[EL] 8th Circuit 2-1 decision cuts back Minnesota deadline; more news and commentary

Fri Oct 30 06:20:21 PDT 2020

I made no comment about the Eighth Circuit's decision.  I was merely
responding to Sam's point.

JHA

Jonathan H. Adler
jha5 at case.edu

On Fri, Oct 30, 2020, 9:18 AM Marty Lederman <
Martin.Lederman at law.georgetown.edu> wrote:

> As it happens, the statute in question *does *have a rather "objectively
> discernible" meaning, and it's one that *supports *the Secretary here.  Section
> 204B.47 provides: “When a provision of the Minnesota Election Law cannot
> be implemented as a result of an order of a state or federal court, the secretary
> of state *shall* adopt alternative election procedures to permit the administration
> of any election affected by the order.”
>
> The statutory receipt deadline here can't be implemented because of an
> order of a state court (the approval and entry of the consent decree), and
> therefore the Secretary was using a Nov. 10 deadline, in conformity with
> that court order, just as Section 204BB.47 *requires *him to do
> ("shall").  For a federal court to conclude that this reasonable (indeed,
> objectively discernible) state judicial and executive reading of a state
> statute is so unreasonable as to require an injunction, well, I'm not even
> sure how to describe that.
>
>
> On Fri, Oct 30, 2020 at 8:48 AM Jonathan Adler <jha5 at case.edu> wrote:
>
>> Only if one concludes that the state statute lacks an objectively
>> discernible meaning or range of permissible meanings.
>>
>>
>> ----
>> Jonathan H. Adler
>> Johan Verheij Memorial Professor of Law
>> Director, Coleman P. Burke Center for Environmental Law
>> Case Western Reserve University School of Law
>> 11075 East Boulevard
>> Cleveland, OH 44106
>> ph) 216-368-2535
>> fax) 216-368-2086
>> cell) 202-255-3012
>> jha5 at case.edu
>> SSRN: http://ssrn.com/author=183995
>> Blog: https://reason.com/people/jonathan-adler/
>> Web: http://www.jhadler.net
>>
>>
>>
>>
>> On Fri, Oct 30, 2020 at 8:28 AM Samuel Bagenstos <sbagen at gmail.com>
>> wrote:
>>
>>> Can I ask a naive question?  If SCOTUS is telling us that a state court
>>> or other state entity impermissibly deviated from a state statute, isn't
>>> SCOTUS violating Article II by displacing the role of the state
>>> legislature?  I think this Article II theory logically cannibalizes
>>> itself.  Not that logic means anything, especially.
>>>
>>> On Fri, Oct 30, 2020, 8:25 AM Lori A Ringhand <ringhand at uga.edu> wrote:
>>>
>>>> It is striking to me how much these opinions (and the debate
>>>> surrounding them) have surpassed even the three-justice plurality in *Bush
>>>> v. Gore*.  Justice Rehnquist's opinion in that case decidedly did not
>>>> say that decisions of the state supreme court, the secretary of state, or
>>>> the Florida canvassing boards were invalid simply because these bodies are
>>>> not "the legislature." Instead, the opinion rested on the idea that the
>>>> state supreme court's interpretation of state law was unreasonable and
>>>> therefore exceeded its authority, *not *that the Constitution requires
>>>> that it or any other of these entities need to be cut out of the regular
>>>> state law process as a matter of course. The opinion even talks
>>>> (approvingly) of how state law vests discretion over recounts in the
>>>> canvassing boards, and how the state supreme court opinion deviated from
>>>> established practice "prescribed by the Secretary."
>>>>
>>>> Lori A. Ringhand
>>>> Fulbright Scotland Visiting Professor, University of Aberdeen
>>>> J. Alton Hosch Professor of Law, University of Georgia
>>>> Athens, GA 30601
>>>>
>>>> ringhand at uga.edu
>>>> http://papers.ssrn.com/sol3/cf_dev/AbsByAuth.cfm?per_id=332414
>>>>
>>>>
>>>> ------------------------------
>>>> *From:* Law-election <law-election-bounces at department-lists.uci.edu>
>>>> on behalf of Schultz, David <dschultz at hamline.edu>
>>>> *Sent:* Thursday, October 29, 2020 9:29 PM
>>>> *To:* Levitt, Justin <justin.levitt at lls.edu>
>>>> *Cc:* Election Law Listserv <law-election at uci.edu>
>>>> *Subject:* Re: [EL] 8th Circuit 2-1 decision cuts back Minnesota
>>>> deadline; more news and commentary
>>>>
>>>> [EXTERNAL SENDER - PROCEED CAUTIOUSLY]
>>>>
>>>> Hi all:
>>>> Justin basically gets the analysis right for Minnesota and it sets up a
>>>> potential duality between state and federal races.  There is state law that
>>>> mandates the requirements for absentee ballots and early voting that
>>>> require signature requirements and as the Frankencase stipulated, strict
>>>> compliance.
>>>>
>>>> It should also be noted that many of the ballots already in are from
>>>> DFL areas and that any of ballots still to come in may be from Republican
>>>> areas.  This decision may well hurt GOP voters more than Democrats,
>>>> especially with the delays in mail especially from  rural areas.
>>>>
>>>> On Thu, Oct 29, 2020 at 7:59 PM Levitt, Justin <justin.levitt at lls.edu>
>>>> wrote:
>>>>
>>>> In the Coleman-Franken contest, as I recall, the Minnesota Supreme
>>>> Court said that Minnesota law required *that the voter* maintain
>>>> “strict” compliance with all statutory requirements (for absentee
>>>> ballots).  In contrast, the court traced a 144-year history of finding that
>>>> if a voter complies with the law, his vote “should not be rejected because
>>>> of irregularities, ignorance, inadvertence, or mistake, or even intentional
>>>> wrong on the part of the election officers.”  767 N.W.2d 453, 462 (2009).
>>>>  The original 1865 case refused to invalidate an election when certain
>>>> pollworkers didn’t take an oath, despite facially plausible arguments based
>>>> on the statutory structure that by declaring that elections shouldn’t be
>>>> invalidated for X and Y reason, the legislature implied elections
>>>> *should* be invalidated based on a failure of the oath.  That logic
>>>> was based on the state constitution … and seems (I’d hope) uncontroversial.
>>>>
>>>>
>>>>
>>>> The Eighth Circuit today, citing SCOTUS dicta, says that the
>>>> legislature’s power in Presidential elections can’t be modified by state
>>>> constitutions.  And the Coleman-Franken court didn’t cite a state statute
>>>> for its interpretation (maybe a Minnesota expert will let me know if one
>>>> exists).  So barring a state statute on point, I presume that that line of
>>>> caselaw in Minnesota is now invalid in the Eighth Circuit for federal
>>>> elections.  I’d hope that the principle is still a part of federal law.
>>>> But as a matter of state law under the Eighth Circuit’s decision, when the
>>>> ballots go to be counted in Minnesota, doesn’t this mean that
>>>> election-official mistakes in statutes that purport to be mandatory,
>>>> however minor, don’t invalidate a ballot for state races, but maybe might
>>>> invalidate a ballot for federal races?  Does that latter conclusion depend
>>>> on an interpretation of the state statutory structure based on something
>>>> other than background state legal principles (and if so, where does it come
>>>> from?), for rules that state statutes purport to make mandatory?
>>>>
>>>>
>>>>
>>>> There’s still an oath requirement in Minnesota law – 204B.24 requires
>>>> “each” poll worker to sign a very specific oath and attach that statement
>>>> to the election returns of the precinct, which implies that the oath is of
>>>> some significance specifically related to the validity of the returns.  If
>>>> there’s a printing error on the oath paper so that the oath isn’t exactly
>>>> as prescribed in statute, or if one of several poll workers fails to sign
>>>> the oath, I certainly hope that doesn’t invalidate the election-day
>>>> precinct returns for all of the federal candidates on the ballot there.
>>>>
>>>>
>>>>
>>>> And yes, that conclusion would be absurd.
>>>>
>>>>
>>>>
>>>> But would it be absurd based on the actual text of the state statutes
>>>> passed by the state Legislature, or based on something else?
>>>>
>>>>
>>>>
>>>> *From:* Law-election <law-election-bounces at department-lists.uci.edu> *On
>>>> Behalf Of *Rick Hasen
>>>> *Sent:* Thursday, October 29, 2020 4:05 PM
>>>> *To:* Election Law Listserv <law-election at uci.edu>
>>>> *Subject:* [EL] 8th Circuit 2-1 decision cuts back Minnesota deadline;
>>>> more news and commentary
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> In Outrageous 2-1 Decision Ignoring Reliance Interests and Rejecting
>>>> the Purcell Principle, 8th Circuit Panel Orders Segregation of Late
>>>> Arriving Ballots in Minnesota, With Strong Hints Late Arriving Ballots Will
>>>> Be Excluded from The Count <https://electionlawblog.org/?p=117784>
>>>>
>>>> Posted on October 29, 2020 4:03 pm
>>>> <https://electionlawblog.org/?p=117784> by *Rick Hasen*
>>>> <https://electionlawblog.org/?author=3>
>>>>
>>>> It is hard to know where to start with this opinion
>>>> <https://www.documentcloud.org/documents/7278436-8th-Circuit-Court-of-Appeals-MN-absentee-ballot.html>.
>>>> The majority suggests that a consent decree extending the deadline for
>>>> absentee ballots in Minnesota, entered into by the Secretary of State and
>>>> plaintiffs and approved by a state court, usurps the power of the state
>>>> legislature under article II of the Constitution (under a theory a majority
>>>> of the Supreme Court has not endorsed—at least not yet). The court reached
>>>> this conclusion despite the fact that the Legislature did not object (the
>>>> court found that Electors have standing, quite a dubious proposition that
>>>> they could assert the rights of the legislature), that the Legislature
>>>> delegated the power to the Secretary of State to take these steps, and
>>>> despite the fact that we are on the eve of the election.
>>>>
>>>> This timing issue is doubly troubling. First, the Supreme Court has
>>>> said that federal courts should be very wary of changing election rules
>>>> just before the election. This Purcell Principle is controversial but it
>>>> has been applied very heavily by the Supreme Court this election season
>>>> especially.
>>>>
>>>> More importantly, think of the reliance interests of Minnesota voters,
>>>> who have been told until today that they have extra time to mail their
>>>> ballots. Now there is the very real chance that those late-arriving ballots
>>>> won’t count through no fault of their own. Both the plaintiffs and courts
>>>> could have moved much sooner if they had this concern. It is voters that
>>>> are going to be on the short end of things.
>>>>
>>>> Whether the state goes to the Supreme Court at this time or not, and
>>>> whether they are successful at getting a majority to overturn this (I’d
>>>> give it a fair shot given the reliance interests), things are so uncertain
>>>> that the only advice to people in Minnesota is not to vote by mail at this
>>>> point. Do NOT put your ballot in the U.S. Mail. Use official government
>>>> drop boxes or vote in person.
>>>>
>>>> [image: Share]
>>>> <https://www.addtoany.com/share#url=https%3A%2F%2Felectionlawblog.org%2F%3Fp%3D117784&title=In%20Outrageous%202-1%20Decision%20Ignoring%20Reliance%20Interests%20and%20Rejecting%20the%20Purcell%20Principle%2C%208th%20Circuit%20Panel%20Orders%20Segregation%20of%20Late%20Arriving%20Ballots%20in%20Minnesota%2C%20With%20Strong%20Hints%20Late%20Arriving%20Ballots%20Will%20Be%20Excluded%20from%20The%20Count>
>>>>
>>>> Posted in absentee ballots <https://electionlawblog.org/?cat=53>
>>>>
>>>>
>>>>
>>>>
>>>> “How a fake persona laid the groundwork for a Hunter Biden conspiracy
>>>> deluge” <https://electionlawblog.org/?p=117781>
>>>>
>>>> Posted on October 29, 2020 3:35 pm
>>>> <https://electionlawblog.org/?p=117781> by *Rick Hasen*
>>>> <https://electionlawblog.org/?author=3>
>>>>
>>>> NBC News
>>>> <https://www.nbcnews.com/tech/security/how-fake-persona-laid-groundwork-hunter-biden-conspiracy-deluge-n1245387>
>>>> :
>>>>
>>>> *Nine month before a purported leak of files from Hunter Biden’s
>>>> laptop, a fake “intelligence” document about him went viral on the
>>>> right-wing internet, asserting an elaborate conspiracy theory involving
>>>> former Vice President Joe Biden’s son and business in China.*
>>>>
>>>> *That document, a 64-page composition that was later disseminated by
>>>> close associates of President Donald Trump, appears to be the work of a
>>>> fake “intelligence firm” called Typhoon Investigations, according to
>>>> researchers and public documents.*
>>>>
>>>> *The author of the document, a self-identified Swiss security analyst
>>>> named Martin Aspen, is a fabricated identity, according to analysis by
>>>> disinformation researchers, who also concluded that Aspen’s profile picture
>>>> was created with an artificial intelligence face generator. The
>>>> intelligence firm that Aspen lists as his previous employer told NBC News
>>>> that no one by that name had ever worked for their company, and no one by
>>>> that name lives in Switzerland, according to public records and social
>>>> media searches.*
>>>>
>>>> *One of the original posters of the document, a blogger and professor
>>>> named Christopher Balding, took credit for writing parts of the document
>>>> when asked about it by NBC News, and said that Aspen does not exist.*
>>>>
>>>> *Despite the document’s questionable authorship and anonymous sourcing,
>>>> its claims that Hunter Biden has a problematic connection to the Communist
>>>> Party of China have been used by people who oppose the Chinese government,
>>>> as well as by far-right influencers, to baselessly accuse candidate Joe
>>>> Biden of being beholden to the Chinese government.*
>>>>
>>>> *The document and its spread have become part of a wider effort
>>>> <https://www.nbcnews.com/tech/tech-news/inside-campaign-pizzagate-hunter-biden-n1244331> to
>>>> smear Hunter Biden and weaken Joe Biden’s presidential campaign, which
>>>> moved from the fringes of the internet to more mainstream conservative news
>>>> outlets.*
>>>>
>>>> *An unverified leak of documents including salacious pictures from what
>>>> President Donald Trump’s lawyer, Rudy Giuliani, and Delaware Apple repair
>>>> store owner claimed to be Hunter Biden’s hard drive were published in the
>>>> New York Post on Oct. 14. Associates close to Trump, including Giuliani and
>>>> former White House chief strategist Steve Bannon, have since promised more
>>>> blockbuster leaks and secrets, which have yet to materialize.*
>>>>
>>>> *The fake intelligence document, however, preceded the leak by months
>>>> and helped lay the groundwork among right-wing media for what would become
>>>> a failed October surprise: a viral pile-on of conspiracy theories about
>>>> Hunter Biden.*
>>>>
>>>> [image: Share]
>>>> <https://www.addtoany.com/share#url=https%3A%2F%2Felectionlawblog.org%2F%3Fp%3D117781&title=%E2%80%9CHow%20a%20fake%20persona%20laid%20the%20groundwork%20for%20a%20Hunter%20Biden%20conspiracy%20deluge%E2%80%9D>
>>>>
>>>> Posted in cheap speech <https://electionlawblog.org/?cat=130>,
>>>> chicanery <https://electionlawblog.org/?cat=12>
>>>>
>>>>
>>>>
>>>>
>>>> “Ruling Revision ‘Doesn’t Go Far Enough’, Vermont Secretary of State
>>>> Tells Justice Kavanaugh” <https://electionlawblog.org/?p=117779>
>>>>
>>>> Posted on October 29, 2020 3:33 pm
>>>> <https://electionlawblog.org/?p=117779> by *Rick Hasen*
>>>> <https://electionlawblog.org/?author=3>
>>>>
>>>> Jess Bravin
>>>> <https://www.wsj.com/livecoverage/election-live-updates-trump-biden-2020-10-29/card/yw4eyads0C0mLKh5tfcJ> for
>>>> the WSJ:
>>>>
>>>> *Vermont Secretary of State Jim Condos isn’t satisfied with Justice
>>>> Brett Kavanaugh’s revision to a recent voting-rights opinion that Mr.
>>>> Condos said misstated his state’s election rules.*
>>>>
>>>> *On Wednesday, Justice Kavanaugh revised a Monday opinion
>>>> <https://www.wsj.com/livecoverage/election-live-updates-trump-biden-2020-10-28/card/DPUm2bTc6zMFE7HPfyKS> that
>>>> originally said Vermont hadn’t changed its “ordinary election rules” in
>>>> response to the coronavirus pandemic to state that it hadn’t changed its
>>>> “ordinary election deadline rules,” after Mr. Condos complained that the
>>>> justice overlooked a host of other measures the state took to help voters
>>>> limit exposure to Covid-19.*
>>>>
>>>> *“I’m glad he admitted a mistake and modified his opinion, but a
>>>> one-word addition doesn’t go far enough,” Mr. Condos, a Democrat, said
>>>> Thursday. “I will not sit idly by while Justice Kavanaugh uses factually
>>>> incorrect information about the Green Mountain State as cover to erode
>>>> voting rights in the middle of a pandemic-distressed election.”*
>>>>
>>>> [image: Share]
>>>> <https://www.addtoany.com/share#url=https%3A%2F%2Felectionlawblog.org%2F%3Fp%3D117779&title=%E2%80%9CRuling%20Revision%20%E2%80%98Doesn%E2%80%99t%20Go%20Far%20Enough%E2%80%99%2C%20Vermont%20Secretary%20of%20State%20Tells%20Justice%20Kavanaugh%E2%80%9D>
>>>>
>>>> Posted in Uncategorized <https://electionlawblog.org/?cat=1>
>>>>
>>>>
>>>>
>>>>
>>>> “How The 2020 Election Could End Up In The Courts”
>>>> <https://electionlawblog.org/?p=117777>
>>>>
>>>> Posted on October 29, 2020 3:31 pm
>>>> <https://electionlawblog.org/?p=117777> by *Rick Hasen*
>>>> <https://electionlawblog.org/?author=3>
>>>>
>>>> WMFE
>>>> <https://www.wmfe.org/how-the-2020-election-could-end-up-in-the-courts/167846> talks
>>>> to Ciara Torres-Spelliscy.
>>>>
>>>> [image: Share]
>>>> <https://www.addtoany.com/share#url=https%3A%2F%2Felectionlawblog.org%2F%3Fp%3D117777&title=%E2%80%9CHow%20The%202020%20Election%20Could%20End%20Up%20In%20The%20Courts%E2%80%9D>
>>>>
>>>> Posted in Uncategorized <https://electionlawblog.org/?cat=1>
>>>>
>>>>
>>>>
>>>>
>>>> Ariane de Vogue and I Joined John King on CNN to Talk About Latest
>>>> Supreme Court Rulings on Voting (Video)
>>>> <https://electionlawblog.org/?p=117775>
>>>>
>>>> Posted on October 29, 2020 3:23 pm
>>>> <https://electionlawblog.org/?p=117775> by *Rick Hasen*
>>>> <https://electionlawblog.org/?author=3>
>>>>
>>>> You can watch here:
>>>> <https://www.youtube.com/watch?v=-vKLik6Ptpc&feature=youtu.be>
>>>>
>>>> [image: Share]
>>>> <https://www.addtoany.com/share#url=https%3A%2F%2Felectionlawblog.org%2F%3Fp%3D117775&title=Ariane%20de%20Vogue%20and%20I%20Joined%20John%20King%20on%20CNN%20to%20Talk%20About%20Latest%20Supreme%20Court%20Rulings%20on%20Voting%20(Video)>
>>>>
>>>> Posted in Supreme Court <https://electionlawblog.org/?cat=29>
>>>>
>>>>
>>>>
>>>>
>>>> “So, Russia, You Want to Mess With Our Voting Machines? The United
>>>> States should threaten to retaliate — and I’m not talking about economic
>>>> sanctions or legal indictments.”
>>>> <https://electionlawblog.org/?p=117773>
>>>>
>>>> Posted on October 29, 2020 2:47 pm
>>>> <https://electionlawblog.org/?p=117773> by *Rick Hasen*
>>>> <https://electionlawblog.org/?author=3>
>>>>
>>>> Tim Wu
>>>> <https://www.nytimes.com/2020/10/29/opinion/election-interference-russia-iran.html> for
>>>> NYT Opinion.
>>>>
>>>> I made the same point in Election Meltdown. An attack on our election
>>>> infrastructure or power grid on Election Day should be seen as an act of
>>>> war and declared that in advance by the President.
>>>>
>>>> [image: Share]
>>>> <https://www.addtoany.com/share#url=https%3A%2F%2Felectionlawblog.org%2F%3Fp%3D117773&title=%E2%80%9CSo%2C%20Russia%2C%20You%20Want%20to%20Mess%20With%20Our%20Voting%20Machines%3F%20The%20United%20States%20should%20threaten%20to%20retaliate%20%E2%80%94%20and%20I%E2%80%99m%20not%20talking%20about%20economic%20sanctions%20or%20legal%20indictments.%E2%80%9D>
>>>>
>>>> Posted in Election Meltdown <https://electionlawblog.org/?cat=127>
>>>>
>>>>
>>>>
>>>>
>>>> Why Did Justice Alito Not Address the Huge Standing Issue in
>>>> Yesterday’s Pennsylvania Case? <https://electionlawblog.org/?p=117766>
>>>>
>>>> Posted on October 29, 2020 12:09 pm
>>>> <https://electionlawblog.org/?p=117766> by *Rick Hasen*
>>>> <https://electionlawblog.org/?author=3>
>>>>
>>>> Yesterday I wrote <https://electionlawblog.org/?p=117673> about the
>>>> Supreme Court order in the Pennsylvania case and Justice Alito’s separate
>>>> statement strongly suggesting the PA Supreme Court acted unconstitutionally
>>>> in taking power away from the state legislature.
>>>>
>>>> It’s a controversial theory but I want to put that to one side and
>>>> raise the point that the PA Legislature did not file this cert. petition
>>>> nor did legislative leaders (who were on an earlier stay request, but not
>>>> this cert. petition).
>>>>
>>>> Isn’t the lack of standing, which I flagged earlier
>>>> <https://electionlawblog.org/?p=117413>, reason enough to defeat this
>>>> claim? That is, how can the party complain about the loss of the
>>>> Legislature’s purported rights?
>>>>
>>>> [image: Share]
>>>> <https://www.addtoany.com/share#url=https%3A%2F%2Felectionlawblog.org%2F%3Fp%3D117766&title=Why%20Did%20Justice%20Alito%20Not%20Address%20the%20Huge%20Standing%20Issue%20in%20Yesterday%E2%80%99s%20Pennsylvania%20Case%3F>
>>>>
>>>> Posted in Uncategorized <https://electionlawblog.org/?cat=1>
>>>>
>>>> --
>>>>
>>>> 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
>>>>
>>>> http://www.law.uci.edu/faculty/full-time/hasen/
>>>>
>>>> http://electionlawblog.org
>>>>
>>>>
>>>>
>>>>
>>>> _______________________________________________
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>>>>
>>>>
>>>> --
>>>> David Schultz, Distinguished University Professor
>>>> Hamline University
>>>> Department of Political Science and
>>>> Department of Legal Studies
>>>> 1536 Hewitt Ave
>>>> MS B 1805
>>>> St. Paul, Minnesota 55104
>>>> 651.523.2858 (voice)
>>>> http://davidschultz.efoliomn.com/
>>>> http://works.bepress.com/david_schultz/
>>>> http://schultzstake.blogspot.com/
>>>> Twitter:  @ProfDSchultz
>>>> My latest book:  Presidential Swing States:  Why Only Ten Matter
>>>>
>>>> https://rowman.com/ISBN/9780739195246/Presidential-Swing-States-Why-Only-Ten-Matter
>>>> FacultyRow SuperProfessor, 2012, 2013, 2014
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> Marty Lederman
> Georgetown University Law Center
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