National: The $5 billion presidential campaign? | The Hill

The 2016 presidential election could cost as much as $5 billion, according to top fundraisers and bundlers who are already predicting it will more than double the 2012 campaign’s price tag. Behind-the-scenes jockeying to raise big bucks from bundlers connected to super-PACs and third-party groups is well underway, even with no top-tier candidates officially in the race. Potential candidates with proven fundraising prowess, such as 2012 GOP presidential nominee Mitt Romney, former Florida Gov. Jeb Bush and New Jersey Gov. Chris Christie, are throwing political elbows at each other to secure donors’ money at an early stage in the race. And then there’s Hillary Clinton. In private conversations, allies to the former secretary of State are predicting that the campaign totals on their end alone might surpass $1.5 billion and go as high as $2 billion.

National: Backers of voting rights bill try a new strategy | USA Today

President Barack Obama named voting rights protections as a priority in his State of the Union address Tuesday, but legislation that would restore a key provision of the Voting Rights Act faces tough challenges this Congress. That legislation, called the Voting Rights Amendment Act, would resurrect the 1965 law’s “pre-clearance” provision requiring states with a history of voting discrimination to get federal approval before making any changes in their elections procedures. The Supreme Court ruled in 2013 — in Shelby County vs. Holder — that the formula used to determine which states were subject to pre-clearance was invalid, effectively nullifying the provision itself.

National: Supreme Court considers whether judges can directly ask for campaign donations | The Washington Post

The Supreme Court’s latest test of whether campaign contribution restrictions violate free-speech rights split the justices into familiar liberal and conservative camps. And skeptical questions from Justice Anthony M. Kennedy, who probably holds the pivotal vote, did not bode well for Florida and 29 other states that forbid judicial candidates from directly soliciting campaign contributions. Such restrictions are needed, the states contend, because judges are not like other politicians. The public expects judges to be impartial, the states argue, and that perception is compromised when candidates directly ask for money. But Barry Richard, representing the Florida Bar Association, received sharp questioning from justices about whether Florida’s regulations are too porous to accomplish those goals. While candidates may not directly solicit contributions, they may organize a committee to ask for money, direct the committee toward potential contributors, see who gave and even send thank-you notes.

National: Hoyer presses GOP on voting rights | The Hill

Saying voter discrimination “has not gone away,” House Minority Whip Steny Hoyer called on GOP leaders Tuesday to update the 1965 Voting Rights Act (VRA). The Maryland Democrat said the Supreme Court’s 2013 decision eliminating central provisions of the law “clearly undermined the protections of the right to vote in this country” and urged Republicans to replace those provisions this year. “The majority of the court was simply wrong,” Hoyer said during a press briefing in the Capitol. “Something that had helped solve the problem, and made sure it didn’t reoccur, was jettisoned.” Republican leaders have shown little interest in the issue. And last week, Rep. Bob Goodlatte (R-Va.), head of the House Judiciary Committee, said congressional reforms are unnecessary because “substantial” parts of the VRA remain intact. “To this point, we have not seen a process forward that is necessary because we believe the Voting Rights Act provided substantial protection in this area,” he said Wednesday during a breakfast in Washington sponsored by The Christian Science Monitor.

National: Poverty affects not only who you vote for, but if you vote | Deseret News National

Lower income voters may not be as large of a Democratic voting bloc as once thought, but more importantly they may not vote much at all, according to a new Pew Research Center survey. “Because of their greater uncertainty about candidate preference and their lower propensity to vote, the least financially secure were poorly represented at the ballot box, with just 20 percent of this group predicted to turn out,” wrote Pew. The Pew study states that 80 percent of the lower-income demographic are not considered likely voters. The survey also says 42 percent prefer Democrat candidates, 41 percent are undecided and 17 percent prefer Republican candidates. Last year the Washington Post‘s Dylan Matthews poked holes in a theory supported by conservative radio show host Rush Limbaugh and activist Gary Bauer that lower-income people are a formidable voting bloc.

National: Supreme Court reviews campaign finance rules in judicial races | CBS News

Voters in the Tampa area didn’t think much of Lanell Williams-Yulee’s campaign for county judge in 2010, and the group that regulates Florida’s lawyers didn’t much like her campaign tactics. Along with being drubbed in the election, she was hauled before the Florida Bar for violating its ban on personally soliciting campaign contributions by sending a “Dear Friend” letter asking for money. Five years after the Supreme Court freed corporations and labor unions to spend freely in federal elections, the justices will hear arguments Tuesday in Williams-Yulee’s challenge to the Florida rules, which she says violate her right to speak freely. The state bar, defending the ban on personal fundraising, says it’s more important to preserve public confidence in an impartial judiciary. In 39 states, state and local judges get their jobs by being elected. Florida is among the 30 of those that prohibit candidates from personally asking for campaign contributions. If Williams-Yulee prevails, it could free judicial candidates in those states to make personal appeals for campaign cash. In the federal judicial system, including the Supreme Court, judges are appointed to life terms and must be confirmed by the Senate.

National: Argument preview: Judges, politics, and money | SCOTUSblog

Since the 1830s, Americans have been claiming a role for themselves as voters in the naming of judges for their courts.  The obvious lesson, early on and now, is that citizens trust themselves to handle that task fairly and trust that the judges who are chosen that way will do the job impartially. In modern times, some uncertainty has crept in about those assumptions, especially as the cost of elections has escalated, including the price of running for a judgeship.  Former Justice Sandra Day O’Connor has made a new career in retirement of leading a public charge against judicial elections. If campaign money is a threat to judicial impartiality, but the First Amendment is understood to treat political money as speech, how far can states go to regulate it?  The Supreme Court is no stranger to the abiding controversy over money in politics, and takes that up again this week in a Florida judicial election case. Judges are still elected in thirty-nine states, and in all but nine of those states, there is a law or an ethics code provision that bans a judicial candidate from personally asking for campaign donations.  That, it appears, is more preferable as a remedy than getting rid of judicial elections altogether, or relying on judges to disqualify themselves in specific cases. A civic-minded Tampa lawyer, who decided in September 2009 that “the time has come for me to seek elected office,” is at the center of a case testing the constitutionality of that kind of ban.  Lanell Williams-Yulee sent out a mass mailing saying that she was running for county judge, declaring: “I want to bring fresh ideas and positive solutions to the Judicial bench.”  Her plea for money was modest indeed, by modern campaign standards: “$25, $50, $100, $250, or $500.”

National: Voting Rights Debate Reignites Heading into Martin Luther King Holiday | NBC

A day after a top Republican seemed to dismiss the need to restore a critical part of the Voting Rights Act, lawmakers Thursday told NBC News they would reintroduce bipartisan voting rights legislation next week, in what the Congressional Black Caucus says will be a massive effort to aggressively defend voting rights. House Judiciary Committee Chairman, Rep. Bob Goodlatte, R-Va., suggested other sections of the Voting Rights Act are already strong enough. “To this point, we have not seen a process forward that is necessary to protect people because we think the Voting Rights Act is providing substantial protection in this area right now,” Goodlatte said while speaking to reporters at the Christian Science Monitor breakfast. Calling Goodlatte’s statement a “bombshell,” the Chair of the Congressional Black Caucus, Rep. G. K. Butterfield, D-N.C., warned “If Bob Goodlatte is speaking for the Republican Conference, this is a very serious development because we are going to push back in a very significant way against the unwillingness of the Republicans to take up extending section five protections.”

National: Five years after Citizens United, new report finds wealthy have unprecedented influence | Scripps

It’s been five years since the Supreme Court lifted restrictions on how much money corporations and unions could spend putting their favorite candidates in office. The result, according to eight of the nation’s largest government watchdog groups, is that regular Americans are losing their voice in democracy while a “tiny number” of wealthy individuals have gained record influence. In the 2010 Citizens United vs. Federal Election Commission case, the Court ruled that corporations and unions were entitled to same first amendment rights to free speech as private citizens as long as they are working independent of the campaigns. The Washington D.C.-based watchdog Public Citizen suggests in a new report, however, that the very groups claiming to be independent in the wake of the Court’s decision are often closely aligned with a single candidate.

National: Congressional Black Caucus, Democrats rip lack of voting right protections in Republican agenda | The Hill

The head of the Congressional Black Caucus (CBC) is teeing off on Republicans over the absence of voting right protections in the GOP’s new congressional agenda. Rep. G. K. Butterfield (D-N.C.) said he’s “deeply troubled” by House Judiciary Chairman Bob Goodlatte’s (R-Va.) recent comments that Republicans have no intention of replacing central provisions of the 1965 Voting Rights Act (VRA) shot down by the Supreme Court in 2013. “If this is indeed the position of the entire Republican Conference, then they have clearly drawn a line in the sand — one in which they are on the wrong side of,” Butterfield said in a statement. Speaking to reporters Wednesday, Goodlatte said congressional action is simply not necessary to improve the VRA because the parts of the law remaining after the Supreme Court ruling are “substantial.”

National: Top GOPer confirms Congress won’t strengthen Voting Rights Act | MSNBC

A top Republican has all but confirmed that Congress won’t move forward with legislation to strengthen the Voting Rights Act (VRA), which was badly weakened by the Supreme Court in 2013. Rep. Bob Goodlatte, who chairs the House Judiciary committee, said Wednesday morning that the landmark civil rights legislation is still robust enough to stop racial discrimination in voting. “There are still very, very strong protections in the Voting Rights Act in the area that the Supreme Court ruled on,” Goodlatte said at a breakfast event with reporters, hosted by the Christian Science Monitor. “To this point, we have not seen a process forward that is necessary to protect people because we think the Voting Rights Act is providing substantial protection in this area right now.” He added, according to an audio recording obtained by msnbc: “We’ll continue to examine this, we’ll continue to listen to the concerns of individuals, and we’ll certainly look at any instances of discrimination in people’s access to the ballot box, because it is a very, very important principle.”

National: New IRS Rules on Dark Money Won’t Be Ready By 2016 | Pacific Standard

The Internal Revenue Service says it won’t come out with new proposed rules for so-called dark money groups until late spring at the earliest, increasing the likelihood that no changes will take effect before the 2016 elections. These groups—social welfare non-profits that can engage in politics, but do not have to disclose their donors—have become a major force in elections, pouring at least $257 million into the 2012 elections. The Wesleyan Media Project estimates that dark money paid for almost half the TV ads aired in the 2014 Senate races. The IRS originally issued a draft version of the rules for dark money groups more than a year ago, but withdrew them for revisions after receiving intense criticism from both ends of the political spectrum. It’s unknown how aggressive the IRS’ new proposal will be in attempting to rein in political activity by social welfare non-profits. Some observers expect the agency to set a hard limit on how much of groups’ spending can be devoted to politics, perhaps 40 percent or less.

National: 5 Years After ‘Citizens United,’ SuperPACs Continue To Grow | NPR

Prospective Republican presidential candidate Jeb Bush is moving to get his share via a new political committee. The way he did it could blaze a new trail for candidates seeking out million-dollar donors. Bush’s action comes just before the fifth anniversary, next Wednesday, of Citizens United, the 2010 Supreme Court ruling that restructured the campaign finance landscape. In the five years since, there’s been an explosion of political money. The organization around Bush, a former Florida governor, has created a superPAC, a species of political committee that wasn’t possible before Citizens United. It can take contributions of any amount. Confusingly, the Bush organization also set up another political action committee at the same time, an old-fashioned PAC operating with contribution limits. The PACs have the same name, Right To Rise, similar logos and the same lawyer.

National: How campaigns are courting 16-year-olds | Politico

Coming soon to a battleground state near you: White House campaigns combining census reports with Instagram and Twitter posts to target teenagers who aren’t yet 18 but will be by Election Day 2016. It’s an aggressive strategy with an obvious reward. More than eight million people will become legal adults eligible to vote for the first time by the next general election. Campaigns are eager to find ways to get through to these 16- and 17-year-olds who are still minors and, in most cases, more likely to be concerned with making it to class on time than who should be elected president. “It’s got to be the right candidate with the right message to excite and motivate that age demographic, with so many distractions in their life, to register, and then turn out,” said Vincent Harris, digital director for Rand Paul’s political operation.

National: Judge candidates’ free-speech rights at issue before the Supreme Court | The Washington Post

Tampa lawyer Lanell Williams-Yulee’s 2010 campaign for Hillsborough County judge was in many ways one she might like to forget. Not only did she lose in a landslide to a longtime incumbent, she was rebuked by the Florida Bar and fined a little more than $1,800. Voters failed to find Williams-Yulee’s candidacy compelling, but the Supreme Court has taken a greater interest. Later this month, the justices will consider whether the action that got the lawyer into trouble — violating Florida’s restriction against directly soliciting contributions to judge campaigns — is instead an unreasonable constraint on Williams-Yulee’s right to free speech. Florida is among the vast majority of states that require the election of at least some judges. (Federal judges, by contrast, are nominated by the president and confirmed by the Senate to lifetime appointments.) But 30 states prohibit judicial candidates from directly asking for campaign contributions, in most cases leaving that work to a committee the candidate establishes.

National: The Income Gap at the Polls | Politico

In 1986, the economist John Kenneth Galbraith declared, “If everybody in this country voted, the Democrats would be in for the next 100 years.” But for decades, the consensus among scholars and journalists has been the opposite. In their seminal 1980 study on the question, using data from 1972, political scientists Raymond Wolfinger and Steven Rosenstone argued that “voters are virtually a carbon copy of the citizen population.” In 1999, Wolfinger and his colleague Benjamin Highton again came to the same conclusion: “Outcomes would not change if everyone voted.” Their argument rested upon the fact that polling data did not show large differences in opinions on most issues between those who voted and those who did not. However, a growing literature both within the United States and internationally suggests that, in fact, policy would change rather dramatically if everyone voted. Does this mean that Galbraith was right all along? Not exactly. The reason for the recent shift in the findings is not that the early studies were wrong, but that the preferences of voters and nonvoters are becoming increasingly divergent.

National: How Facebook Influences Voter Participation | Digital Journal

2015 will be an interesting year for politics. Whether you love it or hate it, social media is completely changing the landscape of voter participation, one Facebook post at a time. The social media company is no stranger to watching voting and post activity analytics, keeping track of trends with some intriguing and perhaps unsettling blog updates regarding national voter turnout on Election Day. However, one of the bigger controversies is the question of how our newsfeeds might influence our decisions. According to The Verge, “Facebook had been running another newsfeed experiment, giving news stories an algorithmic boost for certain users to see if it heightened civic engagement, as measured by a questionnaire.” Do these algorithms guarantee that Facebook viewers gain exposure to unbiased items in their news feeds? If not, then it’s certainly possible that our newsfeeds could subtly influence a user’s affinity for specific candidates or party alliances.

National: New IRS Rules on Dark Money Likely Won’t Be Ready Before 2016 Election | ProPublica

The Internal Revenue Service says it won’t come out with new proposed rules for so-called dark money groups until late spring at the earliest, increasing the likelihood that no changes will take effect before the 2016 elections. These groups — social welfare nonprofits that can engage in politics, but do not have to disclose their donors — have become a major force in elections, pouring at least $257 million into the 2012 elections. The Wesleyan Media Project estimates that dark money paid for almost half the TV ads aired in the 2014 Senate races. The IRS originally issued a draft version of the rules for dark money groups more than a year ago, but withdrew them for revisions after receiving intense criticism from both ends of the political spectrum. Some advocates of campaign finance reform have touted tighter IRS controls as the best shot of reining in the influence of such groups ahead of the 2016 presidential race.

National: Double Dip: How Rand Paul Can Legally Tap His Biggest Donors Twice | National Journal

Sen. Rand Paul could have a financial edge over many of his prospective presidential rivals in 2016 due to a quirk in timing and election law that lets him to tap his biggest donors for campaign cash twice. Paul has said he plans to seek Senate reelection and, if he runs, the Republican presidential nomination simultaneously. And because he would be campaigning for two federal offices, he would be eligible to have two open federal campaign committees at the same time. Thus, his largest donors could give $2,600 to his presidential primary campaign and another $2,600 to his Senate account for the primary. While federal rules do limit how he could spend the money, veteran election lawyers say diligent accounting could allow for legal cost-sharing between the two committees, saving Paul’s presidential bid precious dollars and letting him collect bigger checks from his biggest contributors. “The two big advantages you can think of are the ability to double-dip from donors and the ability to allocate your costs between two different entities,” said Neil Reiff, a Democratic campaign lawyer.

National: Fighting red maps in purple states | Politico

Based on the big elections in Virginia in recent years, the Old Dominion is turning reliably blue: victories by Barack Obama in 2008 and 2012, two Senate wins by Democrats in two years, and Terry McAuliffe’s triumph in between. So how is it that Republicans have a stranglehold on the state’s congressional delegation, holding eight seats to Democrats’ three? That question is at the heart of a legal battle over whether Republicans have improperly leveraged their power over the redistricting process. The outcome could have far-reaching implications because the contours of congressional districts drawn by Republican-controlled legislatures are seen as a driving reason why Democrats may be locked in the House minority until at least after the next census in 2020. In Virginia, Democrats are hoping to redraw the lines to make some GOP districts more competitive after a panel of federal judges ruled recently that the Republican-led Legislature’s decision to pack African-American voters into the 3rd Congressional District, which is represented by Democratic Rep. Bobby Scott, was motivated purely by race — a violation of the 14th Amendment. Other battleground states such as North Carolina and Florida also have redistricting battles pending.

National: Court won’t reconsider Arizona, Kansas citizenship lawsuit | Associated Press

A federal appeals court has refused to reconsider a decision allowing residents of Kansas and Arizona to register to vote using a federal form without providing proof of their U.S. citizenship. A three-judge panel of the 10th U.S. Circuit Court of Appeals in Denver issued a one-sentence ruling denying a request from the two states. The appeals court ruled in November that Kansas and Arizona cannot demand help from federal officials in enforcing state laws requiring new voters to submit a birth certificate or other papers documenting U.S. citizenship.

National: States seek rehearing of voter citizenship lawsuit | Lawrence Journal-World

Kansas and Arizona have asked a federal appeals court panel to revisit its decision allowing residents of those states to register to vote using a federal form without having to provide proof of citizenship. The states submitted a petition late Monday asking the 10th Circuit Court of Appeals panel to rehear the case, saying they believe the court overlooked certain legal issues when it ruled against them in November. The appeals court ruled that Kansas and Arizona cannot demand federal election officials help them enforce their state laws requiring new voters to submit a birth certificate, passport or other papers documenting U.S. citizenship. The panel overturned a March ruling by U.S. District Court Judge Eric Melgren that required the U.S. Election Assistance Commission to tailor its federal voter registration form for those states to require those proof-of-citizenship documents.

National: Discord Brews Over SEC Campaign-Finance Rule | Wall Street Journal

A Securities and Exchange Commission rule designed to limit conflicts of interest in state contracting is becoming less effective amid the rise of super PACs and should be broadened, groups that track campaign finance say. The SEC’s so-called pay-to-play rule, which applies to state officials including governors, could become a prominent factor in the 2016 presidential election given that four or more Republican governors who would be in office during the campaign have said they may run or are thought to be considering a candidacy. The rule effectively prohibits certain employees of financial-services companies that do—or might do—business with state agencies from contributing to the officials who oversee those agencies. The rule, adopted in 2010, was intended to prevent political contributions from influencing state contracting decisions.

National: Inquiry Into I.R.S. Lapses Shows No Links to White House | New York Times

An 18-month congressional investigation into the Internal Revenue Service’s mistreatment of conservative political groups seeking tax exemptions failed to show coordination between agency officials and political operatives in the White House, according to a report released on Tuesday. The I.R.S. has admitted that before the 2012 election it inappropriately delayed approval of tax exemption applications by groups affiliated with the Tea Party movement, but the I.R.S. and its parent agency, the Treasury Department, have said that the errors were not motivated by partisanship. Republican lawmakers, dismissing the Obama administration’s denials, have suggested that the delays were not only politically motivated but also orchestrated by the White House. Some of the most strident comments have come from Representative Darrell Issa, Republican of California and the chairman of the House Oversight Committee, which has issued subpoenas to compel testimony from administration officials and held a series of tumultuous hearings on the I.R.S. scandal.

National: Lengthy vacancy ends for election commissioners | USA Today

The last-minute flurry of action by the Senate Tuesday included filling three of four seats on the federal Election Assistance Commission, which had languished without commissioners since 2010 — or two election cycles, to put it in Washington terms. The Senate confirmed Thomas Hicks, a former election law counsel on Capitol Hill, Matthew Masterson of the Ohio Secretary of State’s office, and Christy McCormick, a Justice Department civil rights lawyer, to the commission. A fourth nominee, Matthew Butler, former CEO of liberal media watchdog Media Matters, has yet to be confirmed. House Republicans have tried to shut down the EAC, and Senate Republicans resisted nominating commissioners. But reviving the commission was one of the recommendations of the bipartisan panel formed by Obama to look into long voting lines during the 2012 election. For one thing, the Election Assistance Commission is in charge of setting federal standards for voting systems, which  haven’t been updated since 2005.

National: Every Election Is the Most Expensive Election. Or Not. | New York Times

Was this election the most expensive midterm in history? It’s possible, but nobody really knows for certain. That’s because we don’t know the total cost of the 2014 elections, or pretty much any federal election. Here’s why: Despite the efforts of the Federal Election Commission, which has been faithfully disseminating campaign finance data since 1975, there are limitations in the ways that data is collected and summarized that make generating totals and comparisons very difficult. And there are other problems, too. In describing federal elections, users of the F.E.C.’s data — The New York Times among them — have regularly cited statistics that are aren’t strictly accurate or have made comparisons without regard to the impact of inflation or population. In a paper presented at the American Political Science Association conference this year, Robin Kolodny, a political-science professor at Temple University, challenged the idea that we know each election is more expensive than previous ones, or that we even know how much campaigns really cost. This lack of knowledge fuels our perceptions of money in politics as an issue, she concludes.

National: The pros and cons of all-mail elections, as told by two Republican secretaries of state | The Washington Post

Weeks before Election Day, every registered voter in Oregon, Washington and Colorado got a ballot in the mail. They didn’t have to sign up, and no one had to make any special plans to head to out-of-the-way polling places within a specific window: Elections in those three states are conducted entirely by mail. It’s a controversial practice: Democrats who passed legislation creating all-mail elections say they help boost participation, especially for those who have to work on Election Day. Some Republicans say it’s a transparent attempt to tip the scales toward Democratic candidates, and that it’s ripe for fraud and abuse. But the Republican view on all-mail elections isn’t uniform: Kim Wyman (R), Washington’s secretary of state, is a big fan. Scott Gessler (R), Colorado’s secretary of state, isn’t.

National: Party fundraising provision, crafted in secret, could shift money flow in politics | The Washington Post

A massive expansion of party fundraising slipped into a congressional budget deal this week would fundamentally alter how money flows into political campaigns, providing parties with new muscle to try to wrest power back from independent groups. The provision — one of the most significant changes to the campaign finance system since the landmark McCain-Feingold measure — was written behind closed doors with no public debate. Instead, it surfaced at the last minute in the final pages of a 1,603-page spending bill, which Congress is rushing to pass to keep government operations from shutting down. Under the language in the bill, a couple could give as much as $3.1 million to a party’s various national committees in one election cycle — more than triple the current limit.

National: Campaign Finanace Changes in the Cromnibus | Roll Call

Despite backlash from Democrats, good government groups think the language in the year-end spending bill that alters campaign finance law benefits both parties’ pocketbooks too much for it to be carved out. The watchdogs were among the first to criticize provisions buried deep in the “cromnibus” released Tuesday night that would dramatically ease spending limits on individual contributions to national political party committees. House Minority Leader Nancy Pelosi followed suit. The California Democrat said she learned about the provisions only one day before the carefully negotiated agreement was released. Pelosi, one of the top fundraisers for the Democratic Congressional Campaign Committee, announced she’s “deeply troubled” by how that part of the package would increase by tenfold the amount of money wealthy individuals can contribute. Reps. Chris Van Hollen of Maryland and Steve Israel of New York, former chairmen of the DCCC, joined in the criticism of the legislation that would allow a single individual to contribute to each national party’s three committees a total of $1.5 million per two-year election cycle.

National: Outside Groups Set Spending Record in Midterms | New York Times

Political groups independent of candidates spent more than $814 million to influence congressional elections last month, a record for the midterms and nearly twice the spending in 2010, Federal Election Commission records show. The most obvious explanation for the rapid increase is the effect of the 2010 Citizens United decision by the Supreme Court and the rise in spending by super PACs, which can accept unlimited contributions from individuals, corporations and unions. This year the groups jumped into Democratic efforts to maintain control of the Senate, and into the ultimately successful campaign by Republicans to retake it. The total includes Democratic and Republican party committees for House and Senate candidates, which are not permitted to coordinate with their candidates when making independent expenditures, but even excluding those four committees the amount ($605 million) would still be a midterm record. It does not include some groups, mostly non-profits, that spend money to influence elections without explicitly calling for the election or defeat of a candidate.