[EL] ELB News and Commentary 12/7/16

Tue Dec 6 21:00:11 PST 2016

Time Warner CEO Jeff Bewkes: Democrats, not Donald Trump, are the real ‘threat to the First Amendment’”<http://electionlawblog.org/?p=89766>
Posted on December 6, 2016 8:55 pm<http://electionlawblog.org/?p=89766> by Rick Hasen<http://electionlawblog.org/?author=3>
ReCode:<http://www.recode.net/2016/12/6/13861950/trump-jeff-bewkes-time-warner-first-amendment-citizens-united-democrats>
Don’t worry about Donald Trump and the First Amendment, says Time Warner CEO Jeff Bewkes: He won’t harm it, despite a campaign promise to “open up” libel laws, and a tweet proposing to strip flag-burners of their citizenship.
But Bewkes, who runs one of the world’s biggest media companies, says you shouldbe worried about the Democratic Party, because its 2016 campaign posed a “threat to the First Amendment.”
Speaking at Business Insider’s Ignition conference, Bewkes said Democrats “had a campaign plank to change the First Amendment … in the guise of campaign finance reform.”
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Posted in campaign finance<http://electionlawblog.org/?cat=10>

“What Jill Stein really wants is an audit, not a recount”<http://electionlawblog.org/?p=89764>
Posted on December 6, 2016 8:53 pm<http://electionlawblog.org/?p=89764> by Rick Hasen<http://electionlawblog.org/?author=3>
Business Insider:<http://finance.yahoo.com/news/jill-stein-really-wants-audit-220900923.html>
So why is she putting time and a lot of money<http://www.businessinsider.com/wisconsin-recount-faqs-who-will-win-jill-stein-donald-trump-hillary-clinton-2016-12/> into a recount? In a rally outside of Trump Tower yesterday<https://www.facebook.com/drjillstein/videos/1392097814163738/>, Stein said she was hoping this recount would ensure this election was accurate, secure and just — a cause that’s found support among some people in the wake of several high-profile hacking incidents during the campaign.
“Given that she states her goal is accuracy and verification, that sounds like the language for an audit,” Ned Foley, the director of Election Law at Moritz at Ohio State’s law school tells Business Insider. “She’s calling for a recount to perform the function of an audit.”
Voting experts are making the distinction between a recount and an audit, explaining that a recount is simply a re-tabulation of the votes cast. An audit, on the other hand, would verify that systems were functioning properly.
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Posted in election administration<http://electionlawblog.org/?cat=18>

“Courts Disagree Over Michigan Vote Recount”<http://electionlawblog.org/?p=89762>
Posted on December 6, 2016 8:47 pm<http://electionlawblog.org/?p=89762> by Rick Hasen<http://electionlawblog.org/?author=3>
NYT:<http://www.nytimes.com/2016/12/06/us/politics/michigan-vote-recount.html?_r=0>
Dueling court rulings left the fate of a presidential vote recount in Michigan uncertain on Tuesday night, and elections officials in the state said they were “seeking clarity about the next steps.”
A recount of last month’s election had already begun in parts of Michigan, one of three closely contested states where Jill Stein<http://www.nytimes.com/topic/person/jill-stein?inline=nyt-per>, the Green Party’s presidential nominee, had called for new counts, when the seemingly conflicting legal decisions emerged late Tuesday from state and federal courts in Michigan. Ms. Stein has cited concerns about computer hacking and the reliability of voting machines, setting off legal fights with lawyers for President-elect Donald J. Trump<http://www.nytimes.com/topic/person/donald-trump?inline=nyt-per>, his campaign and his allies, who view the recounts as a needless and expensive tactic.
A panel of the Michigan Court of Appeals found that Ms. Stein, who finished a distant fourth to Mr. Trump in the election, had not met the state’s requirements for a recount because she had no chance of winning. The panel concluded that the Michigan Board of State Canvassers ought not to have permitted a recount to go forward because Ms. Stein, given the size of the vote for her, could not be deemed “aggrieved,” as required for a recount under state election law.
Yet in a separate decision, also announced late Tuesday, a federal appeals court turned down requests from the state’s Republican Party and from Bill Schuette, the state’s attorney general, to block a federal court ruling that had cleared the way for the recount to proceed more swiftly than expected.
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Posted in election administration<http://electionlawblog.org/?cat=18>, recounts<http://electionlawblog.org/?cat=50>

“Schneiderman Says Flawed Election Procedures Marred State’s Primary”<http://electionlawblog.org/?p=89760>
Posted on December 6, 2016 8:45 pm<http://electionlawblog.org/?p=89760> by Rick Hasen<http://electionlawblog.org/?author=3>
WSJ:<http://www.wsj.com/articles/schneiderman-says-flawed-election-procedures-marred-states-primary-1481052913>
New York state Attorney General Eric Schneiderman said Tuesday that flawed election procedures and laws led to what he called an unprecedented number of voting complaints during the state’s April presidential primary.
In announcing the results of his inquiry into voting complaints, Mr. Schneiderman said his office’s voter hotline received 1,500 calls around the primary, “10 times the previous high mark.”
About two-thirds of the complaints stemmed from barriers created by voter-registration rules and practices, he said. Twenty percent of the complaints involved rules or laws related to the voting process, such as reduced poll hours in some counties and voters confused about polling places that had moved.
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Posted in election administration<http://electionlawblog.org/?cat=18>

“Trump’s Lies About Voter Fraud Are Already Leading to New GOP Voter-Suppression Efforts”<http://electionlawblog.org/?p=89758>
Posted on December 6, 2016 8:36 pm<http://electionlawblog.org/?p=89758> by Rick Hasen<http://electionlawblog.org/?author=3>
Ari Berman writes<https://www.thenation.com/article/trumps-lies-about-voter-fraud-are-already-leading-to-new-gop-voter-suppression-efforts/> for The Nation.
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Posted in election administration<http://electionlawblog.org/?cat=18>, fraudulent fraud squad<http://electionlawblog.org/?cat=8>, The Voting Wars<http://electionlawblog.org/?cat=60>

“Bethune-Hill & McCrory: If Either Party Wins, We All Lose”<http://electionlawblog.org/?p=89756>
Posted on December 6, 2016 8:34 pm<http://electionlawblog.org/?p=89756> by Rick Hasen<http://electionlawblog.org/?author=3>
Mike Parsons<https://moderndemocracyblog.com/2016/12/06/if-either-party-wins-we-all-lose/> on yesterday’s racial gerrymandering arguments.
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Posted in redistricting<http://electionlawblog.org/?cat=6>, Supreme Court<http://electionlawblog.org/?cat=29>

“SCOTUS hearing VA & NC Gerrymandering cases today. Suffice to say, Racial Gerrymandering in Deep South states is even worse”<http://electionlawblog.org/?p=89754>
Posted on December 6, 2016 4:46 pm<http://electionlawblog.org/?p=89754> by Rick Hasen<http://electionlawblog.org/?author=3>
Dan Smith:<https://electionsmith.wordpress.com/2016/12/05/scotus-hearing-gerrymandering-cases-from-va-and-nc-today-suffice-to-say-racial-gerrymandering-in-deep-south-states-is-even-worse/>
Today, the Supreme Court is hearing arguments in gerrymandering cases from North Carolina and Virginia. Plaintiffs claim that GOP lawmakers in the two states excessively packed black voters into congressional and state legislative districts, thus diluting the influence of black voters. Attorneys for the majority lawmakers, in contrast, claim they are merely complying with provisions of the Voting Rights Act by creating majority-minority districts to enhance the representation of minority voters.
However the Court rules, it is important that context matters when drawing minority access districts. My colleagues (Will Hicks, Appalachian State; Carl Klarner, University of Florida; Seth McKee, Texas Tech) have a paper<https://electionsmith.files.wordpress.com/2016/12/prq-hkms-draft.pdf> that examines the likelihood of electing African Americans to state legislatures, comparing the threshold of black voting age population needed to elect a black lawmaker in Southern and Non-Southern states over time. We also look across states within the South. Suffice to say, there’s a considerable difference across regions, and even within the South, of how packed a district needs to be in order for voters to have the ability to elect an African American to the state legislature.
We find that the black population threshold required for a Deep South (Louisiana, Mississippi, Alabama, Georgia, South Carolina) state legislative district to elect a black lawmaker is significantly higher than the black population threshold in districts in Rim South or Non-South states….
Beyond the pressing normative views regarding the broader political and representational implications of the relationship between majority-minority districts and black representation, our empirical analysis indicates an inexorable dynamic in party politics. Our findings leave no doubt that a considerable reduction in majority-minority state legislative district populations can be accomplished while ensuring black descriptive representation. In light of the Supreme Court’s 2013 decision in Shelby County v. Holder, which scrapped the federal enforcement of the Section 5 preclearance provision of the Voting Rights Act, we expect in the next decennial round of redistricting most Democrats will push for a reduction in the size of minority populations in majority-minority districts, while almost every Republican will continue to insist that majority-black districts should remain as is, or better yet, contain even higher African-American populations.
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Posted in redistricting<http://electionlawblog.org/?cat=6>, Supreme Court<http://electionlawblog.org/?cat=29>

“Redistricting and Representation Drawing Fair Election Districts Instead of Manipulated Maps”<http://electionlawblog.org/?p=89752>
Posted on December 6, 2016 4:43 pm<http://electionlawblog.org/?p=89752> by Rick Hasen<http://electionlawblog.org/?author=3>
New report<https://www.americanprogress.org/issues/democracy/reports/2016/12/05/294272/redistricting-and-representation/> from CAP.
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Posted in redistricting<http://electionlawblog.org/?cat=6>

“Civil Rights Organizations Applaud Timely Release by Census Director Identifying Jurisdictions that Must Provide Language Assistance under Section 203 of Voting Rights Act”<http://electionlawblog.org/?p=89749>
Posted on December 6, 2016 4:40 pm<http://electionlawblog.org/?p=89749> by Rick Hasen<http://electionlawblog.org/?author=3>
Release:<http://electionlawblog.org/wp-content/uploads/FINAL-Joint-Press-Release-203-12.2016.pdf>
On December 5, 2016, the Director of the U.S. Census Bureau issued a notice of determination identifying the jurisdictions subject to the language assistance provisions of Section 203 of the Voting Rights Act, which are available at 81 Federal Register 87532. The new Section 203 determinations, which are described in detail in the Voting Rights Act Coverage Update, replace the previous Section 203 determinations made in October 2011.
Key features of the new determinations include the following:
• The number of states covered in whole or in part by Section 203 has increased from 25states to 29.
• All of the states previously covered in part continue to be covered, and four new states earned partial coverage since 2011: Georgia, Idaho, Iowa, and Oklahoma.
• Los Angeles County, California, continues to be the locale required to provide assistance in the most languages (6 languages): Spanish, Cambodian, Chinese, Filipino, Korean, and Vietnamese.
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Posted in Voting Rights Act<http://electionlawblog.org/?cat=15>

Peter Schuck: “Still in the Thickest Thicket”<http://electionlawblog.org/?p=89747>
Posted on December 6, 2016 4:35 pm<http://electionlawblog.org/?p=89747> by Rick Hasen<http://electionlawblog.org/?author=3>
Here is a guest post from Professor Peter Schuck<https://www.law.yale.edu/peter-h-schuck>:
Still in the Thickest Thicket
Peter Schuck
Just before Thanksgiving, a 3-judge federal court gave Democrats good reason to cheer. It struck down a Wisconsin districting plan favoring Republican candidates as an unconstitutional partisan gerrymander. This decision could be far-reaching because almost all states draw district lines to advantage their majority party in legislative and congressional elections. (Putatively non-partisan commissions draw the lines in a few states). The Supreme Court is hearing other gerrymandering cases and will surely review this one.  This is a judicial minefield; skepticism is warranted.
Legislated maps are almost inevitably partisan due to political, legal, and practical factors. Voters’ tend to reside in partisan clusters (Democrats in cities, Republicans in suburban and rural areas). Also limiting the mapping options somewhat is the Court’s one-person, one-vote rulings: districts must be roughly equal in population and reasonably compact except when necessary to protect minority voting rights. At the same time, the Court reads the Voting Rights Act to require districts to be “packed” with enough minorities to assure victory for a minority candidate, and this number must be large since many minorities are non-citizens and don’t vote. (Another constraint: California and some other states reject maps that divide “communities of interest.”)
But the Supreme Court has strongly resisted regulating partisan gerrymandering for federal elections. (Some states now constrain the gerrymandering of statehouse seats). No Court majority has endorsed a test for when maps are so egregiously partisan as to unconstitutionally disadvantage the other party. Indeed, no one opinion on this subject has even garnered a majority of justices! Court pluralities have rejected tests focused on legislators’ intent; partisanship is in legislators’ job description, and parsing their mixed motives is difficult. Other tests using multiple factors and hard-to-measure criteria would produce too much uncertainty and judicial discretion. Any constitutional test must be “judicially manageable,” the justices agree, but they have been unable or unwilling to come up with a satisfactory one.
Now comes the bold Wisconsin decision. Carefully reviewing these Supreme Court opinions and political scientists’ views about partisan gerrymandering, the judges adopted a test based on how many votes for each party a given map “wastes.” The Wisconsin Republicans sought to waste Democratic votes in two familiar ways: they “cracked” Democratic voters by placing them in districts where they would be too few to elect the Democrat, and “packed” them into districts where they would elect the Democrat by far more votes than needed. Both techniques gave Democratic votes little or no marginal effect on those election outcomes. They made Republican votes more “efficient” than Democratic ones, converting GOP votes into legislative seats at a higher rate, producing an “efficiency gap” between the parties larger than the average gap in past elections.  Unless Republicans could show that legitimate, non-partisan reasons required this particular map, it was unconstitutional.
This “efficiency gap” test for partisan gerrymanders is plausible; indeed, some election law scholars and state courts have endorsed it.  Even so, the Supreme Court should proceed with caution, skeptical of any such simple, “one-size-fits-all” solution. Here’s why.  Increased clustering of partisans in discrete communities would assure many wasted votes even with no packing.  Also, the test’s outcome can turn on slight changes in the distribution of votes among districts. It would also protect bipartisangerrymanders protecting both parties’ incumbents from competition; they tend to have low efficiency gaps. The efficiency gap test, moreover, cannot easily account for how independent voters, third-party voters, and party-switching might make past voting a less reliable guide to predicting future efficiency gaps. And it makes much turn on precisely how large a gap courts will tolerate in deciding when waste becomes excessive and thus unconstitutional. More fundamentally, the wasted-vote measure misconceives how actual representation works. Even with a comfortable victory margin, a representative must still attend to the concerns of the other party’s voters, at least if she expects to seek re-election in a dynamic political environment. Indeed, if her party gerrymanders for vote efficiency, it will want to keep her victory margin low so that it can distribute its voters to win other districts.
Even more important, any such test will necessarily draw federal courts into new partisan battles from which they have heretofore been protected by the Supreme Court’s hands-off treatment of these gerrymanders. Using this test to regulate elections will be especially problematic because one can usually predict which party will benefit from it. (Indeed, its predictability is a supposed virtue). At a time when our public institutions are experiencing a crisis of legitimacy, when public esteem for even the Court has declined, and when the next round of appointments to it will be bitterly contested, we can ill afford its further politicization.  Alas, partisan gerrymanders may be one of those problems without any good judicial solution.
Peter H. Schuck is the Simeon E. Baldwin Professor Emeritus of Law at Yale.  His most recent books are Why Government Fails So Often, and How It Can Do Better (Princeton, 2014), and  One Nation Undecided: Clear Thinking About Five Hard Issues That Divide Us (Princeton, Feb. 2017)
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Posted in redistricting<http://electionlawblog.org/?cat=6>, Supreme Court<http://electionlawblog.org/?cat=29>

“Appeals court panel won’t lift Michigan recount order”<http://electionlawblog.org/?p=89745>
Posted on December 6, 2016 4:31 pm<http://electionlawblog.org/?p=89745> by Rick Hasen<http://electionlawblog.org/?author=3>
Josh Gerstein:<http://www.politico.com/blogs/under-the-radar/2016/12/michigan-recount-appeal-232284>
A federal appeals court panel has declined to overturn a federal judge’s order mandating a recount of presidential election results in Michigan at the request of Green Party nominee Jill Stein.
In an order issued Tuesday evening<http://www.politico.com/f/?id=00000158-d695-dd9c-a15e-f79785590001>, the 6th Circuit panel split, 2-1, along partisan lines in declining to temporarily lift the order<http://www.politico.com/blogs/under-the-radar/2016/12/michigan-recount-ordered-judge-232182> that required the recount to begin by noon Monday in order to meet a target next week for states to name Electoral College electors. The Michigan Republican Party and Michigan Attorney General Bill Schuette had both asked the appeals court to step in.
From Judge McKeague’s dissent:
Moreover, in manifest display of partiality and overreach, the district court purports to have granted relief even more expansive than was requested. Whereas plaintiff Stein asked the court to enjoin any delay in commencement of the recount prior to December 7 (when the recount otherwise would have been commenced in accordance with state law), the district court purports to have not only ordered immediate commencement of the recount, but continuation thereof “until further order of this Court.” And not only that: the district court further defined the required continuation as including the requirement that “all governmental units participating in the recount to assemble necessary staff to work sufficient hours to assure that the recount is completed in time to comply with the safe harbor provision of 3 U.S.C. § 5.” R. 16, Temporary Restraining Order at 7–8, Page ID 678–79.
To this, I can only respond, “Astounding!” “Just who do we think we are?” Obergefell v. Hodges, 135 S.Ct. 2584, 2612 (2015) (Roberts, J., dissenting).
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Posted in election administration<http://electionlawblog.org/?cat=18>

When President Trump Forms a Non-Disclosing 501c4 to Support His Agenda, Say “Thanks Obama”<http://electionlawblog.org/?p=89741>
Posted on December 6, 2016 4:12 pm<http://electionlawblog.org/?p=89741> by Rick Hasen<http://electionlawblog.org/?author=3>
From today’s Washington Post:<https://www.washingtonpost.com/news/post-politics/wp/2016/12/05/new-pro-trump-group-takes-form-with-kellyanne-conway-possibly-at-the-helm/?utm_term=.d8d2592d150a>
The entity will resemble in part Citizens for America, an organization launched by supporters of President Ronald Reagan in the early 1980s. Led by Lewis Lehrman, a Republican New York banker, the group claimed more than 260 local chapters and drew funding from supporters including T. Boone Pickens and top executives at Fortune 500 firms, including Amway, Shell Oil and Chase Manhattan Bank. The group didn’t campaign for or endorse Reagan’s 1984 reelection, but local chapter leaders sought to rally the public for Reagan’s policies by submitting newspaper and magazine letters to the editor, calling into radio and television talk shows and mobilizing local activists to call and lobby lawmakers.
More than 30 years later, “Trump has the ability to do Citizens for America on steroids through the Internet,” said Richard F. Hohlt, a Washington-based Republican consultant and lobbyist. “They’re smart enough to know how to harness the movement to their advantage. This is going to be huge. Republicans have never had this before.”
The legal structure of the new organization is being discussed by attorneys. If the group is formed as a super PAC or set up under Section 501(c)(4) of the tax code, it could accept unlimited donations, but 501(c)(4) nonprofits are not required to publicly disclose their donors. Organizing for Action, the nonprofit advocacy group that grew out of President Obama’s reelection campaign, is set up as a 501(c)(4), but it voluntarily discloses its contributors.
From my book, Plutocrats United<https://www.amazon.com/Plutocrats-United-Campaign-Distortion-Elections/dp/0300212453/ref=sr_1_1?s=books&ie=UTF8&qid=1481069325&sr=1-1&keywords=plutocrats+united>, on President Obama and fundraising:
[creen-shot-2016-12-06-at-4-11-01-pm]<http://electionlawblog.org/wp-content/uploads/Screen-Shot-2016-12-06-at-4.11.01-PM.png>[creen-shot-2016-12-06-at-4-11-42-pm]<http://electionlawblog.org/wp-content/uploads/Screen-Shot-2016-12-06-at-4.11.42-PM.png>
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Posted in campaign finance<http://electionlawblog.org/?cat=10>

--
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<http://electionlawblog.org/>
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