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 # 641  

September 2012




Media Shows Pervasive Bias When Covering Voter ID

by Justin Danhof, Esq.

 

On July 30, 2012, Huffington Post Senior Washington Correspondent Dan Froomkin issued a clarion call to the news media, imploring them to eschew journalistic integrity and attack those who support voter integrity laws.1 Froomkin claimed that "[v]oter fraud simply isn't a problem in this country," and that new state-level voter ID laws are "attack[s] on the very notion of democracy... poll tax[es] with a new twist."2 Ample evidence suggests that Froomkin's plea to the media was unnecessary and redundant. The American media consistently denigrates voter integrity measures and vilify those who seek to secure elections.

Since 2011, 37 states have passed or considered some form of voter integrity measure.3 Many of these laws require photo identification for in-person voting.4 While the majority of Americans consider these laws commonsense fraud-prevention measures,5 the mainstream media has engaged in a systematic effort to demonize voter ID.

The media use three primary tactics to attack voter ID laws: rhetoric, flawed data and selective coverage. The media claim that voter integrity measures are racist, Jim Crow-era voter suppression laws aimed at disenfranchising poor, elderly and monitory voters. Giving an academic veneer to these claims, the media rely on biased work by the Brennan Center for Justice, the National Association for the Advancement of Colored People, News21, the American Civil Liberties Union and other liberal groups. Finally, the media often ignore two primary facts about voter ID: the American people overwhelmingly support voter ID laws, and the United States Supreme Court ruled in 2008 that state-level voter ID laws can be constitutional.

 

Crawford v. Marion Blackout

One glaring example of the media's extreme bias in voter ID reporting is its near-total blackout of the seminal voter ID United States Supreme Court case, Crawford v. Marion.6 In that 2008 decision, liberal Justice John Paul Stevens authored the majority opinion upholding Indiana's voter ID law against a legal challenge from the American Civil Liberties Union (ACLU). The ACLU claimed that Indiana's law was unnecessary because – in its opinion – in-person voter fraud was rare.7 The ACLU also claimed that the law was unconstitutional because it would disproportionately disfranchise minority and elderly state residents.8 The Supreme Court disagreed.

In his majority opinion, Justice Stevens wrote that, "[t]here is no question about the legitimacy or importance of the State's interest in counting only the votes of eligible voters… the inconvenience of making a trip to the BMV, gathering the required documents, and posing for a photograph surely does not qualify as a substantial burden on the right to vote."9 Stevens declared that Indiana's voter ID law was "unquestionably relevant to the State's interest in protecting the integrity and reliability of the electoral process."10

Since 2008, state legislators have used Indiana's law and Crawford as a guide in drafting voter ID legislation. Competent journalists reporting on voter ID laws in 2012 must address the Crawford decision. It supplies the legal framework and establishes precedent for state-level voter ID laws. Additionally, as state laws are challenged in local and federal courts, Crawford is either binding precedent or extremely persuasive. Objective reporters covering these cases have a duty to explain the Supreme Court's position on voter ID.11 However, since the decision does not comport with the progressive narrative – that voter ID laws are racist and suppressive – the media largely ignore the case.

On August 15, 2012, I conducted an experiment to determine the focus of media reporting on voter ID.12 Using the Google News search engine, I entered different word combinations to get a sense of the media's focus on voter ID reporting. The results highlighted the media's extreme bias and deceit regarding voter ID and the law.

First, I searched for "voter ID laws." That search yielded 27,700 results.

Voter ID search results

Clearly, voter ID is an important topic with great bearing on local and national politics. The media actively and aggressively report on the topic.

To get a sense of what journalists wrote about voter ID measures, I refined the search to "voter ID laws Crawford v. Marion." Of the more than 27,000 results concerning "voter ID laws," only 31 mentioned the Crawford decision.

Voter ID Crawford v. Marion search results

This is more than just an oversight. The media have largely abandoned their duty to report facts. Writing about my findings on the National Center for Public Policy Research's blog, I explained that the media "are misleading the public. And they are either doing so out of ignorance, malice or both."13 An American reading the news in August 2012 would have no clue that the Supreme Court found a state-level voter ID law constitutional just four years earlier. The media are either purposefully creating a false narrative that is void of the factual and legal underpinnings of voter ID laws, or they are grossly negligent.

Of the 31 articles that referenced Crawford, I selected the "all news" button, which yielded a mere eight primary sources. Of the eight, two were National Center for Public Policy Research materials, and one quoted a National Center press release.14 The media blackout was clear.

Voter ID Crawford primary source search results

Shocked by the unadulterated bias, I wrote: "outside of the National Center, almost no one is willing to explain the true history and legal precedent that back new voter ID laws. So, if not the truth, what is the media selling? Race wars and rhetoric, that's what."15

 

Racial Rhetoric

On July 10, 2012, Attorney General Eric Holder spoke at the National Association for the Advancement of Colored People's national convention about the evils of voter ID laws.16 Holder told the audience that some people will have a tough time obtaining a proper ID, and "[w]e call those poll taxes."17 Seemingly taking their cues from the Obama White House and Holder, the media have written thousands of stories presenting voter integrity measures in racial tones.

To quantify this observation, my next Google News search was for "voter ID laws racist."

Voter ID racist search results

That search yielded 4,450 results. I commented on the media bias, saying: "the media unnecessarily infuses race into voter ID stories 145.5 times more often than they report on binding legal doctrine. While some of these articles are likely defending voter ID laws against charges of racism, the results are nonetheless instructive on the media's wayward focus on the voter integrity issue."18

Finally, I searched for "voter ID laws Jim Crow," which produced 671 results – or 24 times more than the media mentioned Crawford.

Voter ID Jim Crow search results

Invoking Jim Crow-era laws in a modern-day discussion of voter ID laws is journalistic malpractice. Jim Crow laws were bigoted norms that cemented black Americans as second-class citizens. They would shock the consciences of all but the most depraved and hateful in America today. Voter ID laws simply call for individuals to obtain an ID – offered free to indigent residents – prior to voting, whereas Jim Crow laws intentionally treated blacks as inferior to whites whites. Voter ID laws treat everyone equally and with dignity. No serious journalist would ever equate the two.

Race baiting and ignoring Crawford and are not the only tactics the media use to distort the voter ID story. The media also ignore the vox populi.

 

MSNBC Ignores Inconvenient Data

A common adage states that everyone is entitled to his own opinions but not his own facts.19 When discussing voter ID, however, the media appears to ignore inconvenient facts, such as Crawford. The media are seemingly so busy telling the American people how they ought to think; they miss the clear position of the people.

The American public strongly supports voter ID laws. On August 13, 2012, the Washington Post published a poll showing that 74 percent of Americans support voter ID laws.20 Support for voter ID transcends race, political party and gender. The poll found that "86 percent of self-identified Republicans support voter I.D. measures. 67 percent of independents and 60 percent of Democrats also voiced their support. 78 percent of white adults, 65 percent of African Americans and 64 percent of Hispanics support voter I.D. 75 percent of men and 73 percent of women agree: voter I.D. laws are necessary."21

The Washington Post poll data is consistent with other voter ID polling results. In April 2012, a Rasmussen Reports poll indicated that 73 percent of Americans supported voter ID laws.22 In June 2011, another Rasmussen Reports poll found that 75 percent of likely U.S. voters supported voter ID laws and that "support for such a law is high across virtually all demographic groups."23

In an article announcing the findings, Washington Post writers Michael Brandon and Jon Cohen downplayed the staggering results of their own poll.24 They claimed that even though Americans support voter ID laws, they are also concerned with voter suppression.25 But this is a distraction – no one supports voter suppression. Pitting these two items together is a false comparison. Writing for Hot Air, novelist Libby Sternberg explains, "[w]ith poll numbers like those, of course Voter ID opponents would rather make this a debate about 'suppression' and 'racism.' Nobody likes a racist, after all, so they easily win that fake argument, while they lose the one on the policy itself."26 Some progressive journalists and talking heads went further than downplaying the poll data; they ignored it outright.

MSNBC's coverage of the Washington Post poll is instructive as to how the progressive media handle inconvenient facts. From the time the poll was released, through August 16, 2012, MSNBC ran 19 stories on voter ID. Not a single one mentioned the Washington Post poll. Instead, according to Mediate, MSNBC hosts Chris Matthews, Al Sharpton, Ed Schultz, Rachel Maddow and their guests attacked voter ID laws with racist rhetoric such as "voting suppression," "poll taxes" and "literacy tests."27

MSNBC is guilty of dishonesty by omission. Serious journalists would, at a minimum, address the poll results. An opinion journalist may disagree with the majority of Americans, but, they, too, should address the poll and explain why they stand among the minority on the issue.

Writing for Mediate, columnist Noah Rothman criticized MSNBC for ignoring the Washington Post poll, saying, "[t]hese are earth-shattering numbers in a nation that cannot agree on anything – from the Boy Scouts to baseball – to the tune of 74/23 percent. This newsworthy poll about a heated issue that is a major subject of debate should penetrate the national dialogue. However, if you only watched MSNBC, you could be excused for thinking that voter ID represents an existential threat to democracy and amounts to a coup being perpetrated by Republican-dominated state legislatures."28

 

What the Mainstream Media Reports

The mainstream media largely present voter ID laws as voter suppression and claim that voter fraud does not exist. Relying on supposed academic work of think-tanks and advocacy groups, journalists present reports and studies by these third-party groups to give an academic veneer to their otherwise unfounded claims. Too often, however, the reports suffer from bias and data errors.

News21

On August 11, 2012, the Washington Post reported on a new study by News21 that claimed only ten cases of voter fraud have occurred since 2000.29 Compiling what they purport to be an "exhaustive" and "comprehensive" voter fraud database, the authors claim, "[a] new nationwide analysis of more than 2,000 cases of alleged election fraud over the past dozen years shows that in-person voter impersonation on Election Day, which has prompted 37 state legislatures to enact or consider tougher voter ID laws, was virtually nonexistent."30 Further analysis reveals, however, that the News21 report is irreparably flawed and the accompanying Washington Post article is misleading.

The authors of the News21 report are actually college students who wrote the accompanying Washington Post article, trumpeting their own work. National Center for Public Policy Research Executive Director David Almasi criticized the report and the Post article, saying "[i]t's essentially a press release for News21 on page A3 of the biggest newspaper in the nation's capital… the Post should[n't] become a giant national refrigerator upon which C-level work is prominently posted."31

Almasi investigated the report and found it was, "riddled with incomplete and bad data."32 He pointed out: "News21 reportedly spent $1,800 sending out over 2,000 public records requests to various state and local election boards. So they got over 2,000 replies for the database, right? "No." Many states — including Massachusetts, South Dakota and Oklahoma — sent back nothing at all."33

Additionally, the News21 article had a sidebar in which the authors admitted limitations and gaps in their work. They noted the following problems:

• "[I]t is possible that some jurisdictions which did respond failed to include some cases."

• "Despite the huge News21 public-records request effort, the team received no useful responses from several states."

• "Hundreds of officials responded with short notes — some handwritten, even coffee-stained — saying they had no cases of fraud."

• "Some jurisdictions insisted that their computer system lacked the capability to search for election fraud cases."

• "Dozens of jurisdictions flatly refused the requests."

• "For nearly all the data News21 received, there would be some vital piece of information that had been requested specifically but that was missing."

• "[T]here are cases in the database that contain so little detail that they cannot be properly categorized as one kind of fraud or another."34

Any objective journalist or publication would be derelict in reporting the findings of this study without a massive disclaimer listing the glaring shortcomings of the authors' research. What we are left with, as Almasi lamented, is that "the News21 report is still being trumpeted by others who should know better as a justification for the Obama Administration and its leftist supporters to try to lay waste to very popular and democratically-enacted polling place protections in 37 states."35

The evidence backs up Almasi's fear: after the News21 report surfaced, the Washington Post editorial board presented it without caveat,36 as did the Atlanta Blackstar,37 the Detroit Free Press38 and many others. Additional outlets – just as the Washington Post did – gave the News21 authors page space to publicize their report. NBC News presented the News 21 article without critique,39 as did the Kansas City Star40 and USA Today.41

News 21 is not the only organization that escapes media scrutiny. The media often cite advocacy groups to give their stories a faηade of objectivity. In reality, however, they are often little more than biased reports from advocacy firms.

Brennan Center for Justice

One of the most highly cited opponents of voter integrity measures is the Brennan Center for Justice. Operating out of New York University Law School, the Brennan Center is often cited by the media as proof that millions of Americans do not possess government-issued photo ID and that voter fraud rarely occurs.

In 2006, the Brennan Center published "Citizens Without Proof," a report that claimed 11 percent of Americans do not have a photo ID.42 Election scholars with the Heritage Foundation evaluated the report, noting that the Brennan Center polling was flawed and concluded that "[b]y eschewing many of the traditional scientific methods of data collection and analysis, the authors of the Brennan Center study appear to have pursued results that advance a particular political agenda rather than the truth about voter identification."43

Despite the fact that Brennan Center work has been debunked by election scholars, the media continue to present it in both news and opinion columns to support claims that millions of Americans (specifically minority, poor and elderly) do not possess photo ID.

In 2007, the Brennan Center published "The Truth About Voter Fraud," claiming that "[a]llegations of widespread voter fraud, however, often prove greatly exaggerated… on closer examination, many of the claims of voter fraud amount to a great deal of smoke without much fire. The allegations simply do not pan out."44

A prominent election law attorney also criticized that report. Calling the Brennan Center "[o]ne of the most dishonest and aggressive voter fraud deniers," former Justice Department attorney J. Christian Adams noted that, five months before the Brennan Center report came out, he prosecuted a massive voter fraud case in Mississippi. According to Adams, the Brennan Center "ignored the detailed court ruling because the avalanche of voter fraud did not fit their thesis."45

In addition to its biased and flawed reporting, the Brennan Center has received more than $7 million from liberal activist donor George Soros further damaging the group's claim to objectivity.46 The National Center's GroupSnoop.org series published a profile of the Brennan Center in July 2012 that exposed the group's bias, history of sloppy work and liberal funding.47 The report reveals how the media often present Brennan Center studies as facts and not advocacy.

For instance, on July 17, 2012, the Brennan Center published a report titled "The Challenge of Obtaining Voter Identification."48 The report claimed that ten states with voter ID laws are placing poll taxes on its citizenry by requiring a photo ID – even though the Brennan Center conceded that these states provide free IDs to low-income residents.49 The next day, July 18, 2012, the Washington Post,50 National Public Radio51 and Rachel Maddow's blog for MSNBC52 all heralded the report in news stories. None of the articles mentioned the Brennan Center's established bias or its ties to George Soros.

Announcing the Brennan Center's GroupSnoop.org profile, I said: "Brennan Center work should be presented as opinion - if it is considered at all. The Brennan Center is a George Soros-funded, extreme advocacy group that appears willing to fight all meaningful efforts to combat voter fraud. It should be regarded as such."53

 

Conclusion

The mainstream media are engaged in a massive misinformation campaign aimed at vilifying voter ID laws. By ignoring the legal history of voter ID laws, using biased third-party reports and injecting racial rhetoric into their stories, the media are creating a false narrative that distorts the truth. However, the public is not fooled. Polls show that Americans of all stripes broadly support voter ID laws. Voter ID laws remain a commonsense, constitutional way to combat voter fraud and the American people know that – in spite of the mainstream media's concerted efforts to distract them from the truth.

Justin Danhof, Esq., is General Counsel for the National Center for Public Policy Research.


 

Footnotes:

1 Dan Froomkin, "Reporters Know What the 'Voter ID' Push is Really About. Why Don't They Just Say So?," Huffington Post, July 30, 2012, available at http://www.huffingtonpost.com/dan-froomkin/reporters-know-what-the-v_b_1719778.html as of August 21, 2012.

2 Dan Froomkin, "Reporters Know What the 'Voter ID' Push is Really About. Why Don't They Just Say So?," Huffington Post, July 30, 2012, available at http://www.huffingtonpost.com/dan-froomkin/reporters-know-what-the-v_b_1719778.html as of August 21, 2012.

3 Ethan Magoc, "Many States' Voter-ID Laws, Including Pennsylvania's, Appear to Have Tie to Same U.S. Group," Philadelphia Enquirer, August 14, 2012, available at http://www.philly.com/philly/news/politics/Many_states_voter-ID_laws_including_Pennsylvanias_appear_to_have_tie_to_same_US_group.html as of August 22, 2012.

4 The National Conference of State Legislatures has an interactive map showing voting requirements in each state, available at http://www.ncsl.org/legislatures-elections/elections/voter-id.aspx as of August 21, 2012.

5 See infra, Washington Post poll.

6 Full case site is: Crawford v. Marion County Election Board, 553 U.S. 181 (2008).

7 Crawford v. Marion County Election Board, Brief for Petitioners, available at http://www.aclu.org/files/pdfs/scotus/crawford_v_marioncounty_brief.pdf as of August 22, 2012. ("It is uncontested there is no evidence that there has ever been any in-person impersonation voting fraud in Indiana. Indeed, studies demonstrate that in-person impersonation fraud in voting is an extremely rare phenomenon anywhere.")

8 Crawford v. Marion County Election Board, Brief for Petitioners, available at http://www.aclu.org/files/pdfs/scotus/crawford_v_marioncounty_brief.pdf as of August 22, 2012. ("[T]he law 'will make it significantly more difficult for some eligible voters . . . to vote. And, this group is mostly comprised of people who are poor, elderly, minorities, disabled or some.")

9 Crawford v. Marion County Election Board, 553 U.S. 181 (2008).

10 Crawford v. Marion County Election Board, 553 U.S. 181 (2008).

11 As of August 2012, Texas, South Carolina, Pennsylvania and Wisconsin were all involved in legal battles over their voter ID laws.

12 Justin Danhof, "How the Media Hates One U.S. Supreme Court Case So much They Tried to Make it Disappear," Amy Ridenour's National Center Blog, August 16, 2012, available at http://www.conservativeblog.org/amyridenour/2012/8/16/how-the-media-hates-one-us-supreme-court-case-so-much-they-t.html as of August 22, 2012.

13 Justin Danhof, "How the Media Hates One U.S. Supreme Court Case So much They Tried to Make it Disappear," Amy Ridenour's National Center Blog, August 16, 2012, available at http://www.conservativeblog.org/amyridenour/2012/8/16/how-the-media-hates-one-us-supreme-court-case-so-much-they-t.html as of August 22, 2012.

14 The three sources were: Justin Danhof, "How the Media Hates One U.S. Supreme Court Case So much They Tried to Make it Disappear," Amy Ridenour's National Center Blog, August 16, 2012, available at http://www.conservativeblog.org/amyridenour/2012/8/16/how-the-media-hates-one-us-supreme-court-case-so-much-they-t.html as of August 20, 2012; Horace Cooper, "Victims of Voter Fraud: Poor and Disadvantaged are Most Likely to Have Their Vote Stolen," National Center for Public Policy Research – National Policy Analysis, August 2012, available at http://www.nationalcenter.org/NPA635.html as of August 20, 2012; Mary Silver, "Pennsylvania Voter ID Law on Trial," Epoch Times, last updated August 6, 2012, available at http://www.theepochtimes.com/n2/united-states/pennsylvania-voter-laws-challenged-conference-july-31-273415.html as of August 20, 2012.

15 Justin Danhof, "How the Media Hates One U.S. Supreme Court Case So much They Tried to Make it Disappear," Amy Ridenour's National Center Blog, August 16, 2012, available at http://www.conservativeblog.org/amyridenour/2012/8/16/how-the-media-hates-one-us-supreme-court-case-so-much-they-t.html as of August 20, 2012.

16 In a display of pure hubris and hypocrisy, all press attending the event were forced to show government-issued photo ID. See, Katie Pavlich, "NAACP Requires Photo I.D. to see Holder Speak in State Being Sued Over Voter ID," Townhall, July 10, 2012, available at http://townhall.com/tipsheet/katiepavlich/2012/07/10/naacp_requires_photo_id_to_see_holder_speak as of August 22, 2012.

17 Conor Skelding, "Eric Holder on Voter ID Laws: 'We Call Those Poll Taxes,'" Yahoo! News, July 10, 2012, available at http://news.yahoo.com/blogs/ticket/eric-holder-voter-id-laws-call-those-poll-193012336.html as of August 22, 2012.

18 Justin Danhof, "How the Media Hates One U.S. Supreme Court Case So much They Tried to Make it Disappear," Amy Ridenour's National Center Blog, August 16, 2012, available at http://www.conservativeblog.org/amyridenour/2012/8/16/how-the-media-hates-one-us-supreme-court-case-so-much-they-t.html as of August 22, 2012.

19 Commonly attributed to Daniel Patrick Moynihan.

20 "Fear of Voter Suppression High, Fear of Voter Fraud Higher," Washington Post, August 13, 2011, available at http://www.washingtonpost.com/page/2010-2019/WashingtonPost/2012/08/12/National-Politics/Polling/release_116.xml?uuid=E1kPqOQZEeGJ93biOpgtBg as of August 22, 2012.

21 Noah Rothman, "MSNBC Broadcasts 19 Segments On Voter I.D. This Week, Ignores Poll Showing 74% Support for I.D. Laws," Mediaite, August 16, 2012, available at http://www.mediaite.com/online/msnbc-broadcasts-19-segments-on-voter-i-d-this-week-ignores-poll-showing-74-support-for-i-d-laws/ as of August 17, 2012.

22 "73% Think Photo ID Requirement Before Voting Does Not Discriminate," Rasmussen Reports, April 16, 2012, available at http://www.rasmussenreports.com/public_content/politics/general_politics/april_2012/
73_think_photo_id_requirement_before_voting_does_not_discriminate
as of August 22, 2012.

23 Peter Roff, "Poll: Democrats and Republicans Support a Voter ID-Check Law," U.S. News & World Report, June 10, 2011, available at http://www.usnews.com/opinion/blogs/peter-roff/2011/06/10/poll-democrats-and-republicans-support-a-voter-id-check-law as of August 22, 2012.

24 Michael Brandon and Jon Cohen, "Poll: Voter ID Laws Have Support of a Majority of Americans," Washington Post, August 11, 2012, available at http://www.washingtonpost.com/politics/poll-concerns-about-voter-fraud-spur-broad-support-for-voter-id-laws/2012/08/11/40db3aba-e2fb-11e1-ae7f-d2a13e249eb2_story.html as of August 22, 2012.

25 Michael Brandon and Jon Cohen, "Poll: Voter ID Laws Have Support of a Majority of Americans," Washington Post, August 11, 2012, available at http://www.washingtonpost.com/politics/poll-concerns-about-voter-fraud-spur-broad-support-for-voter-id-laws/2012/08/11/40db3aba-e2fb-11e1-ae7f-d2a13e249eb2_story.html as of August 22, 2012.

26 Libby Sternberg, "Why Demonize Voter ID Policies?" Hot Air, August 20, 2012, available at http://hotair.com/greenroom/archives/2012/08/20/why-demonize-voter-id-policies/ as of August 22, 2012.

27 Noah Rothman, "MSNBC Broadcasts 19 Segments On Voter I.D. This Week, Ignores Poll Showing 74% Support for I.D. Laws," Mediaite, August 16, 2012, available at http://www.mediaite.com/online/msnbc-broadcasts-19-segments-on-voter-i-d-this-week-ignores-poll-showing-74-support-for-i-d-laws/ as of August 22, 2012.

28 Noah Rothman, "MSNBC Broadcasts 19 Segments On Voter I.D. This Week, Ignores Poll Showing 74% Support for I.D. Laws," Mediaite, August 16, 2012, available at http://www.mediaite.com/online/msnbc-broadcasts-19-segments-on-voter-i-d-this-week-ignores-poll-showing-74-support-for-i-d-laws/ as of August 22, 2012.

29 Natasha Khan and Corbin Carson, "Election Day Impersonation, an Impetus for Voter ID Laws, a Rarity, Data Show," Washington Post, August 11, 2012, available at http://www.washingtonpost.com/politics/election-day-impersonation-an-impetus-for-voter-id-laws-a-rarity-data-show/2012/08/11/7002911e-df20-11e1-a19c-fcfa365396c8_story.html as of August 21, 2012.

30 Natasha Khan and Corbin Carson, "Election Day Impersonation, an Impetus for Voter ID Laws, a Rarity, Data Show," Washington Post, August 11, 2012, available at http://www.washingtonpost.com/politics/election-day-impersonation-an-impetus-for-voter-id-laws-a-rarity-data-show/2012/08/11/7002911e-df20-11e1-a19c-fcfa365396c8_story.html as of August 21, 2012.

31 David Almasi, "Voter ID News That's Not Fit to Print," Amy Ridenour's National Center Blog, August 15, 2012, available at http://www.conservativeblog.org/amyridenour/2012/8/15/voter-id-news-thats-not-fit-to-print.html as of August 21, 2012.

32 David Almasi, "Voter ID News That's Not Fit to Print," Amy Ridenour's National Center Blog, August 15, 2012, available at http://www.conservativeblog.org/amyridenour/2012/8/15/voter-id-news-thats-not-fit-to-print.html as of August 21, 2012.

33 David Almasi, "Voter ID News That's Not Fit to Print," Amy Ridenour's National Center Blog, August 15, 2012, available at http://www.conservativeblog.org/amyridenour/2012/8/15/voter-id-news-thats-not-fit-to-print.html as of August 21, 2012.

34 Corbin Carson, "Exhaustive Database of Voter Fraud Cases Turn Up Scant Evidence that It Happens," News21, August 12, 2012, available at http://votingrights.news21.com/article/election-fraud-explainer/ as of August 21, 2012.

35 David Almasi, "Voter ID News That's Not Fit to Print," Amy Ridenour's National Center Blog, August 15, 2012, available at http://www.conservativeblog.org/amyridenour/2012/8/15/voter-id-news-thats-not-fit-to-print.html as of August 22, 2012.

36 "The Truth About Voter Fraud," Washington Post, August 13, 2012, available at http://www.washingtonpost.com/opinions/the-truth-about-voter-fraud/2012/08/13/7d6f5ad2-e58b-11e1-936a-b801f1abab19_story.html as of August 21, 2012.

37 Jackie Jones, "Report: Despite GOP Claims, Voter Fraud Virtually Non-Existent in U.S.," Atlanta Blackstar, August 21, 2012, available at http://atlantablackstar.com/2012/08/21/report-despite-gop-claims-voter-fraud-virtually-non-existent-in-u-s/ as of August 21, 2012.

38 Rochelle Riley, "GOP Caught With Voter Suppression Pants Down," Detroit Free Press, August 14, 2012, available at http://www.freep.com/article/20120814/COL10/120814050/rochelle-riley-republicans-voter-suppression-ID-law as of August 21, 2012.

39 Natasha Khan and Corbin Carson, "New Database of US Voter Fraud Finds No Evidence That Photo ID Laws are Needed," NBC News, August 11, 2012, available at http://openchannel.nbcnews.com/_news/2012/08/11/13236464-new-database-of-us-voter-fraud-finds-no-evidence-that-photo-id-laws-are-needed as of August 22, 2012.

40 Natasha Khan and Corbin Carson, "Voter Fraud Found to be Rare, Survey Indicates" Kansas City Star, August 13, 2012, available at http://www.kansascity.com/2012/08/13/3760122/voter-fraud-found-to-be-rare-survey.html as of August 22, 2012.

41 Natasha Khan, "Voter Fraud is Rare in U.S.," USA Today, August 19, 2012, available at http://www.usatoday.com/USCP/PNI/Front%20Page/2012-08-20-PNI0820met-voter-fraudPNIBrd_ST_U.htm as of August 22, 2012.

42 "Citizens Without Proof: A Survey of Americans' Possession of Documentary Proof of Citizenship and Photo Identification," Brennan Center for Justice, November 2006, available at http://www.brennancenter.org/page/-/d/download_file_39242.pdf as of August 22, 2012.

43 Hans A. von Spakovsky and Alex Ingram, "Without Proof: The Unpersuasive Case Against Voter Identification," Heritage Foundation – Legal Memorandum #72, August 24, 2011, available at http://www.heritage.org/research/reports/2011/08/without-proof-the-unpersuasive-case-against-voter-identification as of August 22, 2012.

44 Justin Levitt, "The Truth About Voter Fraud," Brennan Center for Justice, November 9, 2007, available at http://www.truthaboutfraud.org/pdf/TruthAboutVoterFraud.pdf as of August 22, 2012.

45 J. Christian Adams, "Soros Funded Newspaper Praises Soros Funded Brennan Center," PJ Media, December 31, 2011, available at http://pjmedia.com/jchristianadams/2011/12/31/soros-funded-newspaper-praises-soros-funded-brennan-center/ as of August 22, 2012.

46 Jack Coleman, "Ezra Klein Describes Soros-Funded Brennan Center as 'Non Partisan'," NewsBusters, June 15, 2012, available at http://m.newsbusters.org/blogs/jack-coleman/2012/06/15/ezra-klein-describes-soros-funded-brennan-center-non-partisan as of August 22, 2012.

47 The Brennan Center for Justice Profile is available at http://www.groupsnoop.org/Brennan+Center+for+Justice as of August 22, 2012.

48 Keesha Gaskins and Sundeep Iyer, "The Challenge of Obtaining Voter Identification," Brennan Center for Justice, July 17, 2012, available at http://brennan.3cdn.net/2232d41548789ffdf6_9km6b4d67.pdf as of August 22, 2012.

49 Keesha Gaskins and Sundeep Iyer, "The Challenge of Obtaining Voter Identification," Brennan Center for Justice, July 17, 2012, available at http://brennan.3cdn.net/2232d41548789ffdf6_9km6b4d67.pdf as of August 22, 2012.

50 Krissah Thompson, "Study Finds Costs Associated With Voter IDs," Washington Post, July 18, 2012, available at http://www.washingtonpost.com/politics/study-finds-costs-associated-with-voter-ids/2012/07/17/gJQAlrcXsW_story.html as of August 22, 2012.

51 Pam Fessler, "Study: Many Could Face Obstacles In Voter ID Laws," National Public Radio, July 18, 2012, available at http://www.npr.org/2012/07/18/156935624/study-many-could-face-obstacles-in-voter-id-laws as of August 22, 2012.

52 Steve Benen, "The Costs of Voter-ID Laws," The Maddow Blog – MSNBC, July 18, 2012, available at http://maddowblog.msnbc.msn.com/_news/2012/07/18/12810793-the-costs-of-voter-id-laws?lite as of August 22, 2012.

53 "Report Exposes Brennan Center for Justice's Biased Reporting and Liberal Funding; New GroupSnoop.org Profile of the Brennan Center for Justice Released; Leading Opponent of Voter Integrity Measures is Financed By George Soros," National Center for Public Policy Research – Press Release, July 26, 2012, available at http://www.nationalcenter.org/PR-Brennan_Center_072612.html as of August 22, 2012.


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