North Carolina: Civil Rights Groups Vow to Overturn Voting Reform Law | ABC

North Carolina’s sweeping and restrictive new voting law is facing multiple legal challenges from civil rights groups that argue it discriminates against black and young voters. Republican Governor Pat McCrory signed the bill Monday, which goes into effect in 2016. Among other things, the law requires voters to bring state-issued photo IDs to the polls, cuts down early voting time by one week, eliminates same-day voter registration, and bans pre-registration for youth voters who will turn 18 on Election Day. The American Civil Liberties Union, along with two other groups, immediately filed a legal challenge that argues the law attempts to suppress minority voters, thereby violating the Constitution and the 1965 Voting Rights Act. The NAACP has filed a similar suit.

Editorials: North Carolina law takes war on voting rights to a new low | The Washington Post

In the wake of the Supreme Court’s Shelby v. Holder decision, which gutted significant portions of the Voting Rights Act, it’s difficult to say which of the many recently passed voter-suppression bills constitutes the greatest threat to that most sacred of American freedoms: the right to vote. The contest has several leading contenders, but the winner just might be North Carolina’s especially draconian bill, signed into law on Monday. The bill includes the usual provisions that have come to characterize the quiet assault on the franchise: a shortened early-voting period, the elimination of the state’s successful same-day registration program and, of course, a strict photo identification requirement despite any evidence of voter fraud in the state.

Editorials: Vote suppression is the real voting fraud in South Carolina | Brett Bursey/The State

When I saw Rep. Alan Clemmons’ guest column, “Voting problems continue to haunt us” (July 21), I was hoping he’d explain his part in peddling the myth of dead people voting in South Carolina, and apologize to the people he misled. He did neither. Instead, he again claimed an “undeniable presence of election fraud in South Carolina,” and took a cheap shot at the S.C. Progressive Network to make his point. He referenced an instance years ago when bogus forms were turned in by someone the network hired to do voter registration in Florence County. I caught the fraud myself and called SLED and the County Election Board the day the forms were submitted. No fraudulent votes were cast. I testified against the perpetrator, and he went to jail. The system worked.

Editorials: No fair play in Moscow mayoral election | Russia Beyond The Headlines

The first major scandals of the Moscow mayoral campaign have erupted. The Prosecutor General of Russia claimed to have found evidence that opposition candidate Alexei Navalny received funding for his campaign from overseas, while Navalny has released information about the misdealings of his main rival, current acting mayor of Moscow Sergey Sobyanin. Experts think the mudslinging is unlikely to swing voters one way or the other, although Navalny’s alleged transgressions may lead to his removal from the race. The Liberal Democratic Party of Russia (LDPR) was the first to drive attention towards the source of funding in Navalny’s election campaign. An investigation by the Prosecutor General’s office following a complaint filed by LDPR leader Vladimir Zhirinovsky has revealed that more than 300 foreign entities – businesses, private individuals and anonymous donors – from 46 countries and 347 addresses used the Yandex.Money electronic payment system to send money to the digital wallets of Navalny and other members of his campaign team. According to reports from Russian newswire Interfax, the evidence has been forwarded to the Investigation Committee so that a criminal proceeding can be initiated.

North Carolina: Governor signs sweeping voter ID bill into law | Los Angeles Times

One of the nation’s most restrictive voter ID bills was signed into law Monday by North Carolina’s Gov. Pat McCrory, a Republican. The new law requires voters to show government-issued ID cards, with polling places not allowed to accept college ID cards or out-of-state driver’s licenses. The law also shortens early voting by a week; eliminates same-day voter registration; allows any registered voter to challenge another voter’s eligibility; and ends popular preregistration for high school students. Republicans have said the law will combat voter fraud and restore integrity to voting, but they have offered no evidence of voter fraud in the state. Civil rights groups and many independent analysts say the law is a blatant attempt to curb voting by blacks, students, the poor and other groups that tend to vote Democratic. The law takes effect for the 2016 elections. Civil rights groups have threatened to sue the state and Atty. Gen. Eric Holder has said the Justice Department may pursue legal challenges to voter ID laws passed by several states, including North Carolina. North Carolina Republicans introduced the so-called Restore Confidence in Government Act after the Supreme Court struck down a key provision of the 1965 Voting Rights Act in June. The court overturned the Act’s requirement for Justice Department “pre-clearance” for any changes to voting laws in certain states.

Pennsylvania: Judge again blocks Pennsylvania voter ID law…for now | CNN

A Pittsburgh judge on Friday barred enforcement of Pennsylvania’s voter-identification law for the Nov. 5 general election, as well as any election that may come before. State Judge Bernard McGinley’s preliminary injunction means Pennsylvania will again go the polls with no enforcement of the law – a different judge made similar ruling a month before the 2012 presidential election. In fact, the controversial law has never been implemented; it has languished in a legal limbo since Republican Governor Tom Corbett signed the bill into law in March of 2012.

Editorials: Texas and the Voting Rights Act: Bigotry for the right reasons | The Economist

Last month Eric Holder, the attorney-general, asked a district court to make Texas “pre-clear” any proposed changes to its election procedures with the federal government. Texas was doing this as a matter of course in every election for the last 40 years: it was subject to Section 5 of the Voting Rights Act (VRA). That section requires jurisdictions with a history of discrimination against minority voters to get approval from either the Justice Department or a federal district court in Washington, DC before changing their election procedures to ensure those changes have “neither discriminatory purpose or effect”. But the Supreme Court’s ruling in Shelby County v Holder last June made Section 5 vestigial. The court found that the formula used to determine which jurisdictions must pre-clear changes was outdated, but it did not, as some VRA opponents had hoped, find Section 5 a violation of the tenth amendment. Hence Mr Holder’s turn to the previously little-used (because little-needed) Section 3 of the VRA, which lets courts mandate pre-clearance for jurisdictions found to be violating the 14th- or 15th-amendment guarantees of equal protection and access to the ballot. In this case, Mr Holder argues, the violation stems from state redistricting plans proposed in 2011—plans that a federal court already rejected, saying that they “provided more evidence of discriminatory intent than [the Court had] space, or need, to address.”

Editorials: Hillary Clinton's voter rights crusade | theguardian.com

increasingly likely that Hillary Clinton will be taking another shot at the presidency in 2016. She hasn’t announced her candidacy yet and may not do so for at least two more years, but preparations appear to be underway – and pretty much everyone seems to be assuming that getting the Democratic nomination is a done deal for her. Which, of course, would mean that we might soon have our first woman president. Time will tell how this will all play out, but at least we can take comfort in the knowledge that if Mrs Clinton actually does become the 45th “POTUS”, it will not be because she or any other power players in the Democratic party spent years devising ingenious schemes to disenfranchise blocs of voters who tend to support the opposition. On Monday, in the first of a series of policy speeches, Hillary Clinton spoke about the worrying implications of the US supreme court’s recent decision to strike down a key provision of the Voting Rights Act (VRA). The provision required states with a history of discrimination to get pre-clearance from the Department of Justice (DOJ) before they passed any laws that changed voting procedures. Clinton pointed out that in the past 15 years, the VRA has been used to block nearly 90 attempts to pass discriminatory voting laws. Since the provision was struck down just over a month ago, Republican law makers in several states have wasted no time ramming through highly restrictive voting laws that will make it more difficult, if not impossible, for millions of Americans to exercise their right to vote.

Editorials: Burning the house to roast the pig: Can elections be saved by banning political speech? | SCOTUSblog

The central paradox of most campaign finance reform measures is that they are premised on the odd notion that political speech is far too important to be free. That paradox presents itself to the Justices yet again in McCutcheon v. Federal Election Commission as they prepare to rule on another First Amendment challenge to a campaign finance restriction on political spending. Of course, the proponents of such regulations rarely frame the issue that way.  Rather, they generally argue that the First Amendment was never intended to allow unfettered political participation in the form of campaign contributions or expenditures and that the activity they seek to regulate is not really protected expression. They also argue that the subjects of their intended regulation are not entitled to constitutional privileges. This has generated two great bumper sticker themes that have dominated the “tastes great-less filling” shouting match over political campaign regulation since Buckley v. Valeo (1976), and Citizens United v. FEC (2010):  (1) Is money speech?, and (2)  Are corporations people?  These aren’t the actual legal questions at issue of course, but are merely the caricatures of the underlying questions as translated in the political realm.

Colorado: Recall Election Update: Libertarians Strike Back | The American Spectator

As I mentioned yesterday, the Libertarian Party of Colorado sued the State of Colorado to get more time to petition candidates on to the ballots to replace two state senators who are facing recall elections. It seemed to me that the Libertarians were likely to win because their argument was based squarely on the state constitution, even though a victory by them would through some chaos into the election, particularly by making it impossible to conduct a proper mail-in ballot election. Indeed, news reports say that despite the recent passage of a law that requires all major Colorado elections to be by mail, this election will not be. Yesterday, the judge in the case ruled for the Libertarians, meaning they will have until late August to try to submit enough valid signatures to have their candidates’ names appear on the ballot.

Hawaii: U.S. Supreme Court May Hear Appeal on Hawaii Reapportionment | Honolulu Civil Beat

Hawaii’s drawn-out process to settle on its political district boundaries isn’t quite finished. On Friday, the plaintiffs who are suing the state Office of Elections over its 2011 reapportionment plan appealed their case to the U.S. Supreme Court. The appeal was filed just one month after the U.S. District Court in Honolulu rejected the plaintiff’s claim that the plan is unconstitutional. The claim is based on the fact that the plan removed more than 100,000 military personnel, their dependents and out-of-state university students from district populations. Five of the eight plaintiffs, including congressional candidate and state Rep. Mark Takai, are military personnel, dependents or veterans. Attorney Robert Thomas said his clients want to see district lines redrawn to include military personnel stationed in Hawaii.

Iowa: State gains federal access to investigate voter fraud | The Des Moines Register

After months of negotiations and paperwork, Iowa Secretary of State Matt Schultz said Wednesday his office will gain access to a federal immigration database it can use to investigate potential voter fraud. Schultz, a Republican, released a signed memorandum of understanding between his office and the U.S. Department of Homeland Security that will allow him to tap the Systematic Alien Verification for Entitlements, or SAVE, Program, which tracks the legal status of immigrants. “While there are still many logistics to work out in this process that may take some time, I want to thank the Federal government for finally granting my office access to the federal SAVE program,” Schultz said in a statement. “Ensuring election integrity without voter suppression has been our goal throughout this process. This is a step in the right direction for all Iowans that care about integrity in the election process.”

North Carolina: Elections boards move to curtail student voting | The State

Within hours of Gov. Pat McCrory signing a Republican-backed bill this week making sweeping changes to the state’s voting laws, local elections boards in two college towns made moves that could make it harder for students to vote. The Watauga County Board of Elections voted Monday to eliminate an early voting site and election-day polling precinct on the campus of Appalachian State University. The Pasquotank County Board of Elections on Tuesday barred an Elizabeth City State University senior from running for city council, ruling his on-campus address couldn’t be used to establish local residency. Following the decision, the head of the county’s Republican Party said he plans to challenge the voter registrations of more students at the historically black university ahead of upcoming elections. Voting rights advocates worry the decisions could signal a statewide effort by GOP-controlled elections boards to discourage turnout among young voters considered more likely to support Democrats.

Editorials: The long road ahead for voting rights | NC Policy Watch

State GOP lawmakers wasted no time ramping up their efforts to drastically change voting in North Carolina after the U.S. Supreme Court, in Shelby County v. Holder, gutted the requirement that certain jurisdictions get proposed voting changes pre-approved. “Now we can go with the full bill,” Senator Tom Apodaca told WRALthat same day, referring to an omnibus voting bill that would do more than just require voter ID; it would reduce early voting, eliminate Sunday voting and ban same-day registration. Go they did, pushing House Bill 589 through both chambers and on to Gov. Pat McCrory’s desk for signature in just weeks and prompting voting rights advocates and even the Attorney General to warn that, by signing the bill into law, the governor would be casting the state into a protracted and costly battle in the courts. And those groups wasted no time, after the governor signed H589 into law on Monday, hauling McCrory and the state into court, filing three separate lawsuits challenging the law.

Editorials: McCrory offers shallow rhetoric to justify North Carolina Voter ID law | Charlotte News Observer

Even as Gov. Pat McCrory put pen to paper Monday, specifically the pen that signed the Voter ID bill into law, two lawsuits were on the way in federal court, a third was being readied for state court, and U.S. Rep. G.K. Butterfield of North Carolina’s 1st Congressional District was asking U.S. Attorney General Eric Holder to use his authority to ensure voting rights in this state. McCrory mouthed the rationalizations of Republican ideologues in the legislature who have been giving the governor his marching orders for six months. The governor said the new law would prevent voter fraud. He didn’t bother to mention that voter fraud is about as big a threat in North Carolina as an invasion of dinosaurs (excepting the Republicans on Jones Street). And he of course didn’t linger on the other parts of the legislation clearly designed to give Republicans an advantage in future elections, blatantly political maneuvers: no more straight-ticket voting, which is favored by more Democrats than Republicans; no more same-day registration and voting, again something shown to be used more by Democrats; early voting periods will be shorter, and early voting also tends to draw more Democrats; no more pre-registration for students younger than 18, as the young tend to lean Democratic.

Ohio: Voting problems prompt retraining of poll workers | Cincinnati Enquirer

Hundreds of Hamilton County poll workers will be retrained – and 163 “retired” – as a result of voting problems in the 2012 election. That includes 94 workers at 16 precincts that will be completely re-staffed because of a high number of errors. The others failed to vote themselves and/or performed poorly on Election Day. Those 163 poll workers represent about 5.6 percent of poll workers – the most ever who aren’t being asked back. The move comes as board of elections officials continue to work to find the 2,905 poll workers needed to staff the county’s 545 polling locations.

Editorials: Fair elections and double standards | Cincinnati Enquirer

The decision not to prosecute Hamilton County voters who had registered using addresses that weren’t their residences seems on its face like a reasonable one. But in light of the recent five-year sentence handed down to a poll worker convicted of voter fraud, it’s imperative that officials strive to treat all cases of voter impropriety with the same standards. The 85 voters who registered using ineligible addresses may or may not have known that doing so is a felony. They include more than a dozen police officers who registered using the police stations where they work, apparently in an attempt to keep their home addresses from becoming public knowledge.

Texas: Texas AG Acknowledges GOP Redistricting Decisions Made 'At The Expense Of The Democrats' | Huffington Post

Texas Attorney General Greg Abbott (R) explicitly referenced Texas Republicans’ gerrymandering tactics in a court brief earlier this month, acknowledging that districts were redrawn in 2011 to minimize the clout of Democratic voters. In July, Attorney General Eric Holder filed a lawsuit, arguing that the state should be required to undergo some form of preclearance with districting plans. A month before, the United States Supreme Court had struck down key provisions of the Voting Rights Act, meaning that the Texas redistricting plan was no longer subject to federal preclearance requirements.

Canada: Cost, security dampen online voting enthusiasm in London | Metro

Leamington residents will be able to cast ballots in their next municipal election by doing nothing more than tapping a mouse from the comfort of their own home. But Londoners may have to wait a while before they get that luxury. Leamington’s decision to allow online voting was based on a number of factors, officials say, not the least of which was the opportunity to reverse a trend in many municipalities of voter apathy. London city clerk Cathy Saunders wouldn’t rule out a similar move locally for the 2014 election, but said there are many questions that have to be answered before a go-ahead could be given. “We still remain somewhat concerned with the online voting,” she said. “We still have some security concerns.”

Editorials: German Election Could Still Surprise | Wall Street Journal

Don’t consider German elections a done deal just yet. Judging from past experience, there is still room for a shock as polls in Germany have often underestimated the end-results of small parties. “There is big surprise potential,” says BHF Bank in a note to clients, because the anti-euro party Alternative for Germany, or AfD, gets little attention from outside Germany. In a poll conducted by Forsa institute and published Wednesday, 3% of participants said they would vote for the AfD in September 22 elections. The result is well below the 5% threshold needed for parties to enter parliament in Germany. AfD’s results in previous surveys have been similar. However, at election betting platform Prognosys, the AfD is mustering a healthy 6%, BHF points out. Prognosys lets betters place odds on the outcome of the vote.

Russia: More Parties Banned From Elections in Russia | RIA Novosti

More parties have been banned from regional elections in Russia this year than in 2012, despite the Kremlin’s attempted liberalization of political legislation, a new study said Wednesday. In total, 9.2 percent of the candidate lists submitted by parties for the September 8 elections have been banned, compared with 2.4 percent last year, according to a report by the Civil Initiatives Committee think tank, founded by longtime Kremlin insider-turned-critic Alexei Kudrin, a former finance minister.

Zimbabwe: Court Takes Up Mugabe Re-election Challenge | VoA NEws

Zimbabwe’s Electoral Court has begun hearing Prime Minister Morgan Tsvangirai’s challenge of the re-election of President Robert Mugabe in the July 31 polls. Mugabe’s swearing in has been put on hold and investors have been cautious since the re-election of the 89-year-old leader because of his policy of seizing foreign owned firms. Tsvangirai and his Movement for Democratic Change accuse the Zimbabwe Election Commission of rigging the election for Mugabe’s Zanu PF party.  On Wednesday, they were at the Electoral Court to force the commission to produce all election materials. Lewis Uriri, the lawyer for Tsvangirai, told reporters that the court reserved judgment. “Clearly time is of essence here,” he said. “We need access to those materials to demonstrate beyond doubt that the election was not properly conducted, to demonstrate the will of the people was not reflected in that election.  There must be a reason why they do not want to produce those materials.  That reason is that there are definitely, definitely, definitely, ghosts in those sealed materials that they do not want us access.”

Zimbabwe: MDC drops court challenge to Mugabe re-election | The Star Online

Zimbabwe’s opposition MDC withdrew a court challenge against President Robert Mugabe’s re-election through a vote the party had denounced as fraudulent, saying on Friday it would not get a fair hearing. Mugabe, 89, and his ZANU-PF party were declared winners of the July 31 election but the Movement for Democratic Change (MDC) led by outgoing Prime Minister Morgan Tsvangirai had filed a motion for the constitutional court to overturn the result. A hearing on the MDC challenge, which had alleged widespread vote-rigging and intimidation by ZANU-PF, had been planned for Saturday. “I can confirm that we have withdrawn the presidential election petition. There are a number of reasons, including the failure by the Zimbabwe Electoral Commission to release critical evidence in this matter,” MDC spokesman Douglas Mwonzora said. The decision appeared to end any hope of further action by the MDC through the courts, which Tsangirai’s party have said are dominated by ZANU-PF along with other state institutions in the southern African nation, formerly known as Rhodesia.

National: Congress Shows No Urgency on Voting Rights Act | Alaska Public Media

In June, the United States Supreme Court struck down a key formula of the Voting Rights Act. Section IV of the 1965 law determined which states needed to get federal approval before changing any voting laws. Alaska was one of nine states subject to that rule known as preclearance. Immediately following the ruling, a frustrated Attorney General Eric Holder condemned the decision. “Existing statutes cannot totally fill the void left by today’s Supreme Court ruling,” Holder said. “And I am hopeful new protections can and will pass in this session of Congress.” Congressional action is highly unlikely anytime soon. Supreme Court Chief Justice John Roberts wrote in his opinion that voter discrimination still exists. The court did not invalidate the entire act, just the formula determining which states need federal scrutiny. Those states include Alaska, and there have always been those in the states who have thought that was unfair, including Governor Sean Parnell, who ordered the state to join the lawsuit against it.

National: John Lewis: Still Marching on Washington, 50 Years Later | New York Times

John Lewis was the 23-year-old son of Alabama sharecroppers and already a veteran of the civil rights movement when he came to the capital 50 years ago this month to deliver a fiery call for justice on the steps of the Lincoln Memorial. As we prepare to cover the anniversary of the march and Rev. Dr. Martin Luther King Jr.’s beloved “I Have a Dream” address, we want to hear from people who were there. Mr. Lewis’s urgent cry — “We want our freedom, and we want it now!” — was eclipsed on the steps that day by the Rev. Dr. Martin Luther King Jr.’s “I Have A Dream” speech. But two years later, after Alabama State Police officers beat him and fractured his skull while he led a march in Selma, he was back in Washington to witness President Lyndon B. Johnson sign the Voting Rights Act of 1965. Today Mr. Lewis is a congressman from Georgia and the sole surviving speaker from the March on Washington in August 1963. His history makes him the closest thing to a moral voice in the divided Congress. At 73, he is still battling a half-century later. With the Voting Rights Act in jeopardy now that the Supreme Court has invalidated one of its central provisions, Mr. Lewis, a Democrat, is fighting an uphill battle to reauthorize it. He is using his stature as a civil rights icon to prod colleagues like the Republican leader, Representative Eric Cantor of Virginia, to get on board. He has also met with the mother of Trayvon Martin and compared his shooting to the 1955 murder of 14-year-old Emmett Till.

National: Report argues for lifting ban on politics from the pulpit | The Washington Post

Even as polls show Americans broadly oppose electioneering from the pulpit, a new report by a group of faith leaders working closely with Capitol Hill argues for ending the decades-old ban on explicit clergy endorsements. The report being given Wednesday to Sen. Charles E. Grassley — the Iowa Republican whose office for years has been probing potential abuses by tax-exempt groups — comes as the ban has become a culture-war flashpoint. More than 1,100 mostly conservative Christian pastors for the past few springs have been explicitly preaching politics — they call the annual event “Pulpit Freedom Sunday” — in an effort to lure the Internal Revenue Service into a court showdown. Meanwhile, groups that favor a strong church-state separation are going to courtto demand that the IRS more aggressively enforce the ban that dates to 1954.

Colorado: Sept. 10 election to go on | The Pueblo Chieftain

Denver District Judge Robert McGahey has ruled there will be no mail ballots in the Sept. 10 recall election because the state constitution requires that alternative candidates should have until 15 days before the election to qualify for the ballot. The ruling overrides the provisions of a new election law passed this year calling for mail ballots in all elections, but McGahey said the Constitution is blunt in saying candidates may petition onto the ballot until 15 days before the election. The judge’s decision means Pueblo County Clerk Gilbert “Bo” Ortiz will have to withhold the mail ballots he’s already prepared for the recall election for state Sen. Angela Giron, D-Pueblo.

Indiana: Charlie White claims Carl Brizzi is at fault for voter fraud conviction | Fox 59

Former Secretary of State Charlie White’s case of voter fraud has always been fraught with contradictions and irony. Elected as the man to enforce Indiana’s election laws, he was convicted of voter fraud for casting a ballot in a part of Fishers where he didn’t live. His attorney was a high profile former prosecutor who was known for taking on the tough cases personally, but White claims he surrendered his case without putting up a fight. White will appear before a judge in Hamilton County Thursday, seeking post conviction relief for the jury verdict that booted him from office. Behind his appeal is White’s contention that former Marion County Prosecutor Carl Brizzi practiced legal malpractice in failing to mount a defense during his trial in the winter of 2012. “Absolutely I got convicted because of ineffective counsel,” White told Fox59 News in his first interview since he filed a lawsuit against Brizzi last month. “My appeals attorney, after he read it, asked me if Carl Brizzi had ever done a trial on his own before.”

Kansas: ACLU notifies Kobach of intention to file voting rights lawsuit | LJWorld.com

The American Civil Liberties Union today notified Kansas Secretary of State Kris Kobach that it will file a lawsuit in 90 days if the state doesn’t address the issue of approximately 14,000 voter registration applications that are in limbo. “Kansans are simply trying to exercise their constitutional right to vote,” said Dale Ho, director of the ACLU’s Voting Rights Project. “This is the most fundamental freedom we have as Americans, yet Secretary of State Kobach is blocking thousands upon thousands of Kansans from their rightful participation in the political process. This is un-American, unconstitutional and must end immediately.” The dispute is over thousands of voter registration applications in Kansas since January when a new state law took effect that requires new registrations to include proof of U.S. citizenship with a document such as a birth certificate or passport.

CLU letter to Kobach ( .PDF )

North Carolina: Race at Center of North Carolina Voting Law Battle | ABC

North Carolina’s sweeping new voting law is facing multiple legal challenges from civil rights groups that argue it discriminates against black and young voters. Gov. Pat McCrory signed the bill — one of the toughest voting measures in the country — into law on Monday. It requires voters to bring photo ID to the polls, cuts down early voting time by one week, eliminates same-day voter registration and bans pre-registration for youth voters who will turn 18 on Election Day. The American Civil Liberties Union (ACLU), along with two other groups, filed a legal challenge that argues the law attempts to suppress minority voters, thereby violating the Constitution and the 1965 Voting Rights Act. The NAACP has filed a similar suit. “Today’s lawsuit is about ensuring that all voters are able to participate in the political process,” Allison Riggs, a staff attorney for the Southern Coalition for Social Justice, said in a statement. “Taken together, the new restrictions in this law will disenfranchise hundreds of thousands of eligible voters, depriving many of our most vulnerable citizens from being able to easily exercise a constitutional right.”