[EL] ELB News and Commentary 4/4/16
Rick Hasen
rhasen at law.uci.edu
Mon Apr 4 09:39:28 PDT 2016
“Citizens United and the Foreign Question”
<http://electionlawblog.org/?p=81495>
Posted onApril 4, 2016 9:35 am
<http://electionlawblog.org/?p=81495>byRick Hasen
<http://electionlawblog.org/?author=3>
NYT letters to the editor
<http://www.nytimes.com/2016/04/04/opinion/citizens-united-and-the-foreign-question.html>on
FEC CommissionerWeintraub’s NYT oped.
<http://www.nytimes.com/2016/03/30/opinion/taking-n-citizens-united.html>
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Posted incampaign finance <http://electionlawblog.org/?cat=10>,federal
election commission <http://electionlawblog.org/?cat=24>
“Why are so many Democrats and Republicans pretending to be
independents?” <http://electionlawblog.org/?p=81493>
Posted onApril 4, 2016 9:34 am
<http://electionlawblog.org/?p=81493>byRick Hasen
<http://electionlawblog.org/?author=3>
John Sides
<https://www.washingtonpost.com/news/monkey-cage/wp/2016/04/04/why-are-so-many-democrats-and-republicans-pretending-to-be-independents/>for
the Monkey Cage.
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Posted inpolitical parties <http://electionlawblog.org/?cat=25>
“Court upholds total population count in electoral districts”
<http://electionlawblog.org/?p=81491>
Posted onApril 4, 2016 9:30 am
<http://electionlawblog.org/?p=81491>byRick Hasen
<http://electionlawblog.org/?author=3>
Mark Sherman reports
<http://www.bigstory.ap.org/article/df4b7b12fdc94bd593b9fcb77387b6e6/court-upholds-total-population-count-electoral-districts>for
AP.
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
“Court Denies Review in Campaign Finance Case”
<http://electionlawblog.org/?p=81489>
Posted onApril 4, 2016 9:28 am
<http://electionlawblog.org/?p=81489>byRick Hasen
<http://electionlawblog.org/?author=3>
Ron Collins:
<http://concurringopinions.com/archives/2016/04/fan-102-3-first-amendment-news-court-denies-review-in-campaign-finance-case.html>
Today the Court issued itsorders list
<http://www.supremecourt.gov/orders/courtorders/040416zor_5i36.pdf>in which
the Justices declined to hear the case of /Justice v.
<http://www.scotusblog.com/case-files/cases/justice-v-hosemann/>_Houseman_./
The issue in the case was whether Mississippi can, consistent with
the First Amendment, prohibit a small informal group of friends and
neighbors from spending more than $200 on pure speech about a ballot
measure unless they become a political committee, adopt the formal
structure required of a political committee, register with the
state, and subject themselves to the full panoply of ongoing
record-keeping, reporting, and other obligations that attend status
as a political committee.
→ The cert. petition was filed by the Institute for Justice with
Paul Avelar as counsel of record for the Petitioners.
→ The Center for Competitive Politics (Allen Dickerson), the Cato
Institute (Ilya Shapiro), and the Independence Institute filed
anamicus
brief<http://www.scotusblog.com/wp-content/uploads/2015/12/151209-for-filing.pdf>on
behalf of the Petitioners.
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Posted incampaign finance <http://electionlawblog.org/?cat=10>
“This Is How Hard It Is To Get A Voter ID In Wisconsin”
<http://electionlawblog.org/?p=81487>
Posted onApril 4, 2016 9:23 am
<http://electionlawblog.org/?p=81487>byRick Hasen
<http://electionlawblog.org/?author=3>
Important Alice Ollstein
<http://thinkprogress.org/politics/2016/04/02/3765448/wisconsin-primary-voter-id/>for
Think Progress.
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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>
“The Definitely Messy, Probably Solvable Reasons Americans Don’t
Vote” <http://electionlawblog.org/?p=81484>
Posted onApril 4, 2016 9:16 am
<http://electionlawblog.org/?p=81484>byRick Hasen
<http://electionlawblog.org/?author=3>
Bloomberg reports.
<http://www.bloomberg.com/politics/graphics/2016-non-voters/?cmpid=BBD040416_POL&utm_medium=email&utm_source=newsletter&utm_campaign=>
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Posted invoting <http://electionlawblog.org/?cat=31>
“Is There a Better Way to Vote, Post-Trump?”
<http://electionlawblog.org/?p=81482>
Posted onApril 4, 2016 9:14 am
<http://electionlawblog.org/?p=81482>byRick Hasen
<http://electionlawblog.org/?author=3>
Andrew McGill
<http://www.theatlantic.com/politics/archive/2016/04/ranked-voting-donald-trump-primary-instant-runoff/476670/>at
the Atlantic.
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Posted inalternative voting systems <http://electionlawblog.org/?cat=63>
“Could Republican Convention delegates be bought? Legally, maybe”
<http://electionlawblog.org/?p=81479>
Posted onApril 4, 2016 8:46 am
<http://electionlawblog.org/?p=81479>byRick Hasen
<http://electionlawblog.org/?author=3>
CNN has this report.
<http://www.cnn.com/2016/04/04/politics/contested-convention-bribing-delegates/index.html>
I’d be careful with this analysis, and point readers to this fascinating
Brian Svoboda
<https://www.lawandpoliticsupdate.com/2016/03/bribery-and-the-brokered-convention-2/> post.on
whether RNC delegates at a contested convention could be bribed.
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Posted inbribery <http://electionlawblog.org/?cat=54>,chicanery
<http://electionlawblog.org/?cat=12>,political parties
<http://electionlawblog.org/?cat=25>,primaries
<http://electionlawblog.org/?cat=32>
Evenwel: Misguided Hysteria, Done With
<http://electionlawblog.org/?p=81462>
Posted onApril 4, 2016 7:30 am
<http://electionlawblog.org/?p=81462>byRichard Pildes
<http://electionlawblog.org/?author=7>
Immediately after the Court agreed to hear the/Evenwel/case, I posted
anessay
<http://www.scotusblog.com/2015/07/symposium-misguided-hysteria-over-evenwel-v-abbott/>on
the Supreme Court blog arguing that the extreme overreactions and that
were already emerging over the Court’s decision to address this issue
from journalists and some academic commentators were deeply misguided.
As I argued then, the Court was right to take the case, to address these
long unresolved issues, and when the Court did so, I thought there was
little doubt the Court would continue to permit State to use total
population for districting.
Today’s decision fully vindicates those views. The Court unanimously
upheld the authority of states to use total population. In addition, a
six-member majority went out of its way to make clear that the question
remains fully open whether states might be/required/to use population,
rather than eligible voters. As the text of the majority opinion says
in its final paragraphs:”Because history, precedent, and practice
suffice to reveal the infirmity of appel-lants’ claims, we need not and
do not resolve whether, as Texas now argues, States may draw districts
to equalize voter-eligible population rather than total population.”
The only hard question in this case, as I’ve said throughout, is whether
the Court should conclude that the total population standard is not just
permitted, but required. I was glad to see the Court made clear that
that is a question that is left open for another day, should the issue
ever actually arise — as it would if a jurisdiction ever did decide to
use eligible voters as the baseline and doing so caused significant
deviations from equality based on population.
All in all, an overwhelming consensus in the Court for the
straightforward resolution of the issue, despite the wildly exaggerated
fears that had been stoked up about this case.
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Posted inUncategorized <http://electionlawblog.org/?cat=1>
Breaking/Analysis: Big Victory for Voting Rights as #SCOTUS Rejects
Plaintiffs’ Claim in Evenwel One Person, One Vote Case
<http://electionlawblog.org/?p=81460>
Posted onApril 4, 2016 7:15 am
<http://electionlawblog.org/?p=81460>byRick Hasen
<http://electionlawblog.org/?author=3>
A unanimous Supreme Court in/Evenwel v. Abbott/ (with two Justices
(Thomas and Alito) concurring in the judgment)has rejected the argument
<http://www.supremecourt.gov/opinions/15pdf/14-940_ed9g.pdf>that states
must draw district lines so as to equalize the total number of voters
(as opposed to total population) in redistricting. A contrary ruling
would have shifted power to Republican, rural districts, and away from
Democratic urban areas (because non-citizens and children, especially in
Latino areas in states such as Texas would be in Democratic areas).
Most importantly, in a big victory for the federal government’s
position in the litigation, the Court did not say that a state can
simply choose between doing total population or total voters in how
district lines are drawn. Some expected that if the Court gave Texas the
green light to choose, as Texas argued it had the right to do in this
litigation, then in the next round of redistricting, it would have done
so in order to increase the number of Republican districts in the state.
Justice Ginsburg wrote the opinion for the Court, and it is clear (as I
had been saying <http://electionlawblog.org/?p=77988>) that Justice
Scalia’s death did not affect the outcome of this case. It was clear
from the oral argument that, despite what some said, this was not a case
where the Court was likely to divide 4-4. Ed Blum’s position in this
case to require voter population was not only at odds with historical
practice, it was not practically possible given the data that we have,
and it would have led to terrible outcomes, including making it
basically impossible to also comply with Voting Rights Act requirements
for districts.
Justice Ginsburg’s opinion holds that districting using total population
was consistent with constitutional history, the Court’s own decisions,
and longstanding practice. A long section of Justice Ginsburg’s opinion
recounts constitutional history, and relies on the fact that for
purposes of apportioning Congressional seats /among/states, total
population, not total voters, must be used. Plaintiffs’ argument in
/Evenwel/was inconsistent with this practice. As to the Court’s own
precedents, Justice Ginsburg acknowledged language supporting both total
voters and total population as possible bases, but Court’s practice has
been to look at total population in its cases. Further, that is the
practice that states uniformly use, despite the occasional case such as
/Burns v. Richardson/, allowing Hawaii to use a registered voter level.
Finally, Justice Ginsburg gives a sound policy reason for a total
population rule. In key language, she writes that “Nonvoters have an
important stake in many policy debates—children,, their parents, even
their grandparents, for example, have a stake in a strong
public-education system—and in receiving constituent services, such as
help navigating public-benefits bureaucracies. By ensuring that each
representative is subject to requests and suggestions from the same
number of constituents, total population apportionment promotes
equitable and effective representation.” A footnote following this
states that even though constituents “have no constitutional right to
equal access to the their elected representatives,” a state “certainly
has an interest in taking reasonable, nondiscriminatory steps to
facilitate access for all its residents.”
Perhaps the most important aspect of Justice Ginsburg’s opinion, and
especially notable because it attracted the votes of not just the
liberals but also Chief Justice Roberts and Justice Kennedy, is the
Court’s refusal to give Texas the green light to use total voters if it
wants in the next round of redistricting. The Court simply put the issue
off for another day. It is hard to stress enough what a victory this is
for liberal supporters of voting rights. Many of us
thought/Burns/already gave Texas this power. The fact that the Court
leaves that issue open will serve as a deterrent for states like Texas
to try to use total voters in the next round of redistricting, because
it will guarantee major litigation on the question.
One notable aspect of Justice Ginsburg’s opinion is that it seeks to
provide some clarity about when perfect equality is required and when it
is not. Interesting, the Court ignores the /Tennant/case, which seemed
to allow some deviation from perfect equality even in Congressional
district cases, and seems to restore a 10% safe harbor for state and
local redistricting. (See pages 3-4.) As Derek Muller points out on
Twitter, this is a bad sign for the plaintiffs in the pending
/Harris/case from Arizona, although the Court could still hold that the
10% safe harbor does not apply when there is proof of partisan motive in
deviating from perfect equality.
The concurring opinions coming from Justices Thomas and Alito are not
surprising. Years earlier, Thomas dissented from the Court’s refusal to
hear an earlier case on this question. Back when Alito applied to work
at the Justice Department, he mentioned in his application his
disagreement with the Warren Court one person, one vote cases. Justice
Thomas, quite radically given the last 50 years, suggests there is no
basis for a one person, one vote principle at all. This strikes me,as
I’ve written, as a sound conservative argument,
<http://www.scotusblog.com/2015/07/symposium-ideology-partisanship-and-the-new-one-person-one-vote-case/>unlikeEd
Blum’s argument
<http://www.slate.com/articles/news_and_politics/jurisprudence/2015/05/evenwel_v_abbott_supreme_court_case_state_districts_count_voters_or_total.html>in
Evenwel which would have restricted states even further in their choice
of one person, one vote rules. I suspect that Justice Scalia could have
concurred in Justice Thomas’s opinion.
Justice Alito does not go as far as Justice Thomas. Relying heavily on
historical analysis, he would hold that a state can use total
population, but casts serious doubts on the question (not reached by the
majority) as to whether it must. He says the question whether a state
could use some other measure “is an important and sensitive question
that we can consider if and when we have before us a state districting
plan that, unlike the current Texas plan, uses something other than
total population as the basis for equalizing the size of districts.”
This was never a close case, as judged by the unanimous rejection of Ed
Blum’s position in this case. So why did the Court take it? As I’ve
suggested inmy forthcoming /Stanford Law Review /piece,
<http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2639902> the Court
likely took this case for a purely technical reason: Ed Blum managed to
maneuver it to come before a three judge district court with direct
appeal to the Supreme Court. In those cases, a decision by the Court not
to hear the case and to simply affirm is treated as a judgment that the
Supreme Court agrees with the lower court result (though not necessarily
its reasoning). The Chief Justice and others have said they feel
compulsion to take these cases, as they are often reluctant to endorse a
result without a full examination.
It might be said that liberals dodged a bullet. But as I’ve said since
the beginning, this bullet was never close to hitting its victim.
/This post has been updated./
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Posted inredistricting <http://electionlawblog.org/?cat=6>,Supreme Court
<http://electionlawblog.org/?cat=29>
“Trump, Cruz Work to Block Kasich From Ballot at Open Convention”
<http://electionlawblog.org/?p=81458>
Posted onApril 3, 2016 3:27 pm
<http://electionlawblog.org/?p=81458>byRick Hasen
<http://electionlawblog.org/?author=3>
NBC News:
<http://www.nbcnews.com/politics/2016-election/trump-cruz-work-block-kasich-ballot-open-convention-n549996>
While Trump and Cruz are locked in a bitter battle, aides to both
men tell msnbc it is in their mutual interest to keep Kasich off the
ballot. The convention rules control who is on that ballot — and
thus eligible to win the nomination.
“I expect the Rules Committee to require a level of support that
would leave only two candidates on the ballot at the convention,” a
senior Cruz Campaign aide told msnbc.
That committee, which writes the rules governing an open convention,
is made up of 112 Republican delegates from around the country.
Operatives for Cruz and Trump say they will have major sway over
what the committee does.
“The Cruz people and Trump people are fighting hard to make sure
their hard-core delegates get on the committee,” said Barry Bennett,
a Trump adviser.
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Posted inpolitical parties
<http://electionlawblog.org/?cat=25>,primaries
<http://electionlawblog.org/?cat=32>
“Republicans on FEC suggest they may scrutinize mystery corporate
donors” <http://electionlawblog.org/?p=81456>
Posted onApril 3, 2016 2:37 pm
<http://electionlawblog.org/?p=81456>byRick Hasen
<http://electionlawblog.org/?author=3>
Matea Gold for WaPo
<https://www.washingtonpost.com/politics/republicans-on-fec-suggest-they-may-scrutinize-mystery-corporate-donors/2016/04/03/f8abc394-f9b8-11e5-80e4-c381214de1a3_story.html>:
The three Republican appointees on the divided Federal Election
Commission have indicated that political donors who give through
private companies solely to shield their identities can be
sanctioned, signaling that the agency may scrutinize a rash of
“pop-up” corporations giving large sums to super PACs.
Their stance suggests the potential for movement by the polarized
six-person panel, where a sense of stasis has been the norm.
Democratic commissioners, however, reacted with skepticism, saying
their GOP colleagues have until now delayed and actively blocked
examination of such cases.
But Lee Goodman, one of the Republican commissioners, said in an
interview that contributors seeking to mask themselves through a
privately held company or limited-liability corporation should think
twice.
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Posted incampaign finance <http://electionlawblog.org/?cat=10>,federal
election commission <http://electionlawblog.org/?cat=24>
“Bromance between Kris Kobach and Brian Newby leads to attack on
voting rights” <http://electionlawblog.org/?p=81454>
Posted onApril 2, 2016 8:05 pm
<http://electionlawblog.org/?p=81454>byRick Hasen
<http://electionlawblog.org/?author=3>
KC Star editorial:
<http://www.kansascity.com/opinion/editorials/article69509812.html>
Take a look at the email Newby sent in June to Kobach: “I think I
would enter the job empowered to lead the way I want to.”
And there was this communication from Newby to the Kansas secretary
of state: “I wanted you in the loop, in part because of other issues
in the past with the (Election Assistance Commission). I also don’t
want you thinking that you can’t count on me in an upcoming period
that will tax our resources.”
Then, bingo, early this year came the restrictive decision by Newby.
In retrospect, the close ties between the two men make it appear
that Newby went to Washington and decided to impose some ugly
Kobach-style restrictions that could affect the voting rights of
thousands of Americans.
Yes, including some of those back in Kansas, the home state of both men.
All of this is frustrating for the people who have worked so hard
across this country to battle the wrongheaded notion that voting
rules must be tightened because voter fraud is “rampant.”
That’s Kobach’s siren song to the ultra-conservative crowd in Kansas
that has elected him to office. It’s how he got his powers to
prosecute voter fraud, powers he’s used so far to almost comically
limited effect.
That’s because there is no widespread voter fraud. It’s a dangerous
byproduct of Kobach’s ideological imagination.
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Posted inelection administration
<http://electionlawblog.org/?cat=18>,The Voting Wars
<http://electionlawblog.org/?cat=60>
“Jury: Wittich violated campaign finance laws”
<http://electionlawblog.org/?p=81452>
Posted onApril 2, 2016 5:26 pm
<http://electionlawblog.org/?p=81452>byRick Hasen
<http://electionlawblog.org/?author=3>
AP
<http://www.greatfallstribune.com/story/news/local/2016/04/01/jury-deliberates-montana-lawmakers-dark-money-case/82536544/>:
A jury found Friday that a Montana lawmaker coordinated with and
received services from conservative corporate groups in violation of
state campaign laws, a ruling that could lead to his removal from
office and bolster the state’s defense of its low campaign
contribution limits.
Rep. Art Wittich, R-Bozeman, took $19,599 worth in-kind
contributions that he didn’t disclose from organizations affiliated
with the National Right to Work Committee during his 2010 campaign,
the jury found. The contributions included campaign consulting,
direct mail, voter data, opposition research, website design and
attack ads against his opponent.
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Posted incampaign finance <http://electionlawblog.org/?cat=10>,chicanery
<http://electionlawblog.org/?cat=12>
WaPo Fact Checker Gives Sanders 3 Pinocchios on Clinton Fossil Fuel
Claim <http://electionlawblog.org/?p=81450>
Posted onApril 2, 2016 6:13 am
<http://electionlawblog.org/?p=81450>byRick Hasen
<http://electionlawblog.org/?author=3>
Kessler
<https://www.washingtonpost.com/news/fact-checker/wp/2016/04/02/fact-checking-the-clinton-sanders-spat-over-big-oil-contributions/>:
The Sanders campaign is exaggerating the contributions that Clinton
has received from the oil and gas industry. In the context of her
overall campaign, the contributions are hardly significant. It’s
especially misleading to count all of the funds raised by lobbyists
with multiple clients as money “given” by the fossil-fuel industry.
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Posted incampaign finance <http://electionlawblog.org/?cat=10>,campaigns
<http://electionlawblog.org/?cat=59>
--
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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