[EL] ELB News and Commentary 7/25/18

Wed Jul 25 08:08:40 PDT 2018

Jenny Diamond Cheng: The Twenty-Sixth Amendment Lives! Federal District Court Strikes Down Florida Rule as Discriminatory against College Student Voters<http://electionlawblog.org/?p=100266>
Posted on July 25, 2018 8:05 am<http://electionlawblog.org/?p=100266> by Rick Hasen<http://electionlawblog.org/?author=3>

The following is a guest post from Jenny Diamond Cheng<https://law.vanderbilt.edu/bio/jenny-cheng> of Vanderbilt Law:

As Rick noted<http://electionlawblog.org/?p=100231>, the Northern District of Florida in League of Women Voters v. Detzne<https://cloudup.com/iRgk2VxxXnS>r recently found the State of Florida to have violated the First, Fourteenth, and Twenty-Sixth Amendments by intentionally discriminating against college voters.  The holding is potentially a shot in the arm for those seeking to challenge voter suppression targeted at young voters.

The opinion has two intriguing aspects:  First, in line with the gradually emerging consensus among federal courts, the court applied the Arlington Heights framework to the Twenty-Sixth Amendment, interpreting the Amendment as prohibiting deliberate age-based voter discrimination.  I have written elsewhere<http://lawreview.syr.edu/wp-content/uploads/2017/03/Vol-67.3_Cheng.pdf> that the Twenty-Sixth Amendment in an Arlington Heights framework is the most sensible and theoretically sound approach.  The Twenty-Sixth Amendment shares nearly identical wording with the Fifteenth Amendment and is ideally suited for an intratextualist reading.  Furthermore, to the extent that much of the dramatic partisan generation gap is likely due to significant demographic differences between older and younger Americans, the conceptual distinction between age-based and race-based voter discrimination is arguably eroding.

Second and more significantly, the court broke new ground by actually finding evidence of unconstitutional intentional discrimination. This is the first time that a court has been willing to explicitly impute discriminatory intent in a Twenty-Sixth Amendment case. The plaintiffs in Detnzer – two organizations and six college students – were challenging Secretary of State Detzner’s 2014 opinion barring early voting sites on college or university campuses.  The district court was clearly skeptical of the state’s purported justifications for the policy, including avoiding parking problems and minimizing on-campus disruption. “[The policy] is unexplainable on grounds other than age because it bears so heavily on younger voters than all other voters.  [The State’s] stated interests . . . reek of pretext.”

The court also held that the Secretary of State’s opinion violated the plaintiffs’ First and Fourteenth Amendment rights. Applying the Anderson-Burdick balancing test, Judge Walker declared that Secretary Detzner had failed to articulate any precise governmental interest that would justify the “significant” and “lopsided” burden on the college student plaintiffs, who were flatly denied an early voting site “on a dense, centralized location where they work, study, and in many cases, live.”

The other federal courts that have recently heard Twenty-Sixth Amendment claims have been tentatively coalescing around the idea that the Amendment prohibits intentional age-based voter discrimination.  However, given courts’ notorious reluctance to attribute discriminatory intent to state officials (as well as their willingness to exclude evidence of such intent), it has been unclear whether this interpretation was really meaningful.   The Northern District of Florida’s decision in Detzner suggests that the Twenty-Sixth Amendment can indeed serve as the basis for a successful constitutional challenge to laws intended to suppress young voters.
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Posted in voting<http://electionlawblog.org/?cat=31>

“Frustrated by Gridlock, House Members Propose Rules Overhaul”<http://electionlawblog.org/?p=100264>
Posted on July 25, 2018 8:01 am<http://electionlawblog.org/?p=100264> by Rick Hasen<http://electionlawblog.org/?author=3>

NYT:<https://www.nytimes.com/2018/07/24/us/politics/house-gridlock-rules-overhaul.html?rref=collection%2Fsectioncollection%2Fpolitics&action=click&contentCollection=politics&region=stream&module=stream_unit&version=latest&contentPlacement=6&pgtype=sectionfront>

Trying to ease gridlock in Congress, a bipartisan group of frustrated House members is coming forward with a rules overhaul intended to give rank-and-file lawmakers more say.

The proposal, to be formally unveiled Wednesday by the House Problem Solvers Caucus, also seeks to rein in hard-right Republican forces in the chamber that have wielded significant influence over the majority party in recent years.

Under the plan, the ability of one representative to essentially force a vote of no confidence in the speaker would be eliminated. That threat from members of the House Freedom Caucus led to the resignation of Speaker John A. Boehner in 2015 and is seen as a way that just a few members can handcuff the speaker.
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Posted in legislation and legislatures<http://electionlawblog.org/?cat=27>

West Virginia: “Manchin, Morrisey Split on Blankenship’s Challenge to ‘Sore Loser’ Election Law”<http://electionlawblog.org/?p=100262>
Posted on July 25, 2018 7:59 am<http://electionlawblog.org/?p=100262> by Rick Hasen<http://electionlawblog.org/?author=3>

West Virginia Public Radio reports.<http://wvpublic.org/post/manchin-morrisey-split-blankenships-challenge-sore-loser-election-law#stream/0>
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Posted in ballot access<http://electionlawblog.org/?cat=46>

Maine SOS Matt Dunlap to Do Webinar on Maine’s Experience with Ranked Choice Voting<http://electionlawblog.org/?p=100259>
Posted on July 25, 2018 7:55 am<http://electionlawblog.org/?p=100259> by Rick Hasen<http://electionlawblog.org/?author=3>

Details for Aug. 2 event<https://register.gotowebinar.com/register/3137876835521530114>. Maybe Dunlap will also answer questions about his lawsuit against Trump’s voter “fraud” commission.
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Posted in alternative voting systems<http://electionlawblog.org/?cat=63>

“Money, politics and Justice Anthony Kennedy: Revisiting Citizens United”<http://electionlawblog.org/?p=100257>
Posted on July 25, 2018 7:51 am<http://electionlawblog.org/?p=100257> by Rick Hasen<http://electionlawblog.org/?author=3>

Michael Morley<http://theconversation.com/money-politics-and-justice-anthony-kennedy-revisiting-citizens-united-99632> at The Conversation.
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Posted in campaign finance<http://electionlawblog.org/?cat=10>, Supreme Court<http://electionlawblog.org/?cat=29>

“Prophylactic Redistricting? Congress’s Section 5 Power and the New Equal Protection Right to Vote”<http://electionlawblog.org/?p=100255>
Posted on July 25, 2018 7:50 am<http://electionlawblog.org/?p=100255> by Rick Hasen<http://electionlawblog.org/?author=3>

Michael Morley has posted this draf<https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3216936>t on SSRN (forthcoming, William & Mary L. Rev.). Here is the abstract:

The Voting Rights Act (VRA) has been an important mechanism for increasing participation by racial minorities in the electoral system. In recent years, however, the Supreme Court has demonstrated its willingness to reconsider the VRA’s constitutionality. Due to the broad prophylactic scope of section 2 of the VRA, two main developments pose risks to its continued validity.

First, the Supreme Court narrowed Congress’s enforcement power under Section 5 of the Fourteenth Amendment in City of Boerne v. Flores, and is likely to interpret Section 2 of the Fifteenth Amendment similarly. Section 2 of the VRA features many key characteristics of statutes that the Court has held exceeded Congress’s Enforcement Clause authority. The Court may nevertheless preserve section 2 by applying it in light of traditional remedial principles governing prophylactic injunctive relief. Section 2 would fit comfortably within Congress’s authority if it were interpreted as prophylactically prohibiting constitutionally valid state laws, legislative maps, or other election-related measures only when those principles establish it is reasonably necessary to prevent violations of Fourteenth or Fifteenth Amendment rights.

Second, ongoing evolution in equal protection jurisprudence calls into question measures such as section 2 of the VRA that provide prophylactic protection for certain groups. The Court has historically adopted a “pro-voting” conception of equal protection under which laws protecting voting rights only for certain people were generally upheld under rational basis scrutiny. Bush v. Gore laid the foundation for a “pro-equality” approach emphasizing that, because voting is a fundamental right, any distinctions among people concerning the right to vote are subject to strict scrutiny and likely invalid. The ongoing shift from a “pro-voting” to “pro-equality” equal protection norm reflects the Court’s skepticism of legislative control over the electoral process, as well as its reformation of voting rights from a purely political issue into a constitutional one. A “pro-equality” conception of equal protection enhances courts’ power to protect voting rights while reducing the ability of Congress and legislatures to do so.
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Posted in Voting Rights Act<http://electionlawblog.org/?cat=15>

Now Available: 2018 Supplement to Election Law–Cases and Materials (6th ed. 2017) by Lowenstein, Hasen, Tokaji, and Stephanopoulos<http://electionlawblog.org/?p=100251>
Posted on July 25, 2018 7:45 am<http://electionlawblog.org/?p=100251> by Rick Hasen<http://electionlawblog.org/?author=3>

You can now find the 2018 Supplement posted at this link.<https://cap-press.com/pdf/LowensteinElectionLaw6e2018SuppWM.pdf>

This 2018 Supplement is up-to-date through the end of the Supreme Court’s October 2017 term. The new material includes coverage of cases on partisan gerrymandering, voter purges, political apparel at the polling place, and Voting Rights Act challenges to redistricting.

And here’s info on the Sixth Edition<https://cap-press.com/books/isbn/9781531004729/Election-Law-Sixth-Edition> (2017):

Election Law
Cases and Materials
Sixth Edition

by Daniel Hays Lowenstein<https://cap-press.com/authors/118/Daniel-Hays-Lowenstein>, Richard L. Hasen<https://cap-press.com/authors/396/Richard-L.-Hasen>, Daniel P. Tokaji<https://cap-press.com/authors/899/Daniel-P.-Tokaji>, Nicholas Stephanopoulos<https://cap-press.com/authors/2666/Nicholas-Stephanopoulos>

The new student-friendly Sixth Edition of Election Law: Cases and Materials fully covers developments in election law through the 2016 election season, including extensive coverage campaign finance cases in the Citizens United era; emerging issues in voting rights and redistricting, including recent partisan and racial gerrymandering challenges; and challenges to new voter identification laws and other voting restrictions. It will continue to include perspectives from law and political science, and is appropriate in both law and political science courses. The extensive campaign finance coverage makes the book appropriate for a campaign finance seminar as well.

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Posted in pedagogy<http://electionlawblog.org/?cat=23>

North Carolina General Assembly, in Another Special Session, Seeks to Change Party Designation to Help Preferred Republican Supreme Court Candidate<http://electionlawblog.org/?p=100247>
Posted on July 24, 2018 1:04 pm<http://electionlawblog.org/?p=100247> by Rick Hasen<http://electionlawblog.org/?author=3>

A few weeks ago, I reported on a candidate<https://www.newsobserver.com/news/politics-government/state-politics/article214261469.html> for state Supreme Court Justice in North Carolina. He is running as a Republican even though he used to be a Democrat. Republicans suspect he’s doing this to split the R vote and help the Democratic candidate, voting rights attorney Anita Earls.

Well now the North Carolina General Assembly, already  in special session to write the ballot captions for proposed constitutional amendments on voter id and other things (so Democratic elected officials cannot do it) are considering a bill that would now require listing no candidate party affiliation if affiliation changed 90 days ago.<https://www.ncleg.net/Sessions/2017E1/Bills/Senate/PDF/S3v0.pdf> [corrected]

There are also rumors of a change to require a runoff in this race.

Needless to say, changes in the middle of the election season raise serious due process concerns, and it would not surprise me if these changes are challenged in either state or federal court should they be put in place and applicable to the election season already in progress.
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Posted in chicanery<http://electionlawblog.org/?cat=12>

‘Civil Rights Groups Sue Secretary of State for Voting Rights Violations Affecting People with Disabilities, Low-Income Californians’<http://electionlawblog.org/?p=100245>
Posted on July 24, 2018 12:56 pm<http://electionlawblog.org/?p=100245> by Rick Hasen<http://electionlawblog.org/?author=3>

The ACLU of Northern California has issued this press release<https://www.aclunc.org/news/civil-rights-groups-sue-secretary-state-voting-rights-violations-affecting-people-disabilities>.
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Posted in Uncategorized<http://electionlawblog.org/?cat=1>

“Montana Governor Sues I.R.S., Warning of ‘Foreign Money’ in Elections”<http://electionlawblog.org/?p=100243>
Posted on July 24, 2018 12:22 pm<http://electionlawblog.org/?p=100243> by Rick Hasen<http://electionlawblog.org/?author=3>

NYT:<https://www.nytimes.com/2018/07/24/us/politics/steve-bullock-montana-irs.html>

Gov. Steve Bullock of Montana, a Democrat who has crusaded against the loosening of campaign finance rules, is suing the Trump administration to block it from eliminating a mandate that politically active nonprofit groups disclose the identities of their major donors to the government….

But in a lawsuit filed on Tuesday in Federal District Court in Montana, Mr. Bullock and his administration alleged that the Trump administration had flouted proper government process in eliminating the disclosure requirements. The suit asked the court to issue a judgment voiding the new I.R.S. policy….

The Montana litigation claims that the federal government failed to follow the Administrative Procedure Act, a law that has been the basis for other suits charging<https://www.nytimes.com/2017/09/06/us/daca-lawsuits-trump.html> the Trump administration with improper or capricious rule making. The suit accuses the I.R.S. of evading important regulatory requirements, like the mandate to seek public comment before rewriting government rules, and of rewriting policy under the guise of adjusting what the I.R.S. termed a “revenue procedure.”

Mr. Bullock said that because Montana currently uses I.R.S. information to administer nonprofits at the state level, the abrupt policy shift could hobble its ability to conduct oversight and collect revenue.
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Posted in campaign finance<http://electionlawblog.org/?cat=10>, tax law and election law<http://electionlawblog.org/?cat=22>

“What You Need to Know About Florida’s Voting Rights”<http://electionlawblog.org/?p=100239>
Posted on July 24, 2018 11:23 am<http://electionlawblog.org/?p=100239> by Rick Hasen<http://electionlawblog.org/?author=3>

Ciara Torres-Spelliscy<https://www.shondaland.com/act/a22520765/florida-voting-rights-ex-felons-hand-v-scott/> for Shondaland.
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Posted in felon voting<http://electionlawblog.org/?cat=66>

New Series from TPM on Voting Rights Opens with Josh Marshall’s “The Battle For The Right To Vote Has Never Been Won”<http://electionlawblog.org/?p=100236>
Posted on July 24, 2018 11:20 am<http://electionlawblog.org/?p=100236> by Rick Hasen<http://electionlawblog.org/?author=3>

You can read Josh’s opening at this link.<https://talkingpointsmemo.com/feature/the-battle-for-the-right-to-vote-has-never-been-won>
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Posted in Voting Rights Act<http://electionlawblog.org/?cat=15>

“Commerce Secretary Grew Impatient Over Census Citizenship Question, Emails Reveal”<http://electionlawblog.org/?p=100234>
Posted on July 24, 2018 11:16 am<http://electionlawblog.org/?p=100234> by Rick Hasen<http://electionlawblog.org/?author=3>

Hansi Lo Wang<https://www.npr.org/2018/07/24/631537992/commerce-secretary-grew-impatient-over-census-citizenship-question-emails-reveal> for NPR:

A few months after he started leading the Commerce Department, Secretary Wilbur Ross became impatient. As a powerful decider for the U.S. census, he had a keen interest in adding a citizenship question to the 2020 census as soon as possible.

“I am mystified why nothing [has] been done in response to my months old request that we include the citizenship question. Why not?” he wrote in a May 2017 email to two Commerce Department officials.<https://www.documentcloud.org/documents/4616784-May-2-2017-Email-From-Wilbur-Ross.html#document/p1/a441438>

The email was among the more than 2,400 pages of internal documents<http://www.osec.doc.gov/opog/FOIA/Documents/CensusProd001.zip> the Trump administration filed in federal courts Monday as part of the lawsuits against Ross’ addition of a controversial citizenship question<https://apps.npr.org/documents/document.html?id=4426784-Planned-Questions-2020-Acs#document/p11/a414610> to the 2020 census….

In response to Ross’ frustrations with delays in adding a citizenship question, the director of the Commerce Department’s Office of Policy and Strategic Planning, Earl Comstock, assured Ross in a May 2017 email<https://apps.npr.org/documents/document.html?id=4616785-May-2-2017-Email-From-Earl-Comstock#document/p1/a441444>: “On the citizenship question we will get that in place.”

Comstock suggested using the Justice Department as a means for their goal. “We need to work with [the Justice Department] to get them to request that citizenship be added back as a census question,” he wrote in the same email. “I will arrange a meeting with [Justice Department] staff this week to discuss.”…

In an email to Ross’ chief of staff, Wendy Teramoto<https://www.documentcloud.org/documents/4616848-Page-2637-Of-Administrative-Record-For-Census.html#document/p2/a441564>, the acting head of the Justice Department’s civil rights division, John Gore, appears to refer to the citizenship question request as “a DOJ-DOC issue.” A few months ago, Gore represented the Justice Department during a House hearing on the citizenship question, when he dodged many inquiries<https://www.npr.org/sections/thetwo-way/2018/05/08/609548162/lawmakers-to-subpoena-doj-official-over-census-citizenship-question> from lawmakers by citing the DOJ’s role in representing the Trump administration in ongoing lawsuits about the question.

According to subsequent emails from September, Gore connected Ross’ staff with one of Attorney General Jeff Sessions’ advisers, Danielle Cutrona, who wrote to Teramoto<https://www.documentcloud.org/documents/4616848-Page-2637-Of-Administrative-Record-For-Census.html#document/p1/a441571>, “From what John told me, it sounds like we can do whatever you all need us to do.”
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Posted in redistricting<http://electionlawblog.org/?cat=6>

Breaking: Federal District Court Preliminarily Blocks Florida SOS Ruling Barring College Campus Locations as Early Voting Sites<http://electionlawblog.org/?p=100231>
Posted on July 24, 2018 11:12 am<http://electionlawblog.org/?p=100231> by Rick Hasen<http://electionlawblog.org/?author=3>

A very thoughtful opinion <http://electionlawblog.org/wp-content/uploads/fla-college-early-voting.pdf> granting a preliminary injunction in League of Women Voters v. Detzner. In addition to applying the Anderson-Burdick balancing test for equal protection claims, the court also applied a Twenty-Sixth Amendment  analysis, finding that the Secretary of State’s opinion barring college campus locations as early voting sites was pretexual discrimination in voting on  the basis of age.

I think we are likely to see this 26th Amendment analysis percolate in the lower courts, and potentially end up before the Supreme Court in the next few years (either in this case or another).
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Posted in election administration<http://electionlawblog.org/?cat=18>

“A Shadow Across Our Democracy”<http://electionlawblog.org/?p=100229>
Posted on July 24, 2018 9:24 am<http://electionlawblog.org/?p=100229> by Rick Hasen<http://electionlawblog.org/?author=3>

Charles Fried<https://blog.harvardlawreview.org/a-shadow-across-our-democracy/> for the HLR Blog:

There is a clear constitutional warrant. As long ago as 1986, the Court recognized<https://supreme.justia.com/cases/federal/us/478/109/> that partisan gerrymanders manifestly offend the Fourteenth Amendment’s constitutional guarantee of equal protection. They are also contrary to the First Amendment’s guarantee of freedom of association, as Justice Kennedy argued in Vieth<https://supreme.justia.com/cases/federal/us/541/267/> and Justice Kagan, writing for four Justices, recently elaborated in Gill<https://www.supremecourt.gov/opinions/17pdf/16-1161_dc8f.pdf>. Yet Since 1986 no Court majority has been willing to join the radical view that this was an issue forever and in principle beyond the reach of the judiciary. Over and over again, it has been a case of—in the words of St. Augustine<https://www1.villanova.edu/content/villanova/mission/office/programs/pellegrinaggio/_jcr_content/pagecontent/download_4/file.res/confessions_viii.pdf>—Lord, make me pure, but not yet. Four Justices have been willing to pull the trigger<https://supreme.justia.com/cases/federal/us/541/267/> on this outrage, but Justice Kennedy has publicly agonized<https://supreme.justia.com/cases/federal/us/541/267/> that a sufficiently clear metric has not yet been found.

The Supreme Court Term just ended brought to the Court two cases, one from Wisconsin<http://www.scotusblog.com/case-files/cases/gill-v-whitford/> and one from North Carolina<http://www.scotusblog.com/case-files/cases/rucho-v-common-cause/>, with facts so egregious and lower court findings of fact so irrefutable that many hoped<https://www.nytimes.com/2017/09/06/us/politics/prominent-republicans-urge-supreme-court-to-end-gerrymandering.html> that finally the time had come: Justice Kennedy could no longer withhold his fifth vote—and maybe a sixth, maybe even a seventh Justice would follow. Though it is impossible to say just how many hairs a man may sport on his head and still count as bald, surely the smooth, shiny pate must announce a clear case if the word is to have any meaning—and we all understand it does. Wisconsin and North Carolina are surely as bald-faced examples of naked partisan gerrymanders as we will ever see. And given the capabilities of recent algorithms and data-mining techniques<https://www.nytimes.com/2017/10/06/opinion/sunday/computers-gerrymandering-wisconsin.html>, Wisconsin and North Carolina are likely to become the norm.
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Posted in redistricting<http://electionlawblog.org/?cat=6>

In Adding Controversial Citizenship Question, Census Emails Appears to Show Department Used as Pretext DOJ Need for Data for Citizenship Data for Voting Rights Act Cases<http://electionlawblog.org/?p=100226>
Posted on July 24, 2018 9:16 am<http://electionlawblog.org/?p=100226> by Rick Hasen<http://electionlawblog.org/?author=3>
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<https://twitter.com/_justinlevitt_/status/1021693278272466945>

Hi, @rickhasen<https://twitter.com/rickhasen>. This the sort of thing you were talking about?

Dept of Commerce, in May 2017: "We need to work with Justice to get them to request that citizenship be added back as a census question....I will arrange a meeting." https://twitter.com/rickhasen/status/1021636861398200320 …<https://t.co/hGNytPNHUV>
<https://twitter.com/rickhasen/status/1021636861398200320>
Rick Hasen<https://twitter.com/rickhasen/status/1021636861398200320>
✔@rickhasen<https://twitter.com/rickhasen/status/1021636861398200320>

Nice surprise coming in the morning----hundreds of pages of census citizenship documents containing nuggets like this https://twitter.com/rickhasen/status/1021615217363451904 …<https://twitter.com/rickhasen/status/1021636861398200320>

2:47 AM - Jul 24, 2018<https://twitter.com/_justinlevitt_/status/1021693278272466945>

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Dale Ho at dale_e_ho<https://twitter.com/dale_e_ho>

<https://twitter.com/dale_e_ho/status/1021740911733231617>

NEW - For months Commerce Sec Ross has claimed that adding a citizenship question to the Census originated with DOJ and its supposed need for this info to enforce the VRA - BUT new docs we got last night show that the Commerce Dept planted the request. #TheFixWasIn<https://twitter.com/hashtag/TheFixWasIn?src=hash>
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Justin Levitt<https://twitter.com/_justinlevitt_/status/1021693278272466945>
✔@_justinlevitt_<https://twitter.com/_justinlevitt_/status/1021693278272466945>

Hi, @rickhasen. This the sort of thing you were talking about?

Dept of Commerce, in May 2017: "We need to work with Justice to get them to request that citizenship be added back as a census question....I will arrange a meeting." https://twitter.com/rickhasen/status/1021636861398200320 …<https://twitter.com/_justinlevitt_/status/1021693278272466945>
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5:56 AM - Jul 24, 2018<https://twitter.com/dale_e_ho/status/1021740911733231617>

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[Share]<https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D100226&title=In%20Adding%20Controversial%20Citizenship%20Question%2C%20Census%20Emails%20Appears%20to%20Show%20Department%20Used%20as%20Pretext%20DOJ%20Need%20for%20Data%20for%20Citizenship%20Data%20for%20Voting%20Rights%20Act%20Cases>
Posted in chicanery<http://electionlawblog.org/?cat=12>

“Protecting Election Integrity: Why Poll Books Matter”<http://electionlawblog.org/?p=100224>
Posted on July 24, 2018 9:11 am<http://electionlawblog.org/?p=100224> by Rick Hasen<http://electionlawblog.org/?author=3>

This post<https://protectdemocracy.org/update/election-integrity-why-poll-books-matter/> appears at Protect Democracy.
[Share]<https://www.addtoany.com/share#url=http%3A%2F%2Felectionlawblog.org%2F%3Fp%3D100224&title=%E2%80%9CProtecting%20Election%20Integrity%3A%20Why%20Poll%20Books%20Matter%E2%80%9D>
Posted in election administration<http://electionlawblog.org/?cat=18>

--
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
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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