.org/?p=76248>byRick Hasen
<http://electionlawblog.org/?author=3>
Brief of Hawaii Reapportionment Plaintiffs
<http://electionlawblog.org/wp-content/uploads/282716538-Brief-of-Hawaii-Reapportionment-Plaintiffs-David-Brostrom-Andrew-Walden-as-Amici-Curiae-Supporting-Appellees-Evenwel-v-0085691.pdf>
Fair Elections Legal Network
<http://fairelectionsnetwork.com/wp-content/uploads/Evenwel-Amicus-Brief.pdf>
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
“Why The Most Urgent Civil Rights Cause Of Our Time Is The Supreme
Court Itself” <http://electionlawblog.org/?p=76246>
Posted onSeptember 28, 2015 7:39 am
<http://electionlawblog.org/?p=76246>byRick Hasen
<http://electionlawblog.org/?author=3>
I have writtenthis longread for TPM,
<http://talkingpointsmemo.com/cafe/supreme-court-greatest-civil-rights-cause>and
I’ve been working on it for quite some time. It begins:
The future composition of the Supreme Court is the most important
civil rights cause of our time. It is more important than racial
justice, marriage equality, voting rights, money in politics,
abortion rights, gun rights, or managing climate change. It matters
more because the ability to move forward in these other civil rights
struggles depends first and foremost upon control of the Court. And
control for the next generation is about to be up for grabs, likely
in the next presidential election, a point many on the right but few
on the left seem to have recognized.
When the next President of the United States assumes office on
January 20, 2017, Justice Ruth Bader Ginsburg will be nearly 84,
Justices Antonin Scalia and Anthony Kennedy will be over 80, and
Justice Stephen Breyer will be 78. Although many Justices have
served on the Court into their 80s and beyond, the chances for all
of these Justices remaining through the next 4 or 8 years of the
45th President are slim. Indeed, the next president will likely make
multiple appointments to the Court.
The stakes are high. On non-controversial cases, or cases where the
ideological stakes are low, the Justices often agree and are
sometimes unanimous. In such cases, the Justices act much like lower
court judges do, applying precedents, text, history, and a range of
interpretative tools to decide cases. In the most controversial
cases, however—those involving issues such as gun rights,
affirmative action, abortion, money in politics, privacy, and
federal power—the value judgments and ideology of the Supreme Court
Justices, and increasingly the party affiliation of the president
appointing them, are good predictors of each Justice’s vote.
A conservative like Justice Scalia tends to vote to uphold abortion
restrictions, strike down gun restrictions, and view the First
Amendment as protecting the right to spend unlimited sums in
elections. A liberal like Justice Ginsburg tends to vote the
opposite way: to strike down abortion restrictions, uphold gun laws,
and view the government’s interest in stopping undue influence of
money in elections as justifying some limits on money in politics.
This to not to say it is just politics in these cases, or that these
Justices are making crassly partisan decisions. They’re not. It is
that increasingly a Justice’s ideology and jurisprudence line up
with one political party’s positions or another because Justices are
chosen for that very reason.
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Posted incampaign finance <http://electionlawblog.org/?cat=10>,Supreme
Court <http://electionlawblog.org/?cat=29>,Voting Rights Act
<http://electionlawblog.org/?cat=15>
--
Rick Hasen
Chancellor's Professor of Law and Political Science
UC Irvine School of Law
401 E. Peltason Dr., Suite 1000
Irvine, CA 92697-8000
949.824.3072 - office
949.824.0495 - fax
rhasen at law.uci.edu
hhttp://www.law.uci.edu/faculty/full-time/hasen/
http://electionlawblog.org
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