Arizona: Consultant: Secretary of state trying to ‘deflect responsibility’ for pamphlet error | The Arizona Republic

A former consultant to the Arizona Secretary of State’s Office said he was wrongly portrayed as contributing to that office’s failure to distribute publicity pamphlets in advance of this month’s special election. An internal investigation by Secretary Michele Reagan’s office painted the former consultant, Craig Stender, as providing guidance on how to build a pamphlet mailing list for the May 17 election. That list omitted nearly 200,000 households, affecting more than 400,000 voters. Some critics have said failure to deliver pamphlets to all voters might have affected the outcome of the vote on Proposition 123, which won by 1.8 percentage points. The pamphlets included arguments for and against the ballot measure that will put $3.5 billion into public schools over the next 10 years.

Arizona: Judge delays ruling on signature election law | Arizona Daily Star

A federal judge has refused to block a 2015 Arizona law that its legislative proponents admit was designed to try to keep minor-party candidates off the ballot. U.S. District Judge David Campbell said Friday the Arizona Libertarian Party, in waiting until last month to challenge the statute, did not leave enough time for him to consider the merits of its claims or for Secretary of State Michele Reagan to defend the law. That’s because the deadline for candidates to file their nominating petitions is June 1. Campbell said there was no reason for challengers to wait as long as they did before asking him to void the law.

California: Gov. Brown to decide whether voters will sound off in November on money in politics | Los Angeles Times

Lawmakers gave final approval Friday to a November ballot measure asking voters about the growing role of undisclosed donors in political campaign. If Gov. Jerry Brown approves, the measure would ask voters on Nov. 8 whether California’s elected officials should work to overturn the controversial 2010 U.S. Supreme Court decision in the controversial Citizens United case. “This is about trying to get the system under control,” said state Sen. Ben Allen (D-Santa Monica), the author of the legislation. The Citizens United ruling in favor of a conservative nonprofit group opened the door to unlimited spending by corporations and unions in federal candidate campaigns. Much of that spending is done by nonprofit organizations that, under IRS rules, do not have to disclose their donors.

Maryland: Deadline to ask for recount in Baltimore’s primary election is Tuesday | Baltimore Sun

With unanswered questions at 71 Baltimore precincts, candidates must decide this week whether to mount a formal challenge to a primary election in which there was a series of irregularities. The campaign of former Mayor Sheila Dixon said she was considering whether to contest the vote before the deadline Tuesday to request a recount. Martha McKenna, a spokeswoman for Dixon, said campaign officials were investigating issues left unresolved following last week’s recertification of the primary. A review by the state Board of Elections left Dixon behind state Sen. Catherine E. Pugh in the mayor’s race by 2,400 votes. “We’re pressing for more information,” McKenna said. “We’re in the process of trying to determine how we want to proceed, and we’ve contacted the [state] Board of Elections with additional questions and we’re hoping to get answers.”

New Jersey: Bill Creating Automatic Voter Registration through MVC Gains Assembly Approval | Bergen Dispatch

By a vote of 52-21-1, the full Assembly on Thursday approved legislation (A-1944) sponsored by Assembly Democrats Craig Coughlin, Gary Schaer, Tim Eustace and Joann Downey that would require the New Jersey Motor Vehicle Commission (MVC) to automatically register or update a person’s voter registration as part of the process of applying for or renewing a driver’s license. “This bill is designed to encourage participation in the democratic process by integrating voter registration with the process of driver registration,” said Coughlin (D-Middlesex). “This simple move will hopefully encourage more young people to register to vote and make it easier for residents to fulfill their civic duty.”

Editorials: Texas’s voter ID chicanery | The Washington Post

Everyone is clear on the voter-ID games that have been played in Republican-controlled state legislatures in recent years. In the name of preventing ballot fraud — of which there is virtually no evidence — GOP lawmakers have enacted restrictive bills, whose purpose and effect are to disenfranchise a certain number of reliably Democratic-leaning citizens: African Americans, Latinos and low-income voters. The most over-the-top example of voter suppression is legislation adopted in 2011 by Texas, which three federal courts have struck down. Zombie-like, it refuses to die, owing to the unembarrassed determination of Gov. Greg Abbott and other Republicans in Austin intent on resurrecting Jim Crow-style obstacles to the ballot by any means they can finagle through the judiciary.

Virginia: Herring defends McAuliffe’s voting rights order in face of GOP lawsuit | The Washington Post

Virginia Attorney General Mark Herring said Friday that Gov. Terry McAuliffe acted within his constitutional authority when he restored voting rights to more than 200,000 felons. Herring (D), acting as the state’s attorney, defended the governor’s action in a court filing in which he also objected to Republicans’ request for the Virginia Supreme Court to accelerate the timetable for a lawsuit they filed this week to stop the restoration of rights. The legal battle is the latest showdown between the Democratic governor and his allies and the Republican-controlled General Assembly over voting rights. Republican leaders have accused McAuliffe (D) of trying to add potential voters to the rolls to bolster the presidential bid of his friend, Hillary Clinton. McAuliffe denied any political motives and framed the order as a removal of the last vestige of laws such as poll taxes and literacy tests that disproportionately affected the voting rights of African Americans. One in 4 African Americans in Virginia had been banned from voting because of laws restricting the rights of those with convictions.

Wisconsin: Arguments conclude in redistricting case in federal court | Milwaukee Journal Sentinel

Wisconsin Assembly district boundaries that Republicans drew up five years ago have robbed Democratic-leaning voters of their voices, attorneys argued Friday as they wrapped up a federal trial over whether the lines are constitutional. Gerald Hebert, an attorney for a group of voters who sued over the boundaries, told the panel that the boundaries represent the worst example of gerrymandering in modern history and punish Democrats and their supporters by diluting their voting strength. “Their right to vote is fundamental,” Hebert said during closing arguments. “It’s our voice in the government. It’s the only voice many of us have. It’s not right to target people and harm them because of their voting history. What did they do? They had the nerve to participate in the political process and go to the polls.”

Wisconsin: At vanguard of national legal fight on voter ID | Wisconsin State Journal

The legal fight over Wisconsin’s photo ID voting requirement put it back in the political spotlight this month, with the state a key front in the national battle surrounding such laws. Here and elsewhere, the courtroom struggle stems from photo ID and other voting changes enacted by Republican legislators and governors in the last five years. Many, including Wisconsin’s, take effect in a presidential election for the first time this November. A nine-day court trial of the Wisconsin legal challenge concluded Thursday in federal court in Madison, and a forthcoming ruling in that case could decide how voter ID affects the state’s 2016 general election. The outcome of that and another lawsuit also could influence the national back-and-forth on voter ID. For now, how those challenges will be resolved is a big unknown for an election with high stakes.

India: Election Commission cancels polls to two Tamil Nadu seats | Free Press Journal

In an unprecedented move in the history of Tamil Nadu”s electoral politics, the Election Commission of India (EC) on Saturday decided to rescind its poll notification in two constituencies following conclusive evidence of bribery of voters on a large scale. Quite shockingly, the EC has noted that bribing of voters continued in one of the constituencies after the postponement of polls in Aravakurichi constituency in Karur district and Thanjavur constituency, both in central Tamil Nadu, on charges of irregularities. Tamil Nadu went to polls on May 16 but polling in the two constituencies was deferred at the eleventh hour – first in Aravakurichi and then in Thanjavur. Originally the deferred polls were to take place on May 23 but the EC withheld its decision after the PMK and BJP”s candidates moved the Madras High Court seeking postponing of the elections.

Serbia: Opposition Takes to Streets Claiming Election Fraud | Balkan Insight

Serbian opposition groups alleged electoral fraud at weekend polls after the latest results showed a far-right DSS-Dveri coalition has been excluded from parliament. The leaders of the coalition, supported by other three opposition parties, called a protest for Saturday to be held in front of the Electoral Commission in Belgrade. With 99.45 percent of ballots counted, Prime Minister Aleksandar Vucic’s Serbian Progressive Party, SNS, has won nearly 50 percent of the vote, giving it at least 138 seats in the 250-member parliament.

United Kingdom: Council withdraws EU referendum leaflet over ‘unfair’ remain graphic | The Guardian

An EU referendum voting guidance leaflet has been withdrawn after complaints it could influence voters’ decisions on 23 June. Graphic instructions on how to vote included in material sent out with postal votes in Bristol showed a pen hovering over the remain box. It was attacked as unfair by Brexit campaigners – who said similar pictures had been reported in other parts of the country as ballot papers begin to arrive. The Electoral Commission said while the graphic was unlikely to sway voters, it “clearly shouldn’t have been used” in that form. A spokeswoman said the commission had acted to ensure the leaflet was replaced by Bristol city council and was investigating whether the issue was more widespread.

The Voting News Weekly: The Voting Rights Weekly for May 23-29 2016

blood_260The Washington Post examined the challenges many Americans face in obtaining the specific forms of identification required for voting in some states. The Economist notes that while “today’s voting-rights disputes are less clear-cut than those of the civil-rights era, but they are inflammatory all the same.” While giving him two more weeks to comply, a federal judge let Kansas Secretary of State Kris Kobach know that she would brook no further delays in carrying out her order to restore 18,000 Kansas residents to the voter rolls. Hillary Clinton remains the winner of Kentucky’s Democratic presidential primary after a recanvass of votes requested by her opponent Sen. Bernie Sanders. Baltimore’s elections board recertified the results of the April primary election Wednesday after an unusual intervention by state officials. A federal judge struck down an Ohio state law that eliminated “Golden Week,” several days at the beginning of the state’s early voting period when Ohio voters could both register to vote and cast a ballot. The Supreme Court left in place a court-imposed congressional redistricting map in Virginia, dismissing a challenge from three Republican congressmen. Witnesses in the federal court challenge to Wisconsin’s voter id requirement provided insight into real motives for enactment of the law. The failed far-right contender in Austria’s presidential election has dismissed claims by some of his supporters alleging fraud while the UK high court upheld an earlier ruling that Britons who have lived abroad for more than 15 years will not be allowed to vote in the EU referendum.

National: Getting a photo ID so you can vote is easy. Unless you’re poor, black, Latino or elderly. | The Washington Post

In his wallet, Anthony Settles carries an expired Texas identification card, his Social Security card and an old student ID from the University of Houston, where he studied math and physics decades ago. What he does not have is the one thing that he needs to vote this presidential election: a current Texas photo ID. For Settles to get one of those, his name has to match his birth certificate — and it doesn’t. In 1964, when he was 14, his mother married and changed his last name. After Texas passed a new voter-ID law, officials told Settles he had to show them his name-change certificate from 1964 to qualify for a new identification card to vote. So with the help of several lawyers, Settles tried to find it, searching records in courthouses in the D.C. area, where he grew up. But they could not find it. To obtain a new document changing his name to the one he has used for 51 years, Settles has to go to court, a process that would cost him more than $250 — more than he is willing to pay. “It has been a bureaucratic nightmare,” said Settles, 65, a retired engineer. “The intent of this law is to suppress the vote. I feel like I am not wanted in this state.”

Editorials: The fire next time | The Economist

The 45-mile drive from Union Springs, seat of Bullock County, Alabama, to Montgomery, the state capital, might not seem very arduous. But for some locals, the distance itself is not the main obstacle. Going to Montgomery, as some now must to get a driver’s licence, means the best part of a day off work for two people, the test-sitter and his chauffeur (there is no public transport). That is a stretch for employees in inflexible, minimum-wage jobs—and there are lots of them in Union Springs, a tidy town in which the missing letters on the shuttered department store’s façade betray a quiet decline, surrounded by the sort of spacious but dilapidated poverty characteristic of Alabama’s Black Belt. To some, this trek is not just an inconvenience but a scandal. The state’s voters must now show one of several eligible photo-IDs to cast a ballot, of which driving licences are the most common kind. Last year, supposedly to save money, the issuing office in Union Springs, formerly open for a day each week, was closed, along with others in mostly black, Democratic-leaning counties. After an outcry, the service was reinstated for a day per month; at other times, applicants head to Montgomery. For James Poe, a funeral-home director and head of the NAACP in Bullock County, the combination of a new voter-ID law and reduced hours is “insanity”. Such impediments may not be as flagrant as when, as a young man in Union Springs, he had to interpret the constitution in order to vote, but, he thinks, they are obnoxious all the same.

Kansas: Judge Rejects Kobach’s Request For Delay In Voting Rights Case | KCUR

While giving him two more weeks to comply, a federal judge let Kansas Secretary of State Kris Kobach know that she would brook no further delays in carrying out her order to restore 18,000 Kansas residents to the voter rolls. In a harshly worded order Wednesday, U.S. District Judge Julie Robinson rejected Kobach’s claim that compliance with the court’s May 17 order would cause voter confusion and lead to “irreparable harm.” Kobach did not return a call seeking comment. Robinson’s latest ruling came in a lawsuit brought by the American Civil Liberties Union and the League of Women Voters of Kansas on behalf of several individual plaintiffs challenging Kansas’ policy of requiring people who register to vote at DMV offices to provide proof of citizenship.

Kentucky: Recanvass of Democratic Primary votes confirms Hillary Clinton wins Kentucky | Louisville Courier-Journal

Hillary Clinton remains the winner of Kentucky’s Democratic presidential primary after Thursday’s recanvass of votes. “The recanvass results that we received today are the same as those certified totals that my office received on Friday. The difference between Hillary Clinton and Sen. (Bernie) Sanders: 1,911 votes,” Kentucky Secretary of State Alison Lundergan Grimes announced Thursday afternoon at the State Capitol. Unofficial vote totals reported by the state Board of Elections on the night of the May 17 primary gave Clinton a 1,924-vote lead over Sanders, a U.S. senator from Vermont. But those totals changed slightly on Friday – reducing the margin to 1,911 votes – after each county reported its certified results to Grimes’ office later in the week. Grimes said the recanvass resulted in no change from those certified results she had in hand as of Friday: 212,534 votes for Clinton, and 210,623 votes for Sanders. “The recanvass vote totals, which were submitted to my office today will become the official vote totals that the State Board of Elections will certify on May 31,” Grimes said.

Maryland: Baltimore to begin final review of election results | Baltimore Sun

Baltimore’s elections board recertified the results of the April primary election Wednesday after an unusual intervention by state officials. The updated vote totals didn’t change the outcome of any race. Any candidate who wants a recount now has three days to make a request. Anyone who wants to challenge the outcome of the race in court has seven days to file papers. State officials ordered Baltimore’s election results decertified this month after city officials said they found 80 provisional ballots that had not been analyzed. The state review, which lasted more than a week, turned up other problems: Officials concluded that roughly 1,650 ballots were not handled properly. The last step before finalizing the figures was analyzing 555 uncounted provisional ballots that state officials said had not been analyzed or counted. Officials had previously said they thought 465 provisional ballots had been overlooked.

Ohio: Federal judge blocks Ohio law that eliminated ‘Golden Week’ voting | Cleveland Plain Dealer

A federal judge on Tuesday struck down a state law that eliminated “Golden Week,” several days when Ohio voters could both register to vote and cast a ballot. The 2014 law violates both the 14th Amendment of the U.S. Constitution and Section 2 of the Voting Rights Act, U.S. District Court Judge Michael Watson wrote in his opinion siding with Democrats who challenged the law. The state will appeal the ruling, a state attorney general spokesman said. If the ruling stands, Ohio voters will have 35 days to cast a ballot this November instead of 28 and will be able to register to vote and cast a ballot at the same time. In 2014, the American Civil Liberties Union challenged the law on behalf of the Ohio chapters of the National Association for the Advancement of Colored People and League of Women Voters and several African-American churches. A federal district court judge struck down the law, but the state was granted a stay. Ohio Secretary of State Jon Husted and Statehouse Republicans argued that Ohio provides 28 days of absentee voting by mail and in-person, making it one of the most expansive voting systems in the country.

Virginia: Justices Let Court-Imposed Redistricting Stand in Virginia | The New York Times

The Supreme Court on Monday left in place a court-imposed congressional redistricting map in Virginia, dismissing a challenge from three Republican congressmen. The court’s brief, unanimous decision said the members of Congress had not shown that they had suffered the sort of direct and concrete injury that gave them standing to sue. The court, therefore, did not rule on the larger issues in the case, Wittman v. Personhuballah, No. 14-1504, which concerned the role race may play in drawing legislative maps. “We cannot decide the merits of this case unless the intervenor members of Congress challenging the district court’s racial-gerrymandering decision have standing,” Justice Stephen G. Breyer wrote for the court. “We conclude that the intervenors now lack standing. We must therefore dismiss the appeal for lack of jurisdiction.”

Wisconsin: Testimony in Voter ID lawsuit offers insight into real motives for law | Milwaukee Journal Sentinel

It may not be dubbed the Trial of the Century but whatever ruling comes out of the lawsuit against Wisconsin’s Voter ID law may well have an impact that lasts as long. Testimony from a wide range of experts, county clerks and other relevant parties is being heard by U.S. District Judge James Peterson. The suit was brought by One Wisconsin Now and Citizen Action of Wisconsin Education Fund, with the argument that Republican officials passed the law and other related rules as an intentional means of disenfranchising minority and Democratic voters. More than the witnesses called by the plaintiffs, it is in the testimony of those people called to defend the new rules that we get the most insight into the massive rift of understanding between the sides. It also has highlighted the very disparities they’ve set out to defend. A political scientist testifying on behalf of the state claimed that the state’s free ID program could “potentially” mitigate the negative effects of the law, specifically on black voters, who are more than five times as likely as white voters to go through the process to receive a free ID in order to vote. Why make people jump through the extra hoop in the first place, though? There still are no documented cases of voter fraud. This “solution” in search of a problem has only disenfranchised otherwise eligible voters, as evidenced by several of the people who testified about the problems and barriers they faced in trying to receive even those free IDs.

Austria: Far-right presidential candidate dismisses voter fraud claims | The Guardian

The failed far-right contender in Austria’s presidential election has urged his supporters to accept the result despite some in his party alleging fraud. “We should all pull together,” Norbert Hofer said at a Freedom party (FPÖ) meeting in Vienna on Tuesday. “There are no signs of electoral fraud.” In the immediate aftermath of the vote, FPÖ leaders and activists had cried foul over the narrow result, with the Green-endorsed independent candidate Alexander Van der Bellen winning by only about 31,000 votes. Even before it emerged that Hofer had lost out on the presidency due to Van der Bellen’s strong performance in the postal vote, the party’s secretary, Herbert Kickl, had said that absentee votes had in the past shown up “inconsistencies”. “Accomplices of the current political system could potentially use the opportunity to adjust the result in favour of the system’s representative, Alexander Van der Bellen,” Kickl said.

United Kingdom: British emigrants lose supreme court EU referendum vote bid | The Guardian

Britons who have lived abroad for more than 15 years will not be allowed to vote in the EU referendum, the supreme court has ruled. The highest court in the country upheld earlier rulings of the high court and court of appeal against Harry Shindler and Jacquelyn MacLennan, who were challenging the law. The ruling confirms the decision that the UK’s voting regulations do not unlawfully interfere with the right of freedom of movement within the European Union and that the government is entitled to set an arbitrary time limit on residence. Delivering the ruling, Lady Hale, deputy president of the supreme court, said: “The question is not whether this particular voting exclusion is justifiable as a proportionate means of pursuing a legitimate aim. The question is whether EU law applies.”

National: House bill would allow felons to regain voting rights | Sun Sentinel

Calling it “the civil rights cause of the 21st Century,” U.S. Rep. Alan Grayson, D-Orlando, has sponsored a bill that would restore voting rights to more than a million Floridians. The bill, dubbed the No One Can Take Away Your Right to Vote Act, would guarantee that ex-convicts have the right to vote after they leave prison, though it excludes anyone convicted of murder, manslaughter or a sex crime. Florida, which is one of only three states in which all felons lose the right to vote forever unless it’s restored by the state, has more than 1.5 million citizens unable to vote. That’s about ten percent of the state’s voting age population.

California: Hearing for California primary lawsuit set for after voting | Associated Press

A federal judge has set an Aug. 18 hearing date in a lawsuit filed by a Bernie Sanders supporter seeking to extend California’s voter registration deadline ahead of the primary election, meaning the plaintiffs likely won’t get a hearing before the state’s June 7 primary. Attorney William Simpich argued in the filing that the process for unaffiliated voters to get a presidential primary ballot – particularly those seeking to cast ballots in the Democratic primary contest between Vermont Sen. Bernie Sanders and former Secretary of State Hillary Clinton – was too confusing and would leave many voters disenfranchised. He said at least two counties failed to notify some voters of their right to request a ballot to vote in the Democratic, Libertarian or American Independent Party contests.

Connecticut: Motor Voter Dispute Generates More Heat At Capitol | Hartford Courant

Republican legislators Wednesday amplified their claims that Secretary of the State Denise Merrill bypassed the General Assembly by entering an agreement with the Department of Motor Vehicles for a “streamlined motor voter system” to automatically register citizens to vote when they go to the DMV to obtain or renew a driver’s license. At a press conference in the Legislative Office Building, Senate GOP Leader Len Fasano of North Haven said that after Merrill failed to get the legislature this year to approve a bill to establish the automatic motor voter registration system, she “went behind the backs” of lawmakers to negotiate a “memorandum of understanding” to implement the new system administratively. Merrill and the DMV defended the agreement later Wednesday. Under the new “automatic motor voter system,” DMV customers would be registered to vote starting in 2018 unless they decline by choosing to opt out. Under the current motor voter program that’s existed for two decades, DMV customers are registered to vote only if they choose that option.

Georgia: Voting glitch was found in February, but no one told Fulton County | Atlanta Journal Constitution

Fulton County officials got caught by surprise when a data glitch caused some voters to cast the wrong ballot in Tuesday’s primary. Turns out, Georgia officials and state Democrats knew of the problem since February but no one told the county until Election Day. According to emails shared with The Atlanta Journal-Constitution, officials with the Democratic Party of Georgia emailed the Georgia Secretary of State’s Office on Feb. 17 after noticing voter maps for House District 59 and House District 60 — seats held by two Democrats on the south end of Atlanta that stretch into East Point — were coded incorrectly, putting some voters in the wrong district. That means some voters may have received the wrong ballots and voted in the wrong race. A state staffer at the time replied in an attempt to confirm which county the districts were in. No changes were made, and no one contacted Fulton County. Georgia Democrats again reached out to the state about the problem last week after noticing it had not been corrected. But state officials did not say anything to Fulton officials until Tuesday afternoon, after voting was well underway.

Montana: Judge issues stay reinstating campaign contribution limits from political parties | Associated Press

A federal judge on Thursday put back into place limits on what Montana’s political parties can give to campaigns. State attorneys on Tuesday argued that U.S. District Court Judge Charles Lovell should issue a stay over part of his own order from last week that removed contribution limits for the political party committees. In his order May 17, Lovell said the contribution limits were too low and unconstitutional, but left what happened next up to Attorney General Tim Fox. Commissioner of Political Practices Jonathan Motl interpreted Lovell’s order as ending limits set by a 1994 initiative and said he was required to reinstate the limits that were in place before then, adjusted for inflation. That left the limits for contributions from individuals and political action committees significantly higher, especially for PACs.

Ohio: State appeals U.S. court decision in favor of early voting | Reuters

The state of Ohio filed a federal court appeal on Thursday seeking to restore a Republican-backed limit on early voting and accelerated voter-registration measures that were seen by civil rights groups as boosting minority turnout. U.S. District Judge Michael Watson in Columbus ruled on Tuesday that Ohio violated voters’ rights by reducing the period that ballots could be cast before an election to four weeks from five weeks. Watson’s decision also struck down Ohio’s elimination of a seven-day window during which residents could both register to vote and cast their ballots all in the same week – a period known as “Golden Week.”

Editorials: The United States has a moral obligation to give Puerto Rico the right to vote | Noah Berlatzsky/Quartz

Voting rights has become an increasingly partisan issue. In Wisconsin, new voter ID laws led to brutal lines at the polls in urban areas—a development designed, even according to Republicans themselves, to suppress Democratic turnout. In Virginia at the end of April, governor Terry McAuliffe re-enfranchised all felons who had finished parole. In theory, the move returned the vote to 200,000 people. This was a refutation of a policy originally designed to explicitly deny black people the vote. It was also, potentially, a way to give more votes to more minority and poor voters, and tip a narrowly balanced purple state more Democratic in the US presidential election. The focus on voter IDs and felon disenfranchisement—while important—has inadvertently obscured other voting rights issues. Every year, with little comment, the United States denies millions of people representation in the District of Columbia, Puerto Rico, Guam, and other territories. Washington, DC, has a population of over 650,000 people. That makes it larger than the states of Vermont or Wyoming, and yet it has no voting representatives in either the Senate or the House of Representatives. Puerto Rico has a population of around 3.5 million people, which makes it more populous than states like Nevada, Iowa, and Arkansas. But not only do Puerto Ricans lack Congressional representation, they also cannot vote in presidential elections (unlike residents of DC, who are entitled to three votes in the Electoral College).