[EL] “Dark Money” and Advocating for Confirmation

Wed Mar 22 08:17:39 PDT 2017

Sorry, forgot to change the subject line. Please reply here if you’d like.

On Wed, Mar 22, 2017 at 11:16 AM, Steve Klein <stephen.klein.esq at gmail.com>
wrote:

> Prof. Hasen (and anyone who would care to weigh in),
>
>
> Do you agree with Sen. Whitehouse’s contention that someone's "spending
> $10 million to get Gorsuch confirmed” could be categorized as “dark money”?
>
>
> ---
>
>
> *Will Gorsuch Break With Scalia, Providing 2d (or 3d) Vote To Allow Flood
> of Undisclosed Money in Elections? <http://electionlawblog.org/?p=91744>*
>
> Posted on March 22, 2017 7:49 am <http://electionlawblog.org/?p=91744> by *Rick
> Hasen* <http://electionlawblog.org/?author=3>
>
> The Supreme Court has long upheld the constitutionality of requiring
> disclosure of the money behind elections, lobbying, and many political
> activities. In the 1976 *Buckley v. Valeo *case, the Court held that such
> disclosure, while implicating First Amendment rights, served three
> important government interests: deterring corruption, providing voters with
> valuable information, and helping to enforce other laws (such as the ban on
> foreign money in US elections).
>
> Although the Court has repeatedly upheld disclosure laws against First
> Amendment challenge, Justice Thomas has taken the position that there is a
> constitutional right to anonymity, and Justice Alito has been moving in
> that direction (as in his Doe v. Reed concurrence), suggesting that
> disclosure laws can chill activity. Justice Scalia, an originalist like
> Justice Thomas, disagreed that the original meaning of the First Amendment
> required anonymity, famously writing in *Doe*:
>
> *For my part, I do not look forward to a society which, thanks to the
> Supreme Court, campaigns anonymously … and even exercises the direct
> democracy of initiative and referendum hidden from public scrutiny and
> protected from the accountability of criticism. This does not resemble the
> Home of the Brave.*
>
>  There has been a continued push by campaign deregulationists to get the
> Court to water down corruption on First Amendment grounds—not to throw it
> out entirely as to campaigns, but to allow outside groups to mask their
> donors. (It is already now pretty easy to do this under federal law, but
> that’s a political, not legal, problem. Congress needs to rewrite the laws
> to make disclosure work).
>
> So where would a Justice Gorsuch be on this? Would he be with a majority
> that has upheld disclosure, or would he be with J. Thomas and, likely
> Justice Alito, believing that the “chill” of compelled disclosure requires
> constitutional anonymity?
>
> If you watch the exchange with Senator Whitehouse from yesterday’s
> hearing,
> <http://www.slate.com/blogs/the_slatest/2017/03/21/whitehouse_grills_gorsuch_on_dark_money_and_citizens_united.html>I
> believe there is a good chance Gorsuch will be in the Thomas/Alito camp. He
> spoke of the “chill” and did not really give any reason why disclosure
> might be valuable. He never suggested, for example, that the public might
> have an interest in knowing who is spending millions to support his
> campaign. From Slate:
>
> *And because of our lax disclosure laws, it is often very difficult to
> determine who is spending money and how. For example, Whitehouse said,
> someone is spending $10 million to get Gorsuch confirmed.*
>
> *“Hypothetically,” he continued, it could be “your friend Mr. Anschutz. We
> don’t know because it is dark money
> <https://en.wikipedia.org/wiki/Dark_money>.” He asked Gorsuch why someone
> thought it was worth $10 million to get him confirmed.*
>
> *“You’d have to ask them,” a frustrated Gorsuch responded.*
>
> *“I can’t,” Whitehouse said, “because I don’t know who they are. It’s just
> a front group.”*
>
> What does it matter, if he’s only a second or third vote? Because we can
> look to the future, 10 years from now, and there could well be more
> Gorsuch’s on the Court.
>
> It makes me worried.
>
> [image: hare]
> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91744&title=Will%20Gorsuch%20Break%20With%20Scalia%2C%20Providing%202d%20(or%203d)%20Vote%20To%20Allow%20Flood%20of%20Undisclosed%20Money%20in%20Elections%3F>
>
> Posted in campaign finance <http://electionlawblog.org/?cat=10>, Supreme
> Court <http://electionlawblog.org/?cat=29>
>
> On Wed, Mar 22, 2017 at 11:01 AM, Rick Hasen <rhasen at law.uci.edu> wrote:
>
>> *Will Gorsuch Break With Scalia, Providing 2d (or 3d) Vote To Allow Flood
>> of Undisclosed Money in Elections? <http://electionlawblog.org/?p=91744>*
>>
>> Posted on March 22, 2017 7:49 am <http://electionlawblog.org/?p=91744>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> The Supreme Court has long upheld the constitutionality of requiring
>> disclosure of the money behind elections, lobbying, and many political
>> activities. In the 1976 *Buckley v. Valeo *case, the Court held that
>> such disclosure, while implicating First Amendment rights, served three
>> important government interests: deterring corruption, providing voters with
>> valuable information, and helping to enforce other laws (such as the ban on
>> foreign money in US elections).
>>
>> Although the Court has repeatedly upheld disclosure laws against First
>> Amendment challenge, Justice Thomas has taken the position that there is a
>> constitutional right to anonymity, and Justice Alito has been moving in
>> that direction (as in his Doe v. Reed concurrence), suggesting that
>> disclosure laws can chill activity. Justice Scalia, an originalist like
>> Justice Thomas, disagreed that the original meaning of the First Amendment
>> required anonymity, famously writing in *Doe*:
>>
>> *For my part, I do not look forward to a society which, thanks to the
>> Supreme Court, campaigns anonymously … and even exercises the direct
>> democracy of initiative and referendum hidden from public scrutiny and
>> protected from the accountability of criticism. This does not resemble the
>> Home of the Brave.*
>>
>>  There has been a continued push by campaign deregulationists to get the
>> Court to water down corruption on First Amendment grounds—not to throw it
>> out entirely as to campaigns, but to allow outside groups to mask their
>> donors. (It is already now pretty easy to do this under federal law, but
>> that’s a political, not legal, problem. Congress needs to rewrite the laws
>> to make disclosure work).
>>
>> So where would a Justice Gorsuch be on this? Would he be with a majority
>> that has upheld disclosure, or would he be with J. Thomas and, likely
>> Justice Alito, believing that the “chill” of compelled disclosure requires
>> constitutional anonymity?
>>
>> If you watch the exchange with Senator Whitehouse from yesterday’s
>> hearing,
>> <http://www.slate.com/blogs/the_slatest/2017/03/21/whitehouse_grills_gorsuch_on_dark_money_and_citizens_united.html>I
>> believe there is a good chance Gorsuch will be in the Thomas/Alito camp. He
>> spoke of the “chill” and did not really give any reason why disclosure
>> might be valuable. He never suggested, for example, that the public might
>> have an interest in knowing who is spending millions to support his
>> campaign. From Slate:
>>
>> *And because of our lax disclosure laws, it is often very difficult to
>> determine who is spending money and how. For example, Whitehouse said,
>> someone is spending $10 million to get Gorsuch confirmed.*
>>
>> *“Hypothetically,” he continued, it could be “your friend Mr. Anschutz.
>> We don’t know because it is dark money
>> <https://en.wikipedia.org/wiki/Dark_money>.” He asked Gorsuch why someone
>> thought it was worth $10 million to get him confirmed.*
>>
>> *“You’d have to ask them,” a frustrated Gorsuch responded.*
>>
>> *“I can’t,” Whitehouse said, “because I don’t know who they are. It’s
>> just a front group.”*
>>
>> What does it matter, if he’s only a second or third vote? Because we can
>> look to the future, 10 years from now, and there could well be more
>> Gorsuch’s on the Court.
>>
>> It makes me worried.
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91744&title=Will%20Gorsuch%20Break%20With%20Scalia%2C%20Providing%202d%20(or%203d)%20Vote%20To%20Allow%20Flood%20of%20Undisclosed%20Money%20in%20Elections%3F>
>>
>> Posted in campaign finance <http://electionlawblog.org/?cat=10>, Supreme
>> Court <http://electionlawblog.org/?cat=29>
>>
>>
>>
>>
>>
>> *Will Democrats Filibuster Gorsuch, Forcing McConnell to Go Nuclear?
>> <http://electionlawblog.org/?p=91742>*
>>
>> Posted on March 22, 2017 7:38 am <http://electionlawblog.org/?p=91742>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> Carl Hulse
>> <https://www.nytimes.com/2017/03/22/us/politics/joviality-at-neil-gorsuchs-hearing-masks-drama-behind-the-scenes.html?ref=politics> suggests
>> this is a live possibility. The signals I had seen suggested Democrats
>> would not filibuster.
>>
>> We’ll see.
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91742&title=Will%20Democrats%20Filibuster%20Gorsuch%2C%20Forcing%20McConnell%20to%20Go%20Nuclear%3F>
>>
>> Posted in Supreme Court <http://electionlawblog.org/?cat=29>
>>
>>
>>
>>
>>
>> *“Judge Gorsuch: Do You Back the ‘One Person, One Vote’ Principle?”
>> <http://electionlawblog.org/?p=91740>*
>>
>> Posted on March 22, 2017 7:23 am <http://electionlawblog.org/?p=91740>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> Doug Smith, author of On Democracy’s Doorstep
>> <https://www.amazon.com/Democracys-Doorstep-Inside-Supreme-Brought-ebook/dp/B00H0V04TE/ref=as_at?creativeASIN=B00H0V04TE&linkCode=w50&tag=thedailybeast-autotag-20&imprToken=RUiC3c-9qcdvwgANwKXXTA&slotNum=0>, has
>> written this article
>> <http://www.thedailybeast.com/articles/2017/03/22/judge-gorsuch-do-you-back-the-one-person-one-vote-principle.html> for
>> the Daily Beast.
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91740&title=%E2%80%9CJudge%20Gorsuch%3A%20Do%20You%20Back%20the%20%E2%80%98One%20Person%2C%20One%20Vote%E2%80%99%20Principle%3F%E2%80%9D>
>>
>> Posted in Supreme Court <http://electionlawblog.org/?cat=29>
>>
>>
>>
>>
>>
>> *“Gorsuch Could Undermine Trump Travel Ban”
>> <http://electionlawblog.org/?p=91738>*
>>
>> Posted on March 22, 2017 7:11 am <http://electionlawblog.org/?p=91738>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> Ciara Torres-Spelliscy blogs.
>> <http://www.brennancenter.org/blog/gorsuch-could-undermine-trump-travel-ban>
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91738&title=%E2%80%9CGorsuch%20Could%20Undermine%20Trump%20Travel%20Ban%E2%80%9D>
>>
>> Posted in Supreme Court <http://electionlawblog.org/?cat=29>
>>
>>
>>
>>
>>
>> *“Former Colorado GOP chairman Steven Curtis charged with voter fraud”
>> <http://electionlawblog.org/?p=91736>*
>>
>> Posted on March 21, 2017 8:56 pm <http://electionlawblog.org/?p=91736>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> The Denver Channel
>> <http://www.thedenverchannel.com/news/politics/former-colorado-gop-chairman-steven-curtis-charged-with-voter-fraud> with
>> a story that is just too rich:
>>
>> *The former chairman of the Colorado Republican Party is charged with
>> forgery and voter fraud for allegedly forging his wife’s mail-in ballot
>> from last year’s election, according to court records and sources….*
>>
>> *The Colorado Secretary of State’s Office says this is the only voter
>> fraud case that has ended in charges stemming from last year’s election.*
>>
>> *Curtis spoke about voter fraud ahead of last year’s election.*
>>
>> *“It seems to be, and correct me if I’m wrong here, but virtually every
>> case of voter fraud I can remember in my lifetime was committed by
>> Democrats,” he told KLZ 560.*
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91736&title=%E2%80%9CFormer%20Colorado%20GOP%20chairman%20Steven%20Curtis%20charged%20with%20voter%20fraud%E2%80%9D>
>>
>> Posted in chicanery <http://electionlawblog.org/?cat=12>, The Voting Wars
>> <http://electionlawblog.org/?cat=60>
>>
>>
>>
>>
>>
>> *“Watch Sen. Whitehouse Grill Gorsuch About Dark Money, Corporate Power,
>> and Citizens United” <http://electionlawblog.org/?p=91734>*
>>
>> Posted on March 21, 2017 1:49 pm <http://electionlawblog.org/?p=91734>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> Slate
>> <http://www.slate.com/blogs/the_slatest/2017/03/21/whitehouse_grills_gorsuch_on_dark_money_and_citizens_united.html> with
>> the video.
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91734&title=%E2%80%9CWatch%20Sen.%20Whitehouse%20Grill%20Gorsuch%20About%20Dark%20Money%2C%20Corporate%20Power%2C%20and%20Citizens%20United%E2%80%9D>
>>
>> Posted in campaign finance <http://electionlawblog.org/?cat=10>, Supreme
>> Court <http://electionlawblog.org/?cat=29>
>>
>>
>>
>>
>>
>> *Judge Gorsuch Misstates Citizens United’s Holding, and Inexplicably Says
>> Congress Has Ample Room to Enact Expenditure Limits
>> <http://electionlawblog.org/?p=91730>*
>>
>> Posted on March 21, 2017 8:37 am <http://electionlawblog.org/?p=91730>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> From an exchange with Sen. Leahy at today’s hearing:
>>
>> Judge Gorsuch, questioned on Citizens United, said the following (my
>> transcription):
>>
>> *I think there is lots of room for legislation in this area that this
>> court has left. The Court indicated that if proof of corruption can be
>> demonstrated a different result may obtain on expenditure limits….*
>>
>> *I think after Citizens United made clear that quid pro quo corruption
>> remains a vital concern and a subject for potential legislation. And I
>> think there is ample room for this body to legislate, even in light of
>> Citizens United, whether it has to do with contribution limits, whether it
>> has to with expenditure limits, or whether it has to do with disclosure
>> requirements.*
>>
>> This is incorrect. In American Tradition Partnership v. Bullock,
>> <https://www.supremecourt.gov/opinions/11pdf/11-1179h9j3.pdf> the
>> Supreme Court majority (the same majority in Citizens United) held that it
>> would NOT consider evidence of corruption to justify a spending limit. It
>> needed only a paragraph to dispose of the case given its holding in
>> Citizens United. The dissenters (the same dissenters in Citizens United)
>> argued in contrast that the Court should consider evidence of corruption
>> which could justify an expenditure limit.
>>
>> Instead, in Citizens United the Court left NO room for spending limits,
>> apart from spending limits applied to foreign individuals and entities
>> (which it allowed via a summary affirmance in *Bluman v. FEC). *
>>
>> I explain all of this in Citizens United and the Illusion of Coherence
>> <http://repository.law.umich.edu/cgi/viewcontent.cgi?article=1166&context=mlr> in
>> the Michigan Law Review.
>>
>> So either Judge Gorsuch does not understand the scope of Citizens United
>> and its holding, or he is trying to soften its harshness by wrongly
>> suggesting Congress has room to legislate spending limits.
>>
>> I don’t believe he would actually uphold any spending limit Congress
>> passes (expect as to foreign spending).  I explain why based on reading his
>> earlier opinions here.
>> <http://www.cnn.com/2017/03/01/opinions/worry-about-gorsuch-hasen/>
>>
>> Update: Derek Muller disagrees
>> <http://excessofdemocracy.com/blog/2017/3/no-gorsuch-didnt-misstate-citizen-uniteds-holding>
>> .
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91730&title=Judge%20Gorsuch%20Misstates%20Citizens%20United%E2%80%99s%20Holding%2C%20and%20Inexplicably%20Says%20Congress%20Has%20Ample%20Room%20to%20Enact%20Expenditure%20Limits>
>>
>> Posted in campaign finance <http://electionlawblog.org/?cat=10>, Supreme
>> Court <http://electionlawblog.org/?cat=29>
>>
>>
>>
>>
>>
>> *“Trump’s White House Counsel Don McGahn Has Combative Record”
>> <http://electionlawblog.org/?p=91728>*
>>
>> Posted on March 21, 2017 7:32 am <http://electionlawblog.org/?p=91728>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> Peter Overby
>> <http://www.npr.org/2017/03/20/520862756/trumps-white-house-counsel-don-mcgahn-has-combative-record>for
>> NPR.
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91728&title=%E2%80%9CTrump%E2%80%99s%20White%20House%20Counsel%20Don%20McGahn%20Has%20Combative%20Record%E2%80%9D>
>>
>> Posted in election law biz <http://electionlawblog.org/?cat=51>
>>
>>
>>
>>
>>
>> *“Senators must press Gorsuch on campaign finance laws”
>> <http://electionlawblog.org/?p=91726>*
>>
>> Posted on March 21, 2017 7:29 am <http://electionlawblog.org/?p=91726>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> Ann Ravel SacBee oped.
>> <http://www.sacbee.com/opinion/op-ed/soapbox/article139408353.html>
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91726&title=%E2%80%9CSenators%20must%20press%20Gorsuch%20on%20campaign%20finance%20laws%E2%80%9D>
>>
>> Posted in campaign finance <http://electionlawblog.org/?cat=10>, Supreme
>> Court <http://electionlawblog.org/?cat=29>
>>
>>
>>
>>
>>
>> *Would a Gorsuch Confirmation Be Like Putting John Finnis and Natural Law
>> on the Supreme Court? <http://electionlawblog.org/?p=91724>*
>>
>> Posted on March 21, 2017 7:25 am <http://electionlawblog.org/?p=91724>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> Steve Mazie makes the case.
>> <http://www.economist.com/blogs/democracyinamerica/2017/03/moral-hazard>
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91724&title=Would%20a%20Gorsuch%20Confirmation%20Be%20Like%20Putting%20John%20Finnis%20and%20Natural%20Law%20on%20the%20Supreme%20Court%3F>
>>
>> Posted in Supreme Court <http://electionlawblog.org/?cat=29>
>>
>>
>>
>>
>>
>> *“If Judge Gorsuch is Really Like Justice Scalia, Then He Will Be No Fan
>> of Voting Rights” <http://electionlawblog.org/?p=91722>*
>>
>> Posted on March 21, 2017 7:22 am <http://electionlawblog.org/?p=91722>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> Josh Douglas
>> <http://www.huffingtonpost.com/entry/58d11e77e4b07112b6473198> for
>> HuffPo.
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91722&title=%E2%80%9CIf%20Judge%20Gorsuch%20is%20Really%20Like%20Justice%20Scalia%2C%20Then%20He%20Will%20Be%20No%20Fan%20of%20Voting%20Rights%E2%80%9D>
>>
>> Posted in Supreme Court <http://electionlawblog.org/?cat=29>
>>
>>
>>
>>
>>
>> *James Sample: Dems Should Hold Filibuster Confrontation for Nomination
>> that Matters More <http://electionlawblog.org/?p=91720>*
>>
>> Posted on March 21, 2017 7:21 am <http://electionlawblog.org/?p=91720>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> Watch.
>> <https://livestream.com/accounts/18968940/events/7055388/videos/152277320>
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91720&title=James%20Sample%3A%20Dems%20Should%20Hold%20Filibuster%20Confrontation%20for%20Nomination%20that%20Matters%20More>
>>
>> Posted in Uncategorized <http://electionlawblog.org/?cat=1>
>>
>>
>>
>>
>>
>> *Bauer on Hasen on Kozinski on the Travel Ban
>> <http://electionlawblog.org/?p=91718>*
>>
>> Posted on March 21, 2017 7:19 am <http://electionlawblog.org/?p=91718>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> Bob concurs
>> <http://www.moresoftmoneyhardlaw.com/2017/03/judge-kozinskis-complaint-first-amendment-realismin-travel-ban-case/> in
>> the judgment.
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91718&title=Bauer%20on%20Hasen%20on%20Kozinski%20on%20the%20Travel%20Ban>
>>
>> Posted in Uncategorized <http://electionlawblog.org/?cat=1>
>>
>>
>>
>>
>>
>> *“Huefner’s Legislation and Regulation in a Nutshell”
>> <http://electionlawblog.org/?p=91716>*
>>
>> Posted on March 21, 2017 7:18 am <http://electionlawblog.org/?p=91716>
>>  by *Rick Hasen* <http://electionlawblog.org/?author=3>
>>
>> New book coming
>> <http://www.westacademic.com/Professors/ProductDetails.aspx?NSIID=17892> from
>> the great Steve Huefner.
>>
>> [image: hare]
>> <https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D91716&title=%E2%80%9CHuefner%E2%80%99s%20Legislation%20and%20Regulation%20in%20a%20Nutshell%E2%80%9D>
>>
>> Posted in legislation and legislatures
>> <http://electionlawblog.org/?cat=27>
>>
>>
>>
>>
>>
>> --
>>
>> 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 <(949)%20824-3072> - office
>>
>> rhasen at law.uci.edu
>>
>> http://www.law.uci.edu/faculty/full-time/hasen/
>>
>> http://electionlawblog.org
>>
>> _______________________________________________
>> Law-election mailing list
>> Law-election at department-lists.uci.edu
>> http://department-lists.uci.edu/mailman/listinfo/law-election
>>
>
>
>
> --
> Steve Klein
> Attorney*
> https://www.linkedin.com/in/stephenrklein
>
> **Licensed to practice law in Illinois and Michigan*
>

-- 
Steve Klein
Attorney*
https://www.linkedin.com/in/stephenrklein

**Licensed to practice law in Illinois and Michigan*
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