[EL] ELB News and Commentary 12/23/20

[Rick Hasen]

Must-Read Ned Foley: “It’s time for Mike Pence to choose: Trump, or the truth”<https://electionlawblog.org/?p=119907>
Posted on December 23, 2020 9:41 am<https://electionlawblog.org/?p=119907> by Rick Hasen<https://electionlawblog.org/?author=3>

WaPo oped:<https://www.washingtonpost.com/opinions/2020/12/22/its-time-mike-pence-choose-trump-or-truth/>

Mike Pence’s conduct on Jan. 6 matters.

Not to the outcome of the presidential election, but to the process of its resolution. The vice president can either facilitate President-elect Joe Biden’s victory, or he can resist it. Which he chooses will either help or hinder the Republican Party’s recovery from the electoral denialism that afflicts three-fourths<https://www.npr.org/2020/12/09/944385798/poll-just-a-quarter-of-republicans-accept-election-outcome> of its voters….

If McConnell can keep his caucus in line, he can prevent a debacle for Republicans — but only if Pence sides with McConnell and thus against Trump’s wishes.

Pence can wreck McConnell’s strategy — even if no GOP senator joins Brooks’s hopeless cause. That’s because on Dec. 14, Republicans in up to seven states<https://www.newsweek.com/lou-dobbs-says-7-states-chose-electors-both-candidates-trump-could-still-win-1555054> — without any official status whatsoever — purported to cast votes for Trump, claiming Trump would have won their states were it not for fraud.

Although transparently farcical, these rival submissions have reportedly been sent to Pence, who must present them at the Jan. 6 session. The law calls for Congress<https://www.justsecurity.org/72700/navigating-a-contested-election-the-electoral-count-act-and-12th-amendment-how-to-ensure-a-fully-counted-outcome/> to consider all “papers purporting to be certificates of electoral votes,” however frivolous they may be.

Pence could support McConnell by asking Congress to reject these ersatz<https://apnews.com/article/election-2020-joe-biden-donald-trump-elections-electoral-college-ab4452c5e54dc55b5e45bbe737ae66ee> — even delusional<https://www.vox.com/22173990/electoral-college-trump-biden-stephen-miller> — documents. Pence would propose that the joint session simply count, without objection, the obviously official votes from these states. This would follow the model set by Richard Nixon, who, in the same position as Pence for the 1960 election<https://constitutioncenter.org/blog/the-drama-behind-president-kennedys-1960-election-win/>, handled conflicting submissions of electoral votes from Hawaii. Nixon asked whether there was any objection to counting the Hawaiian electoral votes cast for Kennedy; there being none, that’s what happened.

No one should object if Pence proposes the equivalent treatment of Biden votes. But even if House members do, without a senator’s objection, Pence’s proposal dictates the disposition of the state’s submissions. McConnell would get his wish.

But suppose, upon announcing rival returns from a state, Pence says something like, “I believe the votes cast for President Trump are the true votes, and I propose that Congress count those.” This would force a senator and representative, presumably Democrats, to object in writing to Pence’s proposal, and the two chambers would separate to debate and vote on this objection.

Should this happen, the Senate and House will certainly agree to count the official electoral votes for Biden and discard the crackpot<https://www.freep.com/story/news/politics/elections/2020/12/16/new-supreme-court-filing-blatantly-wrong-information-michigan/3920800001/> votes for Trump. But Pence’s maneuver would make GOP senators take stands on whether they’re with Biden or Trump, even if McConnell manages to convince his entire caucus not to object to Biden’s votes.
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Posted in electoral college<https://electionlawblog.org/?cat=44>


“How Trump drove the lie that the election was stolen, undermining voter trust in the outcome”<https://electionlawblog.org/?p=119905>
Posted on December 23, 2020 9:35 am<https://electionlawblog.org/?p=119905> by Rick Hasen<https://electionlawblog.org/?author=3>

Amy Gardner for WaPo<https://www.washingtonpost.com/politics/trump-election-voter-trust/2020/12/20/00282aa6-407a-11eb-8db8-395dedaaa036_story.html>:

To preserve his hold on power, Trump has spent the weeks since Election Day promoting falsehoods<https://www.washingtonpost.com/elections/interactive/2020/election-integrity/?itid=lk_inline_manual_9> about voting problems in Georgia and five other states, successfully persuading tens of millions of his supporters to believe a lie — that the election was stolen from him, and from them.

Hehas done so by harnessing the power of his position, using his pulpit at the White House and his Twitter feed to let loose a fusillade of conspiracy theories. His assault on the integrity of the election has gotten a hefty assist from pro-Trump media outfits and an assortment of state lawmakers and lawyers who gave oxygen to the debunked allegations — and a majority of congressional Republicans, who called on the Supreme Court to overturn the results in four states.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“Republicans plunge into open battle over attempts to overturn Trump’s loss to Biden”<https://electionlawblog.org/?p=119903>
Posted on December 23, 2020 9:33 am<https://electionlawblog.org/?p=119903> by Rick Hasen<https://electionlawblog.org/?author=3>

WaPo<https://www.washingtonpost.com/politics/trump-republicans-election-fight/2020/12/22/fa0c2744-446b-11eb-b0e4-0f182923a025_story.html>:

The GOP is plunging into open warfare over President-elect Joe Biden’s election victory — with President Trump taunting Senate Majority Leader Mitch McConnell and threatening primary challenges against other Republicans, House lawmakers egging on senators to contest the counting of electoral college votes next month, and senior GOP senators rebuffing that effort as a pointless political exercise.

And while the internal Republican Party conflict festers, White House officials are scrambling in private to rein in Trump’s increasing embrace of conspiracy theorists as the defeated president and his most ardent allies continue to plot efforts to subvert the outcome of the Nov. 3 election.

But it all appears to have hardened Trump, who — having been out of sight for more than a week — is continuing to push baseless claims of election fraud, while those closest to him are unwilling to challenge him publicly and are instead only bolstering his efforts.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


Here’s What Happens When You Cannot Sue the Electoral College<https://electionlawblog.org/?p=119901>
Posted on December 23, 2020 9:26 am<https://electionlawblog.org/?p=119901> by Rick Hasen<https://electionlawblog.org/?author=3>

LOL<https://twitter.com/bradheath/status/1341794454550814730>:
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“Despite Trump’s intense hunt for voter fraud, officials in key states have so far identified just a small number of possible cases”<https://electionlawblog.org/?p=119899>
Posted on December 23, 2020 9:24 am<https://electionlawblog.org/?p=119899> by Rick Hasen<https://electionlawblog.org/?author=3>

WaPo:<https://www.washingtonpost.com/politics/voter-fraud-investigations-2020/2020/12/22/bdbe541c-42de-11eb-b0e4-0f182923a025_story.html>

After an intense hunt by President Trump’s allies to surface voting irregularities in this year’s election, law enforcement agencies in six key swing states targeted by the president have found just a modest number of complaints that have merited investigation, according to cases tracked by state officials.

So far, only a handful of cases have resulted in actual criminal charges alleging wrongdoing — some of them against Republican voters aiming to help Trump, according to officials, including a man charged Monday with trying to cast a ballot in Pennsylvania for the president in the name of his deceased mother.

The tiny number of incidents further undercut Trump’s barrage of false allegations <https://www.washingtonpost.com/elections/interactive/2020/election-integrity/?itid=lk_inline_manual_11> that there was widespread manipulation of the vote — claims that continue to be echoed <https://www.washingtonpost.com/national-security/trump-biden-voter-fraud-election-security/2020/12/16/c7e75d5a-3fd0-11eb-9453-fc36ba051781_story.html?itid=lk_inline_manual_11> by many Republican officials, including some who acknowledge President-elect Joe Biden’s victory, but assert that fraud was prevalent.

White House Chief of Staff Mark Meadows on Monday wrote in a tweet that there was “mounting evidence of voter fraud” and members of Congress were preparing to “fight back” against it.

In fact, such allegations have been rejected<https://www.washingtonpost.com/politics/judges-trump-election-lawsuits/2020/12/12/e3a57224-3a72-11eb-98c4-25dc9f4987e8_story.html?itid=lk_inline_manual_14> by dozens of judges across the country, a number of whom noted in their decisions that Trump and his allies failed to put forward evidence to support such claims.

The minimal number of criminal investigations that have so far come out of the November vote further reinforce the absence of sweeping vote fraud schemes.
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Posted in chicanery<https://electionlawblog.org/?cat=12>, fraudulent fraud squad<https://electionlawblog.org/?cat=8>


NYT: “A President Unhappy, Unleashed and Unpredictable”<https://electionlawblog.org/?p=119897>
Posted on December 23, 2020 9:17 am<https://electionlawblog.org/?p=119897> by Rick Hasen<https://electionlawblog.org/?author=3>

Maggie Haberman and Michael Schmidt<https://www.nytimes.com/2020/12/23/us/politics/trump-end-of-presidency.html>:

He has otherwise sequestered himself in the White House, playing host to a cast of conspiracy theorists and hard-core supporters who traffic in ideas like challenging the election’s outcome in Congress and even invoking martial law<https://www.nytimes.com/2020/12/20/us/politics/trump-republican-party-future.html>, seeking to give some of them government jobs….

Most of his advisers believe Mr. Trump will depart the White House for a final time by Jan. 20. The pardons he announced Tuesday night suggest he is comfortable using his powers aggressively until then. But how far he will go to subvert the election results, actually refuse to leave the White House or to unleash a wave of unilateral policy decisions in his final weeks is hard to discern.

Still, his erratic behavior and detachment from his duties have even some of his most loyal aides and advisers deeply concerned.

For the moment, Mr. Trump has told advisers he’s willing to stop listening to Sidney Powell, the lawyer who has appealed to him by peddling a conspiracy theory about the election, and people like Patrick Byrne, the former chief executive of Overstock.com, who was present for a wild, nearly five-hour meeting in the Oval Office and then the presidential residence last Friday….

Mr. Trump has turned to aides like Peter Navarro, a trade adviser who has been trying to gather evidence of election fraud to bolster his boss’s claims. And he is listening to Republicans who insist that Vice President Mike Pence could help sway the election during the normally routine process of ratifying the election early next month, despite the fact that it isn’t realistically possible.

Among Republicans on Capitol Hill, there is talk of clamping down on any of his supporters who might try to disrupt that process, a possibility made real by the president’s importuning of Senator-elect Tommy Tuberville of Alabama <https://www.al.com/news/2020/12/donald-trump-spoke-with-tommy-tuberville-who-hinted-at-challenging-to-election-result.html> to gum up the works.

Yet it is not certain that Mr. Tuberville will carry through the president’s desires, and even he if does, there is the possibility that Senator Mitch McConnell of Kentucky, the Republican majority leader, could step in to prevent such a move. Mr. McConnell has already urged his caucus not to raise objections when the results are certified, because it would force others to publicly vote against the president.
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Posted in Election Meltdown<https://electionlawblog.org/?cat=127>


“Evaluating Legislative Districts Using Measures of Partisan Bias and Simulations”<https://electionlawblog.org/?p=119895>
Posted on December 23, 2020 9:13 am<https://electionlawblog.org/?p=119895> by Rick Hasen<https://electionlawblog.org/?author=3>

Barry Burden and Corwin Smidt have written this new article<https://journals.sagepub.com/doi/10.1177/2158244020981054> in SAGE Open. Here is the abstract:

A well-developed body of research offers ways to measure the partisan advantages that result from legislative districting. Although useful to researchers and legal practitioners, those studies also suffer from theoretical, empirical, and legal limitations. In this essay, we review measures of partisan bias and methods for both simulating election results under existing maps and simulating hypothetical maps. We start by describing the concept of partisan bias and how it has been measured. Then, we turn to new simulation methods that generate hypothetical election results or districts to judge the fairness of a map. While both kinds of evaluation are useful, we point to some unresolved questions and areas for future research.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“New Population Estimates Point to Significant Issues in Recent Supreme Court Case”<https://electionlawblog.org/?p=119893>
Posted on December 23, 2020 9:00 am<https://electionlawblog.org/?p=119893> by Rick Hasen<https://electionlawblog.org/?author=3>

Election Data Services analysis<https://www.electiondataservices.com/wp-content/uploads/2020/12/NR_Appor20wTableMaps.pdf>:

New Census Bureau population estimates for 2020 released today shows a subtle but significant change in the upcoming apportionment process, that is front and center in the Supreme Court’s decision last week in New York v. Trump. The population impacts whether the state of New York loses either one or two congressional districts and whether that seat goes to Alabama if the current estimate numbers were used for apportionment in 2020. These numbers are only estimates and reflect a normal Census Bureau practice of generating population estimates each year from reviewing birth, death and immigration records. These ARE NOT reflecting results from the actual 2020 Census collection efforts from this year, as those numbers are not expected out until sometime in January 2021.

Today’s population estimates reflect numbers as of July 1, 2020, after the official date of April 1, 2020 that is commonly used for Census Day. In all other years of this decade, Election Data Services has aged (added to) the population estimates released yearly by the Census Bureau an additional nine months to bring them in line with Census Day. Because today’s population estimates are pegged to a date after Census Day, for this year’s study we have subtracted a quarter of the year’s growth to move the estimates back to April 1, 2020. While this was done for consistence with previous studies this decade, the Covid pandemic has caused changes in Census practices for the actual counting process in 2020, most importantly in drawing out the timetable for survey collection. As a result, we are releasing apportionment estimates for both April 1, 2020 and July 1, 2020.

That subtle three month change in population estimates will determine whether Alabama loses a Congressional District, as the back-dated April 2020 data shows the loss by only 5,170 people (that seat would have been #436 in the apportionment process, one away from the 435 cut-off point.) The state of Alabama is currently involved in a court case called State of Alabama v. US Department of Commerce where the state has made the claim that their loss of a congressional district is due to the inclusion of illegal aliens in the census count. But Alabama’s loss would change to no-change in their number of Congressional Districts if the new Census estimates for July 1 were instead used for apportionment. Alabama would keep their 7th seat (seat #435) by only 6,120 people to spare without regard to whether illegal aliens were counted in the census or not.
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Posted in census litigation<https://electionlawblog.org/?cat=125>


Important Cybersecurity Measures Congress Approved in the NDAA<https://electionlawblog.org/?p=119889>
Posted on December 23, 2020 4:58 am<https://electionlawblog.org/?p=119889> by Richard Pildes<https://electionlawblog.org/?author=7>

I haven’t seen much coverage of these measures that come out of the bipartisan Cyberspace Solarium Commission (which included executive branch members) Congress had created before the Solar Winds story broke. The NDAA includes 26 amendments the commission recommended on cybersecurity, with more new legislation hopefully to come, based on the excellent work of this commission. For a good piece on the structure of this commission, see here<https://www.washingtonpost.com/opinions/we-werent-ready-for-a-pandemic-we-better-be-ready-for-a-cyberattack/2020/03/12/b5f034fc-6496-11ea-b3fc-7841686c5c57_story.html>.

The President has threatened to veto the NDAA, which was enacted with veto-proof support.

This coverage<https://govmatters.tv/cyberspace-solarium-commission-amendments-in-the-ndaa/> comes from Government Matters:

The Solarium pitched 34 amendments to the NDAA this year, and 26 made it to the final draft. The Commission has a total of 52 amendments it plans to give to Congress. Rather than submitting ideas to Congress, the Solarium submitted fully-drafted bills with legislative language. King said this made it easier for legislators to get onboard.

“Instead of leaving [legislators] to do the work, we did it for them and said, ‘here’s the proposal, here’s the language, all you have to do is say yes,’” King said.

He said having members of the Solarium in Armed Services Committees in both the House and Senate also made it easier to pass the amendments. The process, though, King said was “a heck of a lot of work.”

“In order to get those recommendations into the bill, we had to get 180 clearances from both sides of all kinds of committees on Capitol Hill,” he said. “It was really a monumental undertaking.”

King credits his staff for the Solarium’s achievements in the NDAA, and says he plans to continue to push for Solarium amendments in the future.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“Inside Trump’s pressure campaign to overturn the election”–Politico Reports Trump Tried to Pressure at Least 31 Republican Leaders Across the U.S.<https://electionlawblog.org/?p=119886>
Posted on December 22, 2020 3:28 pm<https://electionlawblog.org/?p=119886> by Rick Hasen<https://electionlawblog.org/?author=3>

Politico:<https://www.politico.com/news/2020/12/21/trump-pressure-campaign-overturn-election-449486?utm_campaign=wp_the_trailer&utm_medium=email&utm_source=newsletter&wpisrc=nl_thetrailer>

Over the next month, the president would conduct a sweeping campaign to personally cajole Republican Party leaders across the country to reject the will of the voters and hand him the election. In his appeals, he used specious and false claims of widespread voter fraud, leaning on baseless allegations that corrupt Democrats had conspired at every level to steal a presidential election.

In total, the president talked to at least 31 Republicans, encompassing mostly local and state officials from four critical battleground states he lost — Michigan, Arizona, Georgia and Pennsylvania. The contacts included at least 12 personal phone calls to 11 individuals, and at least four White House meetings with 20 Republican state lawmakers, party leaders and attorneys general, all people he hoped to win over to his side. Trump also spoke by phone about his efforts with numerous House Republicans and at least three current or incoming Senate Republicans.

And it all occurred in parallel to his campaign’s quixotic efforts to launch recounts and file lawsuits demanding ballots be tossed.<https://www.politico.com/news/2020/11/19/trump-theatrics-election-fights-fizzle-438539>

Trump’s efforts to cling to power are unprecedented in American history. While political parties have fought over the results of presidential elections before, no incumbent president has ever made such expansive and individualized pleas to the officials who oversee certification of the election results. Trump even used his presidential perch to compel officials to talk with him, summoning state officials to the White House on a few-hours notice and insisting that his outreach was simply part of his presidential duties.

This recounting of that pressure campaign is based on interviews with 22 Trump aides, local and states officials, Republicans and elections experts. POLITICO also reached out to the Republicans Trump contacted, but all requests for comment except one went unanswered. The White House referred questions to the Trump campaign, which declined to comment or make an attorney available for an interview.
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Posted in chicanery<https://electionlawblog.org/?cat=12>, Election Meltdown<https://electionlawblog.org/?cat=127>


“James Clyburn: Runoff elections suppress Black representation. Relegate them to the past.”<https://electionlawblog.org/?p=119884>
Posted on December 22, 2020 3:05 pm<https://electionlawblog.org/?p=119884> by Rick Hasen<https://electionlawblog.org/?author=3>

WaPo oped.<https://www.washingtonpost.com/opinions/james-clyburn-runoff-elections-voting-rights/2020/12/22/2eb0827e-446c-11eb-b0e4-0f182923a025_story.html>
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“Republicans Are Facing Very Real Legal Consequences From Trump’s Voter Fraud Lies”<https://electionlawblog.org/?p=119882>
Posted on December 22, 2020 2:29 pm<https://electionlawblog.org/?p=119882> by Rick Hasen<https://electionlawblog.org/?author=3>

Zoe Tillman<https://www.buzzfeednews.com/article/zoetillman/republicans-legal-consequences-trump-voter-fraud-lies> for BuzzFeed:

President Donald Trump and his conservative allies are facing the prospect of very real legal consequences after weeks<https://www.buzzfeednews.com/collection/2020election> of pushing false claims of widespread voter fraud.

On Tuesday, a voting rights group filed a lawsuit that accuses Trump and the Republican National Committee of conspiring to violate the rights of Black voters. The lawsuit doesn’t just ask the judge to stop Trump and the GOP from taking any more steps to overturn or undermine the election results this year; the challengers are also asking for an order that could force the president and the RNC to get court approval before demanding recounts or participating in other “post-election activities” in the future.

The new court action comes just a few years after a federal judge in New Jersey in January 2018 lifted a decades old court-monitored settlement that barred the RNC from engaging in “ballot security” activities based on the “racial or ethnic composition” of a particular community. The RNC signed the agreement<https://www.brennancenter.org/sites/default/files/2020-07/1982%20consent%20decree.pdf> in 1982 to settle claims<https://www.brennancenter.org/sites/default/files/legacy/Democracy/dnc.v.rnc/1981%20complaint.pdf> that it had tried to intimidate, threaten, and disenfranchise voters through voter roll purges and by paying police officers to patrol polling sites in predominantly Black and Latino areas under the guise of preventing election fraud.

The new lawsuit — which is an expanded version<https://assets.documentcloud.org/documents/20434046/12-21-20-michigan-welfare-rights-v-trump-amended-complaint-redline.pdf> of a case that the NAACP Legal Defense and Educational Fund (LDF) filed last month in federal court in Washington, DC, against Trump and his campaign alone — accused the president and Republican Party officials of deliberately focusing their postelection challenges on cities with large Black populations<https://www.buzzfeednews.com/article/paulmcleod/trump-wisconsin-recount-black-voters>, such as Detroit, Milwaukee, Philadelphia, and Atlanta. The latest iteration of the lawsuit brings claims under the federal Voting Rights Act and the Ku Klux Klan Act<https://history.house.gov/Historical-Highlights/1851-1900/hh_1871_04_20_KKK_Act/>.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


Wisconsin: “Trump Carried Counties Where Many Voters Avoided ID Rules”<https://electionlawblog.org/?p=119878>
Posted on December 22, 2020 2:04 pm<https://electionlawblog.org/?p=119878> by Rick Hasen<https://electionlawblog.org/?author=3>

Milwaukee Journal-Sentinel<https://www.jsonline.com/story/news/politics/elections/2020/12/22/trump-carried-counties-where-many-voters-avoided-id-rules/3920405001/>:

More Wisconsin voters were allowed to vote absentee without showing photo identification in counties Donald Trump won than in counties that backed Joe Biden, a new analysis shows…

A Milwaukee Journal Sentinel review shows 123,357 voters in the 58 counties Trump carried claimed to be indefinitely confined on the basis of age, physical illness or disability which allowed them to bypass the photo identification requirement.

In the 14 counties Biden won en route to a 21,000-vote victory, 92,356 voters listed themselves as indefinitely confined.

The finding comes as Trump and other Republicans argue the dramatic increase in indefinitely confined voters this year, including by two Democratic lawmakers who have appeared at public events, is a sign the system is being abused.
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Posted in absentee ballots<https://electionlawblog.org/?cat=53>


New York: “Cuomo Signs Automatic Voter Reg­is­tration Measure”<https://electionlawblog.org/?p=119876>
Posted on December 22, 2020 12:16 pm<https://electionlawblog.org/?p=119876> by Rick Hasen<https://electionlawblog.org/?author=3>

Spectrum News:<https://spectrumlocalnews.com/nys/central-ny/ny-state-of-politics/2020/12/22/cuomo-signs-automatic-voter-registration-measure>

Gov. Andrew Cuomo on Tuesday approved a long-sought bill creating a system of automatic voter registration at multiple state agencies in New York.

“The right to vote is one of, if not the most, sacred pillars of our democracy and for too long, bureaucratic red tape has made it unnecessarily difficult for New Yorkers to exercise this right,” Cuomo said.

“From instituting early voting to making necessary reforms to the absentee ballot process, New York has already made elections more accessible, but we are far from finished. With this new law on the books, we are taking this work a step further and not only instituting automatic voter registration, but creating a single uniform platform for registering online.”

The new law is meant to expand voter registration in the state and make it easier to do so when a person interacts with a state agency like the Department of Motor Vehicles.
[Share]<https://www.addtoany.com/share#url=https%3A%2F%2Felectionlawblog.org%2F%3Fp%3D119876&title=New%20York%3A%20%E2%80%9CCuomo%20Signs%20Automatic%20Voter%20Reg%C2%ADis%C2%ADtration%20Measure%E2%80%9D>
Posted in Uncategorized<https://electionlawblog.org/?cat=1>


Matt Masterson Gives NPR’s Pam Fessler First Interview After Leaving Gov’t: “Former Election Security Official Says It Will Take ‘Years’ To Undo Disinformation”<https://electionlawblog.org/?p=119874>
Posted on December 22, 2020 12:12 pm<https://electionlawblog.org/?p=119874> by Rick Hasen<https://electionlawblog.org/?author=3>

NPR:<https://www.npr.org/2020/12/22/949157510/former-election-security-official-says-it-will-take-years-to-undo-disinformation?utm_campaign=storyshare&utm_source=twitter.com&utm_medium=social>

One of the top federal officials responsible for securing the nation’s elections is speaking out days after leaving his job with the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency.

Matthew Masterson was a senior cybersecurity adviser at CISA, primarily responsible for elections, and his departure comes amid persistent, but baseless, claims that the 2020 elections were riddled with fraud. Many of those have come from President Trump, who last month fired Masterson’s former boss, Christopher Krebs, after Krebs joined others in calling the 2020 election the “most secure in American history.” Trump’s allegations have been widely disputed by election experts and numerous courts, where his campaign has tried unsuccessfully to overturn the election results.

In his first interview since leaving his job, Masterson told NPR that the biggest challenge for the nation now is restoring public faith in the voting process. Recent polls have shown <https://www.npr.org/2020/12/09/944385798/poll-just-a-quarter-of-republicans-accept-election-outcome> that a large segment of the electorate, including a majority of Republicans, does not trust that this year’s results were legitimate.Article continues after sponsor message

Masterson believes, on the contrary, that the 2020 vote was “as smooth a presidential election as I’ve ever seen.” He noted recent improvements in election security and transparency, including expanded use of paper ballots and audits, as well as streaming live video of vote counts.

“Yet we’re still beating back disinformation and claims of technical manipulation that just simply aren’t true,” he said. “So we’ve got to continue to explore how to offer voters more and more evidence, in a transparent fashion, to reassure them that their vote was counted as cast.”
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“Trump supporters asked me to look into voter fraud in Nevada; what I found debunked what they were alleging”<https://electionlawblog.org/?p=119872>
Posted on December 22, 2020 12:09 pm<https://electionlawblog.org/?p=119872> by Rick Hasen<https://electionlawblog.org/?author=3>

Nevada Independent:<https://thenevadaindependent.com/article/trump-supporters-asked-me-to-look-into-voter-fraud-in-nevada-what-i-found-debunked-what-they-were-alleging>

As in any process involving people, there will be mistakes. There will even be a few people who either through ignorance or deceit will vote more than once. (Nevada participates in a 30-state consortium to catch people who vote in more than one state — there are a few hundred nationwide each election.)

But I found nothing in the data that shows the election was rigged.

If anything, there are a few small factors that tilt slightly in favor of Republicans. Yet, overall trust in elections has plummeted among Republicans. According to Morning Consult polls<https://morningconsult.com/form/tracking-voter-trust-in-elections/> prior to the election, 66 percent of GOP voters said they had at least some trust in the U.S. election system. In the latest poll (Dec. 15th), that number dropped to 33 percent. Democratic trust, meanwhile, jumped from 63 percent to 83 percent.

(If it wasn’t fraud, why did President Trump lose Nevada? See Part II of my deep dive into the Nevada election data, coming Wednesday.)

While I can’t argue that the system isn’t transparent (I’ve performed all this analysis and interviews based on publicly available data, and public access), I do think the system lacks visibility. The difference between visibility and transparency is the degree to which the ordinary voter is provided visual proactive updates in a manner that is easy to digest.

Frankly, as an ordinary consumer, I get better tracking and visibility in monitoring a delivery from Amazon than I do from something significantly more important — my vote. It is only because I applied my analytic training and put in many hours of work that I could rule out widespread fraud and increase my own trust in our election process. Perhaps it shouldn’t be so time-consuming or difficult for voters to see the data which addresses doubt about voter fraud.

Increasing visibility and faith in our democratic system of electing our representatives is in everyone’s best interest. It is my view that our state should make a concerted effort to better map the citizen’s voting journey, including clear updates for the individual’s vote, as well as a view of the overall patterns for the county — including one-tap access to videos of the voting and counting processes.

A bipartisan team should reach agreement on enhanced and digitized citizen observation of the voting process. This will increase visibility so there is greater trust in the system and less room for conspiracy theories to grow. It won’t convince those who will believe what they want to believe regardless of the facts, but it will help a meaningful percent of citizens who would like the reassurance of tracking their vote — and being able to see that careful checks for anomalies were conducted in order to rule out fraud and contextualize clerical mistakes.
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Posted in fraudulent fraud squad<https://electionlawblog.org/?cat=8>


“Nessel to seek sanctions against some lawyers challenging Michigan’s election results”<https://electionlawblog.org/?p=119870>
Posted on December 22, 2020 12:05 pm<https://electionlawblog.org/?p=119870> by Rick Hasen<https://electionlawblog.org/?author=3>

Detroit News:<https://www.detroitnews.com/story/news/local/michigan/2020/12/22/nessel-seek-sanctions-against-lawyers-challenging-election-results/4009929001/>

Attorney General Dana Nessel said she plans to seek sanctions against lawyers who filed lawsuits against the state’s election results that contained “intentional misrepresentations” regarding Michigan’s elections.

The Democratic attorney general also plans to pursue court costs and fees and, along with Secretary of State Jocelyn Benson, to file complaints with the attorney grievance commission, Nessel told reporters Tuesday.

The requests will likely be made after the cases have been closed out, she said.

“Some of these cases where we know for a fact there were intentional misrepresentations made — the kind of misrepresentation that there is no question of fact that these were inaccurate statements that were presented to the court — yes, myself and also Secretary Benson, will be filing complaints to the attorney grievance commission,” Nessel said.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


Arizona: “Maricopa County supervisors sue rather than comply with senator’s subpoenas for election materials”<https://electionlawblog.org/?p=119868>
Posted on December 22, 2020 11:57 am<https://electionlawblog.org/?p=119868> by Rick Hasen<https://electionlawblog.org/?author=3>

Tucson.com:<https://tucson.com/news/local/maricopa-county-supervisors-sue-rather-than-comply-with-senators-subpoenas-for-election-materials/article_d8182783-1452-5773-9da1-11d1edf9db4c.html>

Maricopa County supervisors voted Friday to not comply with subpoenas for election materials issued by the chairman of the state Senate Judiciary Committee.

The subpoenas demanded access to copies of the more than 2 million ballots cast by Maricopa County voters in the Nov. 3 election, and for access to the equipment used to tabulate those ballots and the software that ran the equipment.

The 4-1 vote to refuse, following a nearly three-hour executive session with attorneys, came amid concerns that at least some of what is being demanded by Sen. Eddie Farnsworth, R-Gilbert, would expose private information on voters.

There also were questions about whether the county has the legal right to give that information to outsiders.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


Shana Broussard, First African-American Member of the Federal Election Commission, Elected Its New Chair; Allen Dickerson, Formerly of the Institute for Free Speech, Elected Vice Chair<https://electionlawblog.org/?p=119866>
Posted on December 22, 2020 11:38 am<https://electionlawblog.org/?p=119866> by Rick Hasen<https://electionlawblog.org/?author=3>

Congratulations!<https://twitter.com/myhlee/status/1341454505200791555>
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Posted in federal election commission<https://electionlawblog.org/?cat=24>


“A Delay In Census Results Would Hinder States’ Redistricting Efforts”<https://electionlawblog.org/?p=119864>
Posted on December 22, 2020 11:35 am<https://electionlawblog.org/?p=119864> by Rick Hasen<https://electionlawblog.org/?author=3>

NPR reports.<https://www.npr.org/2020/12/22/949078378/a-delay-in-census-results-would-hinder-states-redistricting-efforts>
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Posted in census litigation<https://electionlawblog.org/?cat=125>, redistricting<https://electionlawblog.org/?cat=6>


Derek Muller: “Iowa’s Second Congressional District Contest Should Be Dismissed for Lack of Exhaustion of State Remedies”<https://electionlawblog.org/?p=119861>
Posted on December 22, 2020 11:32 am<https://electionlawblog.org/?p=119861> by Rick Hasen<https://electionlawblog.org/?author=3>

The following is a guest post from Derek Muller<https://law.uiowa.edu/derek-t-muller> about Iowa’s Second Congressional District Contest:

Iowa’s Second Congressional District is officially one of the closest congressional elections in American history. Congresswoman-Elect Mariannette Miller-Meeks led by 47 votes after the official canvass. After challenger Rita Hart requested a recount in all 24 counties, Miller-Meeks led by just six votes. Miller-Meeks received a certificate of election from the state and will be seated, absent an extraordinary move from the House of Representatives, in the 117th Congress.

Hart has filed an election contest<https://www.democracydocket.com/wp-content/uploads/sites/45/2020/12/IA-02-Notice-of-Contest-and-Appendix-Scan1.pdf> under the Federal Contested Elections Act of 1969. Under the Constitution, each House is “the judge of the elections, returns and qualifications of its own members.” In doing so, however, Hart skipped the opportunity to file an election contest in Iowa courts.

Hart’s lead-up to the election contest was a thaumatrope. On one side, the Hart campaign alleged that not all the votes were counted, and every vote needed to be counted. On the other side, the Hart campaign complained that the time to seek an election contest in state court was too short, so the House was the only mechanism for it. Spinning this thaumatrope, the two claims appeared as a single concern.

But now that the contest has been filed, we see two distinct claims. The first are discrete claims about twenty-two ballots that were not counted that the Hart campaign argues should have been counted, amply within the window of a state court contest to resolve. The second are sweeping claims asking for, effectively, a second recount (or a third count) of thousands of ballots, something a contest court would never have entertained because Hart would have been estopped from raising it.

I’ll provide an overall setup of the dispute, then dig into some of the specific claims Hart raises in the contest. I’ll refer to some of the points in the Notice of Contest, but I’ll also refer to relevant facts omitted from the Notice. But in short, Hart raises two types of claims, and both should be dismissed, in my judgment, on fairly straightforward procedural grounds: the first claim should be dismissed for lack of exhaustion; the second claim should be dismissed for estoppel, waiver, or laches.
Continue reading →<https://electionlawblog.org/?p=119861#more-119861>
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Posted in legislation and legislatures<https://electionlawblog.org/?cat=27>, recounts<https://electionlawblog.org/?cat=50>


“Atty Lin Wood Under Fire From Del. Judge For Election Suits”<https://electionlawblog.org/?p=119859>
Posted on December 22, 2020 11:27 am<https://electionlawblog.org/?p=119859> by Rick Hasen<https://electionlawblog.org/?author=3>

Law360<https://www.law360.com/articles/1339984/atty-lin-wood-under-fire-from-del-judge-for-election-suits>:

Attorney L. Lin Wood’s representation of former Trump adviser Carter Page in Delaware state court could be revoked based on his conduct in suits challenging the results of the general election as a plaintiff in Georgia and as counsel in Wisconsin, a state court judge said Friday.

Delaware Superior Court Judge Craig A. Karsnitz ordered Wood to show why his representation of Page in the case should not be revoked, given that Wood’s Georgia suit was found to have “no basis in fact or law” and the Wisconsin suit had “multiple deficiencies.”

Wood, a high-profile trial attorney in Atlanta, was given permission to represent Page in the Delaware suit in August but, Judge Karsnitz said, the cases filed since the election appear to violate the Delaware Lawyers’ Rules of Professional Conduct.
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Posted in chicanery<https://electionlawblog.org/?cat=12>, fraudulent fraud squad<https://electionlawblog.org/?cat=8>


“Trump and Republican officials have won zero out of at least 40 lawsuits they’ve filed since Election Day”<https://electionlawblog.org/?p=119857>
Posted on December 22, 2020 11:25 am<https://electionlawblog.org/?p=119857> by Rick Hasen<https://electionlawblog.org/?author=3>

Business Insider reports.<https://www.yahoo.com/news/legal-challenges-trumps-campaign-filed-040346070.html?guccounter=1>
[Share]<https://www.addtoany.com/share#url=https%3A%2F%2Felectionlawblog.org%2F%3Fp%3D119857&title=%E2%80%9CTrump%20and%20Republican%20officials%20have%20won%20zero%20out%20of%20at%20least%2040%20lawsuits%20they%E2%80%99ve%20filed%20since%20Election%20Day%E2%80%9D>


Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“Misinformation Amplifiers Target Georgia Senate Races; The conservative social media personalities who spread baseless rumors of election fraud are starting to focus on the races that will decide control of the Senate.”<https://electionlawblog.org/?p=119855>
Posted on December 22, 2020 11:14 am<https://electionlawblog.org/?p=119855> by Rick Hasen<https://electionlawblog.org/?author=3>

NYT:<https://www.nytimes.com/2020/12/22/technology/georgia-senate-runoff-misinformation.html>

Two weeks ago, the conservative media personalities Diamond and Silk falsely claimed on their Facebook page that people who were not eligible to vote were receiving ballots in Georgia’s special elections next month. Their post was shared more than 300 times.

A week later, the right-wing commentator Mark Levin shared a post on his Facebook page falsely suggesting that the Rev. Raphael Warnock, one of the two Democrats running in the Georgia Senate runoffs, once welcomed Fidel Castro to his church. The misleading claim was shared more than 3,000 times.

At the same time, a drumbeat of misinformation about the presidential election count in Georgia droned on. Lara Trump, President Trump’s daughter-in-law, and the Hodgetwins, a bodybuilding duo who have turned to pro-Trump political comedy, shared several false stories on their Instagram and Facebook pages that claimed suitcases filled with ballots were pulled out from under tables during the November vote count. Tens of thousands of people shared their posts.

As Georgia prepares to hold special elections that will determine which party will control the U.S. Senate<https://www.nytimes.com/2020/12/15/us/politics/biden-georgia-senate.html>, the state has become the focus of a misinformation campaign that is aimed at discrediting the results of the November elections and convincing voters that Democrats are trying to steal the upcoming vote.
[Share]<https://www.addtoany.com/share#url=https%3A%2F%2Felectionlawblog.org%2F%3Fp%3D119855&title=%E2%80%9CMisinformation%20Amplifiers%20Target%20Georgia%20Senate%20Races%3B%20The%20conservative%20social%20media%20personalities%20who%20spread%20baseless%20rumors%20of%20election%20fraud%20are%20starting%20to%20focus%20on%20the%20races%20that%20will%20decide%20control%20of%20the%20Senate.%E2%80%9D>
Posted in cheap speech<https://electionlawblog.org/?cat=130>, chicanery<https://electionlawblog.org/?cat=12>, fraudulent fraud squad<https://electionlawblog.org/?cat=8>


“POLITICO Playbook PM: Deep dive: Electoral College on the Hill”<https://electionlawblog.org/?p=119853>
Posted on December 22, 2020 11:04 am<https://electionlawblog.org/?p=119853> by Rick Hasen<https://electionlawblog.org/?author=3>

Interesting stuff on the VP here<https://www.politico.com/newsletters/playbook-pm/2020/12/22/deep-dive-electoral-college-on-the-hill-491225?nname=playbook-pm&nid=0000015a-dd3e-d536-a37b-dd7fd8af0000&nrid=0000014e-f109-dd93-ad7f-f90d0def0000&nlid=964328>:

THE VP TYPICALLY presides over the certification in his role as the president of the Senate. JONATHAN SWAN<https://www.axios.com/trump-white-house-conspiracy-theories-d95450a4-c7a3-4579-a568-0473b18529c9.html> from Axios had an excellent report this morning about how President DONALD TRUMP is turning on everyone, and how he would view MIKE PENCE certifying the results of the election as “the ultimate betrayal.”

WELL, PENCE DOESN’T HAVE TO if he doesn’t want to. If PENCE declines to show up, Sen. CHUCK GRASSLEY, the 87-year-old Iowa Republican who is president pro tempore of the Senate, does it in his place. No sweat, no problem.

IN 1969, HUBERT HUMPHREY declined to preside over the certification because he was the losing presidential candidate. So Deschler’s Precedents — which governs some of the instances that arise in the House — says this in Sec. 2.5 of chapter 10: “In the absence of the President of the Senate, the President pro tempore of the Senate presides over the joint session to count the electoral votes for President and Vice President.” This is the precedent that was set in 1969. (h/t this terrific CRS report<https://crsreports.congress.gov/product/pdf/RL/RL32717> about the process by which Congress will certify the Electoral College)

OF COURSE, declining to show up is probably as bad as showing up and certifying the results, in TRUMP’S mind.

THE LARGER MORAL QUESTION is canPENCE preside if he has already been strategizing with the opposition.

AND TWO UNANSWERED questions that may have to be decided by Congress’ rules authorities in the coming days and weeks:
1.       Can Congress vote to reject PENCE as the presiding officer because he has a stake in the outcome? Congress can practically do anything it wants with a majority vote.
2.       If PENCE does preside and goes to bat for TRUMP, can Congress overturn an unjust or improper ruling? This is also an open question.

JAN. 6 will be a long day, given TRUMP has a crew of House Republicans willing to follow him down this idiotic rabbit hole. But this is going to fail in a spectacular fashion.
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Posted in electoral college<https://electionlawblog.org/?cat=44>, legislation and legislatures<https://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 - 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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