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

Samuel Bagenstos sbagen at gmail.com
Fri Oct 30 06:38:17 PDT 2020 

But where in Article II's use of the word "legislature" do we find the
principle that state legislation must be read according to a textualist
methodology?  More generally, what in Article II says that SCOTUS, rather
than another entity, gets to decide what the "objectively discernible
meaning" of state legislation is?  It seems to me that the very arguments
that say that the state courts (or other state entities) can't decide this
question mean that SCOTUS can't, either.

On Fri, Oct 30, 2020 at 9:20 AM Jonathan Adler <jha5 at case.edu> wrote:

> 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
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> _______________________________________________
>>>>> Law-election mailing list
>>>>> Law-election at department-lists.uci.edu
>>>>> https://department-lists.uci.edu/mailman/listinfo/law-election
>>>>>
>>>>>
>>>>>
>>>>> --
>>>>> 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
>>>>> _______________________________________________
>>>>> Law-election mailing list
>>>>> Law-election at department-lists.uci.edu
>>>>> https://department-lists.uci.edu/mailman/listinfo/law-election
>>>>
>>>> _______________________________________________
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>>>
>>> _______________________________________________
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>>
>>
>>
>> --
>> Marty Lederman
>> Georgetown University Law Center
>> 600 New Jersey Avenue, NW
>> Washington, DC 20001
>> 202-662-9937
>>
>>

-- 
Samuel Bagenstos
He/Him/His
sbagen at gmail.com
Twitter: @sbagen
University of Michigan homepage:
http://www.law.umich.edu/FacultyBio/Pages/FacultyBio.aspx?FacID=sambagen
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