[EL] ELB News and Commentary 1/28/21

[Rick Hasen]

“Extremists Emboldened by Capitol Attack Pose Rising Threat, Homeland Security Says”<https://electionlawblog.org/?p=120664>
Posted on January 28, 2021 8:55 am<https://electionlawblog.org/?p=120664> by Rick Hasen<https://electionlawblog.org/?author=3>

NYT:<https://www.nytimes.com/2021/01/27/us/politics/homeland-security-threat.html>

Warning that the deadly rampage of the Capitol this month may not be an isolated episode, the Department of Homeland Security on Wednesday said publicly for the first time that the United States faced a growing threat from “violent domestic extremists” emboldened by the attack.

The department’s terrorism alert did not name specific groups that might be behind any future attacks, but it made clear that their motivation would include anger over “the presidential transition, as well as other perceived grievances fueled by false narratives,” a clear reference to the accusations made by President Donald J. Trump and echoed by right-wing groups that the 2020 election was stolen.

“D.H.S. is concerned these same drivers to violence will remain through early 2021,” the department said.

The Department of Homeland Security does not have information indicating a “specific, credible plot,” according to a statement from the agency. The alert issued was categorized as one warning of developing trends in terrorism, rather than a notice of an imminent attack.
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Posted in chicanery<https://electionlawblog.org/?cat=12>, Election Meltdown<https://electionlawblog.org/?cat=127>


“Democrats consider one-week impeachment trial, censure resolution after GOP signals likely acquittal of Trump”<https://electionlawblog.org/?p=120662>
Posted on January 28, 2021 8:52 am<https://electionlawblog.org/?p=120662> by Rick Hasen<https://electionlawblog.org/?author=3>

WaPo:<https://www.washingtonpost.com/politics/democrats-consider-impeachment-alternatives-censure/2021/01/27/fdfd9b6c-60bd-11eb-afbe-9a11a127d146_story.html>

Bracing for the prospect of a likely acquitta<https://www.washingtonpost.com/politics/gop-senators-to-question-basis-for-trump-impeachment-signaling-likely-acquittal/2021/01/26/cd7397dc-6002-11eb-9061-07abcc1f9229_story.html?itid=lk_inline_manual_1>l, Senate Democrats are eyeing a rapid-fire impeachment trial for former president Donald Trump — as short as one week — while also contemplating alternatives such as censure that could attract more support from Republicans.

The rethinking of the plan to try Trump on the charge that he incited the violent Jan. 6 Capitol riot reflects a growing desire among most Democrats to move forward with President Biden’s governing agenda<https://www.washingtonpost.com/politics/2021/01/26/mcconnell-scorched-earth-fillibuster/?itid=lk_inline_manual_3> in light of a test vote Tuesday that saw all but five Republican senators<https://www.washingtonpost.com/politics/gop-senators-to-question-basis-for-trump-impeachment-signaling-likely-acquittal/2021/01/26/cd7397dc-6002-11eb-9061-07abcc1f9229_story.html?itid=lk_inline_manual_3> back Trump in a constitutional challenge to proceeding with the trial.

After the 55-to-45 tally fell short of the 67 votes needed to convict Trump and possibly bar him from holding office in the future, several Democratic senators said Wednesday that they were eager to move on to coronavirus<https://www.washingtonpost.com/coronavirus/?itid=lk_inline_manual_4> pandemic relief, climate legislation, Cabinet confirmations<https://www.washingtonpost.com/graphics/politics/biden-cabinet/?itid=lk_inline_manual_4> and other items on the party’s to-do list….

Kaine is pitching his censure resolution to Republicans as a potentially more politically palatable alternative to convicting Trump and barring him from future office. But he is also making the case to Democrats that his resolution would have much the same effect as a conviction, by condemning the former president and laying the foundation to keep him from returning to the presidency under the terms of the 14th Amendment.

Section 3 of the amendment holds that no government official can hold office “who, having previously taken an oath . . . to support the Constitution of the United States, shall have engaged in insurrection or rebellion against the same, or given aid or comfort to the enemies thereof.”

The provision, ratified in 1868, was written to keep avowed Confederates out of government office. It has been unevenly and infrequently applied since, and there is scant precedent or case law to determine who has the authority to disqualify a president or any other non-congressional official.

Kaine said his resolution would echo the amendment’s language, calling the Capitol attack “an insurrection against the Constitution of the United States” and finding that Trump “gave aid and comfort” to it.

“It’s more than just a censure, saying, ‘Hey, you did wrong,’ ” he said. “It makes a factual finding under the precise language of the 14th Amendment that would likely put an obstacle in Donald Trump’s path if he were to run for office again.”

Laurence Tribe, a Harvard Law professor, said invoking the 14th Amendment provision is “much more complex than some people assume” and said simply passing a resolution as Kaine is proposing would not be sufficient to bar Trump from office.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“One GOP legal claim failed in 2020 but could change how future elections are run”<https://electionlawblog.org/?p=120660>
Posted on January 28, 2021 8:44 am<https://electionlawblog.org/?p=120660> by Rick Hasen<https://electionlawblog.org/?author=3>

Jordan Wilkie<https://carolinapublicpress.org/41927/one-gop-legal-claim-failed-in-2020-but-could-change-how-future-election-are-run/> for Carolina Public Press:

Each expert to whom CPP talked for this story said that, in election litigation in the United States, the motivation is always driven at least in part by the pursuit of power, and that is not limited to one political party over another.

“In the history of battles over voting in this country, you’re going to find it’s rare that any of these actors have pure motives,” said Roberts, the UNC political science professor.

“It’s almost all motives based on what’s going to help them in the short run, and that’s certainly the case here.”

But Justin Levitt, law professor at Loyola Marymount law school, is not convinced that Republicans actually want to win their Elections Clause arguments.

“It would not be the first time that hubris and lack of forethought caused a political party to take a whole bunch of moves that turned out to bite them in the rear a couple years down the line,” Levitt said.

While the independent state legislature doctrine could help Republicans control federal election rules in states like North Carolina and Pennsylvania, it could actually be more harmful to the party’s national authority.

“Believe me, the tradition and the history in both New York and California, says that, if unleashed, Democrats will have absolutely no trouble figuring out how to abuse their power,” Levitt said.
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Posted in Elections Clause<https://electionlawblog.org/?cat=70>


“Census Numbers For Dividing Up House Seats Delayed Until April 30, Bureau Says”<https://electionlawblog.org/?p=120657>
Posted on January 28, 2021 8:38 am<https://electionlawblog.org/?p=120657> by Rick Hasen<https://electionlawblog.org/?author=3>

NPR reports<https://www.npr.org/2021/01/27/961247853/census-numbers-for-dividing-up-house-seats-delayed-until-april-30-bureau-says>:

Disrupted by the coronavirus pandemic and last-minute changes by the Trump administration, the U.S. Census Bureau announced Wednesday that the release of the first results of the 2020 census will likely be delayed by four months.

The latest state population counts used to determine each state’s share of votes in the House of Representatives and the Electoral College for the next decade are now expected by April 30.

Those numbers were legally due by the end of last year. But the bureau missed that deadline last month for the first time<https://www.npr.org/2020/12/30/951566925/census-to-miss-year-end-deadline-for-delivering-numbers-for-house-seats> since it was put in place in 1976. Career civil servants postponed releasing the counts in order to try to fix irregularities they began uncovering<https://www.npr.org/2020/12/05/943416487/millions-of-census-records-may-be-flawed-jeopardizing-trumps-bid-to-alter-count> in census records shortly after Trump officials ended counting early in October<https://www.npr.org/2020/09/18/911960963/how-trump-officials-cut-the-2020-census-short-amid-the-pandemic>…

The release date for the congressional apportionment counts has been in flux for weeks. As part of a National Urban League-led lawsuit over the Trump administration’s census schedule changes, Justice Department attorneys previously told a federal judge<https://twitter.com/hansilowang/status/1350173871853461507> that the bureau was working towards finishing the processing of census records by March 6.

But that timeline was “not taking into account what we expect to find when we do data processing, which is anomalies that need to be corrected,” Styles said. “We have found anomalies, we will likely find more anomalies, and we will fix additional anomalies as we find them.”

The timing for the second set of new census results — the detailed demographic data that state redistricting officials need to redraw voting districts — remains unclear. That information is normally delivered to the states by the end of March.

“You should not expect it prior to July 30,” Styles said.

The delay ratchets up the pressure for states<https://www.npr.org/2020/12/22/949078378/a-delay-in-census-results-would-hinder-states-redistricting-efforts> that are facing their own series of legal deadlines for the redistricting process in order to hold elections this year or next.

Politico<https://www.politico.com/news/2021/01/28/census-redistricting-delays-2022-house-463388>: Redistricting Delay Freezes House Races
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Posted in census litigation<https://electionlawblog.org/?cat=125>, redistricting<https://electionlawblog.org/?cat=6>


Two from Josh Douglas<https://electionlawblog.org/?p=120655>
Posted on January 28, 2021 8:36 am<https://electionlawblog.org/?p=120655> by Rick Hasen<https://electionlawblog.org/?author=3>

Voter ID Laws Are Bad. But Some Are Better Than Others<https://washingtonmonthly.com/2021/01/27/voter-id-laws-are-bad-but-some-are-better-than-others/> (Wash Monthly)

Republicans react to 2020 defeats by trying to make it harder to vote<https://www.cnn.com/2021/01/27/opinions/republican-voting-rights-election-douglas/index.html> (CNN)
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“Republicans demand audit of Kelli Ward’s narrow win for Arizona GOP chair”<https://electionlawblog.org/?p=120653>
Posted on January 28, 2021 8:32 am<https://electionlawblog.org/?p=120653> by Rick Hasen<https://electionlawblog.org/?author=3>

Arizona Republic:<https://www.azcentral.com/story/news/politics/elections/2021/01/27/republicans-demand-audit-kelli-wards-win-gop-chair/4287034001/>

After months of sounding the alarm on what she claimed was a stolen presidential election, Kelli Ward is facing questions about her own reelection Saturday as Arizona Republican Party chair.

Sergio Arellano, the southern Arizona businessman who narrowly lost to Ward in a runoff, has asked state party officials for an audit of the election results, said Kim Owens, a Republican consultant who is serving as his spokeswoman.

So far, that hasn’t happened, adding to a growing sense of angst among GOP activists that the election had problems.

“This isn’t about the chairman’s race, this is about election integrity,” Arellano said in a written statement provided by Owens to The Arizona Republic.

In a statement issued hours later to the newspaper, Arellano said he did not expect the audit to lead to a reversal of wins for Ward and others.

Neither Ward nor other state party officials could be immediately reached for comment.

Doubts about the results of the chair’s race started to swirl <https://www.azcentral.com/story/news/politics/arizona/2021/01/24/arizona-gop-reelects-kelli-ward-censures-cindy-mccain-jeff-flake-doug-ducey/6679473002/> after the announced winner in another race, for the at-large committee member from the 8th Congressional District, was informed she had lost.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“The Election Reform Agenda: A Deep Dive into H.R.1”<https://electionlawblog.org/?p=120651>
Posted on January 27, 2021 4:32 pm<https://electionlawblog.org/?p=120651> by Rick Hasen<https://electionlawblog.org/?author=3>

Four part series<https://pacscenter.stanford.edu/event/the-election-reform-agenda-a-deep-dive-into-hr1/> at Stanford with dynamite speakers delving into Democrats’ proposed election reform measure, H.R. 1. You need to register to watch.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“Depoliticizing Redistricting”<https://electionlawblog.org/?p=120649>
Posted on January 27, 2021 11:32 am<https://electionlawblog.org/?p=120649> by Nicholas Stephanopoulos<https://electionlawblog.org/?author=12>

I just posted this book chapter<https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3774436> on redistricting commissions around the world, based on the first ever survey of commission members. It’ll be part of the Comparative Election Law volume that Jim Gardner is editing. The abstract is below:

This chapter sheds light on the operation of redistricting commissions around the world through the first ever survey of commission members. The respondents uniformly testify to the nonpartisanship of their bodies. They attribute this impartiality to (1) the institutional structure of the commissions; (2) the elaborate sets of redistricting criteria used by the commissions; and (3) the powerful norms of political independence cultivated by the commissions. Interestingly, the respondents reject the recent American trend of instructing redistricting authorities to consider election results and to overtly pursue partisan fairness. The respondents prefer not using election results at all in the mapmaking process.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“Social Media Influencer Charged with Election Interference Stemming from Voter Disinformation Campaign”: Defendant Alleged to Have Targeted African-American Voters Urging Them to Text Their Votes<https://electionlawblog.org/?p=120646>
Posted on January 27, 2021 9:52 am<https://electionlawblog.org/?p=120646> by Rick Hasen<https://electionlawblog.org/?author=3>

DOJ:<https://www.justice.gov/opa/pr/social-media-influencer-charged-election-interference-stemming-voter-disinformation-campaign>

A Florida man was arrested this morning on charges of conspiring with others in advance of the 2016 U.S. Presidential Election to use various social media platforms to disseminate misinformation designed to deprive individuals of their constitutional right to vote.

Douglass Mackey, aka Ricky Vaughn, 31, of West Palm Beach, was charged by criminal complaint in the Eastern District of New York. He was taken into custody this morning in West Palm Beach and made his initial appearance before U.S. Magistrate Judge Bruce E. Reinhart of the Southern District of Florida….

The complaint alleges that in 2016, Mackey established an audience on Twitter with approximately 58,000 followers. A February 2016 analysis by the MIT Media Lab ranked Mackey as the 107th most important influencer of the then-upcoming Election, ranking his account above outlets and individuals such as NBC News (#114), Stephen Colbert (#119) and Newt Gingrich (#141).

As alleged in the complaint, between September 2016 and November 2016, in the lead up to the Nov. 8, 2016, U.S. Presidential Election, Mackey conspired with others to use social media platforms, including Twitter, to disseminate fraudulent messages designed to encourage supporters of one of the presidential candidates (the “Candidate”) to “vote” via text message or social media, a legally invalid method of voting.

For example, on Nov. 1, 2016, Mackey allegedly tweeted an image that featured an African American woman standing in front of an “African Americans for [the Candidate]” sign.  The image included the following text: “Avoid the Line. Vote from Home. Text ‘[Candidate’s first name]’ to 59925[.] Vote for [the Candidate] and be a part of history.”  The fine print at the bottom of the image stated: “Must be 18 or older to vote. One vote per person. Must be a legal citizen of the United States. Voting by text not available in Guam, Puerto Rico, Alaska or Hawaii. Paid for by [Candidate] for President 2016.”

The tweet included the typed hashtags “#Go [Candidate]” and another slogan frequently used by the Candidate. On or about and before Election Day 2016, at least 4,900 unique telephone numbers texted “[Candidate’s first name]” or some derivative to the 59925 text number, which was used in multiple deceptive campaign images tweeted by the defendant and his co-conspirators.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


Brennan Center Analysis: Rate of Bills Introduced in State Legislature to Restrict Voting Have Tripled Compared to Last Year<https://electionlawblog.org/?p=120644>
Posted on January 27, 2021 9:13 am<https://electionlawblog.org/?p=120644> by Rick Hasen<https://electionlawblog.org/?author=3>

Fear of voting roundup.<https://www.brennancenter.org/our-work/research-reports/voting-laws-roundup-2021>
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


TPM Offers Great Narrative Description of Trump and His Allies’ Months-Long Lies About Voter Fraud in An Attempt to Steal the 2020 Election<https://electionlawblog.org/?p=120642>
Posted on January 27, 2021 9:10 am<https://electionlawblog.org/?p=120642> by Rick Hasen<https://electionlawblog.org/?author=3>

This<https://talkingpointsmemo.com/feature/the-capitol-mob-was-only-the-finale-of-trumps-conspiracy-to-overturn-the-election> from Tierney Sneed and Matt Shuham is a must-read.
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Posted in chicanery<https://electionlawblog.org/?cat=12>, Election Meltdown<https://electionlawblog.org/?cat=127>, fraudulent fraud squad<https://electionlawblog.org/?cat=8>


“Post-Election Litigation and the Paradox of Voting”<https://electionlawblog.org/?p=120640>
Posted on January 25, 2021 3:59 pm<https://electionlawblog.org/?p=120640> by Rick Hasen<https://electionlawblog.org/?author=3>

Peter Salib & Guha Krishnamurthi have posted this draft<https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3771587> on SSRN (forthcoming, U Chicago L Rev. Online). Here is the abstract:

Economists will tell you that your vote does not matter. Or at least it does not matter if what you care about is who wins a large election. Because the margin of victory is irrelevant to determining the winner, all of the votes beyond the single vote that puts one candidate ahead of the other have absolutely zero effect on the outcome. Thus, the only election in which your individual vote matters at all is the election that, without you, would end in a tie. Given the sheer unlikelihood of a tie, if voting has even minimal cost, or is even mildly inconvenient, you are almost certainly better off abstaining.

That, at least, is the traditional story. But recent elections, including the most recent American presidential election between Joe Biden and Donald Trump, tell a different one. They show us that, at least in close, high-stakes American elections, votes do not decide the winner. Litigation does. And critically, vote margins do matter in litigation. The larger the margin of victory, the less likely litigation will overturn a result: as the pre-litigation margin of victory grows, the available arguments become fewer and less credible, and thus less likely to change the outcome. Thus, it is beneficial for a candidate to accrue votes beyond the tipping point of the election, at least until the “margin of litigation”—the number of votes that post-election litigation could plausibly overturn.

In light of these observations, this Essay proffers two novel claims about the paradox of voting: First, we contend that, based on the mechanics of post-election litigation, it is possible that at least some votes should rationally be cast in expectation of having an electoral effect. Second, for closely related reasons, we argue that the margin of litigation can impact the perceived legitimacy of an election. It is therefore possible that at least some votes should be rationally cast to ward off the dangerous results that may arise from perceptions of illegitimacy, including decreased governmental efficacy, but also civil unrest and violent conflict.
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Posted in Uncategorized<https://electionlawblog.org/?cat=1>


“Watchdog Probes Whether Justice Department Officials Tried to Alter 2020 Election Results”<https://electionlawblog.org/?p=120638>
Posted on January 25, 2021 12:38 pm<https://electionlawblog.org/?p=120638> by Rick Hasen<https://electionlawblog.org/?author=3>

WSJ:<https://www.wsj.com/articles/government-watchdog-probes-whether-justice-department-officials-tried-to-alter-2020-election-results-11611595904?mod=hp_lead_pos1>

The Justice Department’s inspector general said Monday his office will investigate whether department officials “engaged in an improper attempt” to overturn President Biden’s victory in the 2020 election.

The announcement comes after news reports that former President Donald Trump<https://www.wsj.com/topics/person/donald-trump> considered moving to replace the acting attorney general with another official ready to pursue unsubstantiated claims of election fraud<https://www.wsj.com/articles/trump-lawyers-face-rebukes-over-election-fraud-claims-11610458283?mod=article_inline>. The Wall Street Journal also reported that Mr. Trump pushed the Justice Department to ask the Supreme Court<https://www.wsj.com/articles/trump-pressed-to-change-justice-department-leadership-to-boost-his-voter-fraud-claims-11611434369?mod=searchresults_pos1&page=1&mod=article_inline> to invalidate Mr. Biden’s win.

Inspector General Michael Horowitz said in a statement that his office will probe “whether any former or current DOJ official engaged in an improper attempt to have DOJ seek to alter the outcome of the 2020 Presidential Election,” adding only that the investigation will “encompass all allegations that may arise that are within the scope” of its jurisdiction.
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Posted in chicanery<https://electionlawblog.org/?cat=12>, Department of Justice<https://electionlawblog.org/?cat=26>, Election Meltdown<https://electionlawblog.org/?cat=127>



--
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>
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http://electionlawblog.org<http://electionlawblog.org/>



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