Florida: A few former felons in Florida regain voting rights weeks before 2016 election | Miami Herald

It took 33 years, but Gilberto Hernandez of Miami finally feels like an American citizen again. He can vote. Hernandez was one of the few fortunate ones Wednesday as Gov. Rick Scott and the Cabinet sat in judgment of four dozen people seeking to restore their civil rights, decades after they ran afoul of the law and weeks before what could be the most important election of their lifetimes. Hernandez, walking with a cane, expressed remorse for his past and pleaded for the right to full citizenship while he still has the chance. He has Parkinson’s disease and will turn 65 next month. “For 33 years, I’ve been waiting for this day, to try to bring back my civil rights,” Hernandez testified. “I felt that I was less than an American because my rights were all taken away. And I felt very bad.” Hernandez is one of 1.5 million disenfranchised felons in Florida, more than any other state, according to a study by the Sentencing Project. Florida revokes civil rights of convicted felons for life, including the right to vote, serve on a jury or run for public office.

Florida: Amendment to restore voting rights to Florida felons clears key hurdle | Associated Press

Backers of a proposed constitutional amendment that could allow former criminals to vote have met a key hurdle in their quest to make the ballot. State election officials this week reported that amendment supporters have gathered nearly 71,000 signatures from registered voters. This means the initiative will be reviewed by Attorney General Pam Bondi and the Supreme Court of Florida. Florida’s constitution bars people convicted of felonies from being able to vote after they have left prison. Convicted felons must ask the governor and members of the Cabinet to have their voting rights restored.

Editorials: A backward march on voting rights | Judith Browne Dianis/The Washington Post

Denying voting rights to people who have served their prison sentences was an outdated, discriminatory vestige of our nation’s Jim Crow past. Yet a measure recently introduced in Virginia’s legislature would make it harder for this group to vote. A constitutional amendment proposed by Senate Majority Leader Thomas K. Norment Jr. (R-James City) would perpetuate our racist past into the commonwealth’s future. Norment’s amendment would make Virginia’s archaic voting ban more restrictive than the Jim Crow constitution Virginia adopted in 1902. While the amendment appears to call for the restoration of rights of certain people, it would create significant hurdles for some and institute an irreversible lifetime ban for others. The measure also could open the door to punishing even low-level offenses by imposing a lifetime status as a second-class citizen for thousands of Virginians. The result would be that people with past felony convictions would have no say in elections for decades after they’ve paid their debt to society.

Virginia: State Supreme Court denies Republican effort to hold McAuliffe in contempt over felon voting rights | Richmond Times-Dispatch

The Supreme Court of Virginia on Thursday rejected a Republican effort to have Gov. Terry McAuliffe held in contempt over his ongoing efforts to restore voting rights for felons. In a unanimous one-page order, the Supreme Court said it would not force McAuliffe to return to court to prove that he is complying with the court’s July 22 ruling that struck down the governor’s first attempt to restore voting rights to more than 200,000 felons via executive order. The court also said it would not allow Republican General Assembly leaders to seek documents from the McAuliffe administration through a new discovery process. The ruling brings to an end the legal fight that cast uncertainty over thousands of ex-offenders just weeks before early voting gets underway for the presidential election.

Editorials: Virginia Republicans’ essentially racist project | The Washington Post

In about 40 states, people convicted of serious crimes regain their voting rights upon discharge from prison or completion of parole. In a handful of others, convicts either are never disenfranchised or automatically regain their rights after a waiting period. These rules amount to an American consensus on what constitutes a reasonable and humane approach to redemption in a modern democracy. In just four states are felons permanently barred from voting absent action by the governor. And in one of them, Virginia, lawmakers are considering an even more restrictive regime that would forever foreclose the possibility of redemption for tens of thousands of citizens. For this essentially racist project, Virginians can credit the ethically challenged majority leader of Virginia’s state Senate, Thomas K. Norment Jr. (R-James City). He filed legislation last week that would bar people convicted of violent felonies, in Virginia disproportionately African Americans, from ever having their voting rights restored.

Virginia: Republicans go back to court to fight governor on felon voting rights | The Washington Post

Republican legislative leaders on Thursday said they will take Gov. Terry McAuliffe to court once again over his efforts to restore voting rights to felons. The GOP leaders filed a contempt-of-court motion against McAuliffe (D), who last week announced that he had individually restored rights to 13,000 felons and was working to do the same for a total of more than 200,000. McAuliffe’s action last week came in response to a July ruling by the Virginia Supreme Court, which threw out a blanket clemency order that he had issued in April. The governor has described his latest move as a way to comply with the court’s order while addressing “an issue of basic justice.” But Republicans argue in the court filing that the practical effect of McAuliffe’s workaround is the same as the original, sweeping clemency order that the state Supreme Court declared unconstitutional.

Virginia: Republican leader of Virginia Senate advances felon voting plan of his own | The Washington Post

A Republican state senator who sued Gov. Terry McAuliffe over the governor’s efforts to restore voting rights to felons filed legislation Thursday to automatically grant political rights to certain nonviolent criminals. Senate Majority Leader Thomas K. Norment Jr. (R-James City) filed the proposed constitutional amendment one day after he and other Republicans announced that they were taking McAuliffe (D) back to court over his latest attempt at rights restoration. Norment’s move seemed intended to push back against McAuliffe’s claim that Republicans had racist motives for opposing his voting-rights actions. But his plan triggered a fierce backlash from McAuliffe and other Democrats, who said it would close off any avenue for violent felons to vote ever again short of a gubernatorial pardon. GOP legislative leaders have said they objected to McAuliffe’s methods, which they and the state’s Supreme Court deemed unconstitutional.

Editorials: A path to justice for ex-convicts in Virginia | The Washington Post

The Virginia Supreme Court’s impressionistic reading of the state constitution, by which it conjured a provision absent from the actual text, has sent Gov. Terry McAuliffe (D) back to the drawing board in his effort to restore voting rights to tens of thousands of former convicts, who are disproportionately African American. The governor’s determination is commendable, both to reverse an essentially racist legacy of the commonwealth’s history and to ensure that future elections in the state are as broadly democratic as possible. Mr. McAuliffe is following in the footsteps of recent predecessors from both parties, who have regarded the permanent disenfranchisement of former convicts as an injustice. (Virginia is one of just a handful of states with such an onerous ban.) Those governors expanded the restoration of voting rights, taking advantage of explicit constitutional language that enables them to do so — a power that the document’s principal draftsman, University of Virginia law professor A.E. Dick Howard, said was virtually unlimited. Mr. McAuliffe is moving aggressively to further right a wrong that has deprived more than 200,000 Virginians from voting, in some cases for a half-century or longer after they paid their debt to society.

National: Efforts to restore felons’ voting rights cause deep divide | News21

Republican and Democratic politicians across the country are deeply divided over restoring the right to vote to felons, a political fracture that affects millions of convicted criminals. In Iowa and Kentucky, Democratic governors issued executive orders to restore voting rights to many felons, only to have them rescinded by Republican governors who succeeded them. Democratic legislators in 29 states proposed more than 270 bills over the last six years that would have made it easier for some felons to vote, but very few passed, especially in legislatures controlled by Republicans, News21 found in an analysis of state legislative measures nationwide.

Virginia: Governor Restores 13,000 Felons’ Voting Rights, This Time One by One | Governing

Individual orders have gone out re-restoring voting rights for some 13,000 former felons in Virginia, Gov. Terry McAuliffe announced Monday. Included with each mailing: A voter registration form. This first round of new restorations covered most of the people who, following McAuliffe’s mass restoration order in April, registered to vote in Virginia. A few of those cases remained under review as of Monday, the administration said. The state Supreme Court nullified McAuliffe’s April order a month ago, agreeing with GOP legislative leaders who had sued the governor over an unconstitutional exercise of his restoration powers. Only individual orders are valid, the court said.

Virginia: McAuliffe Restores Right to Vote to Thousands of Ex-Felons | NBC News

Nearly 13,000 former felons in Virginia had their right to vote restored Monday—and more could be re-enfranchised in time for the November election. Gov. Terry McAuliffe announced the rights restoration at a civil-rights memorial in Richmond. “Restoring the rights of Virginians who have served their time and live, work and pay taxes in our communities is one of the pressing civil rights issues of our day,” McAuliffe said in a statement. “I have met these men and women and know how sincerely they want to contribute to our society as full citizens again.” Monday’s announcement was the latest salvo in an ongoing battle between McAuliffe, a Democrat, and Republican lawmakers over felon voting rights in the Old Dominion.

Virginia: McAuliffe says he has restored voting rights to 13,000 felons | Daily Progress

Gov. Terry McAuliffe will announce today that he has restored the rights of more than 13,000 felons on a case-by-case basis, two sources said. During a noon ceremony at the Virginia Civil Rights Memorial on Capitol Square, the governor also is expected to detail his rights-restoration process for other felons who have completed their terms. In a 4-3 ruling on July 22, the Supreme Court of Virginia struck down as unconstitutional McAuliffe’s April 22 executive order that restored voting and other civil rights to about 206,000 felons who had completed their terms. The court ordered the Virginia Department of Elections to cancel the registration of all felons who had been “invalidly registered” under McAuliffe’s actions.

Delaware: Law restores voting rights for ex-offenders | NewsWorks

A few Wilmington residents will head to the polls for the first time to vote thanks to a new state law restoring voting rights to ex-offenders. Though the new law made headlines in July when it was signed by Gov. Jack Markell, a local man is on a mission to make sure people are aware of it. His name is Vash Turner, and so far he has registered at least 400 ex-offenders since last month. “Sometimes they get out, they lose fight because they feel as though they’re not a part of society anymore,” Turner said. Throughout the years, state leaders have taken several steps to help ex-offenders feel like they are a part of society. Years ago, ex-offenders were allowed to vote after a five year waiting period and settling court fees.

Virginia: ‘Don’t give up hope,’ McAuliffe official says at forum on nullified felon voting order | Richmond Times-Dispatch: City Of Richmond News

Gov. Terry McAuliffe’s administration had few answers Tuesday for a room full of Richmonders frustrated by a court ruling that threw out the governor’s order that restored voting rights for more than 200,000 felons. At a town hall event held in a church on Richmond’s North Side, McAuliffe appointees and Del. Jennifer L. McClellan, D-Richmond, told attendees to stay involved in the issue, but offered little concrete information about when and how felons affected by the order will have their rights restored again. “Don’t give up hope. The governor’s committed to doing this,” said Secretary of the Commonwealth Kelly Thomasson. “The No. 1 marching order for tonight is to stay tuned,” McClellan said.

Virginia: McAuliffe taking a slower approach to rights restoration in Virginia | The Washington Post

Armed with an autopen, Gov. Terry McAuliffe said two weeks ago that he had all he needed to swiftly but individually restore voting rights to more than 200,000 felons. But McAuliffe (D) has since decided that he needs something else: time. McAuliffe brought delegates to their feet at last month’s Democratic National Convention when he vowed to defy the state’s highest court, which had just struck down his April executive order to restore voting rights to felons who had completed their sentences. He said the 200,000 felons would have their rights back in the space of two weeks. That self-imposed deadline came and went Monday without a single felon’s rights having been restored. McAuliffe’s spokesman, Brian Coy, said the governor is taking the time necessary to make sure the rights-restoration orders are handled properly.

Mississippi: Small number have voting rights restored in Mississippi | Jackson Clarion-Ledger

In Mississippi, a person convicted of selling 1,000 kilos of cocaine keeps the right to vote while a person convicted of grand larceny loses the right to vote for life. Mississippi lists 21 felony crimes that disqualify a person from voting for life: arson; armed robbery; bigamy; bribery; embezzlement; extortion; felony bad check; felony shoplifting; forgery; larceny; murder; obtaining money or goods under false pretense; perjury; rape; receiving stolen property; robbery; theft; timber larceny; unlawful taking of motor vehicle; statutory rape; carjacking; and larceny under lease or rental agreement. In Mississippi, the only way to restore the right to vote after a felony conviction is by the Legislature passing a suffrage bill. However, very few people have their right to vote restored through the legislative process. “It’s not an effective, workable system,” said longtime state Rep. Tommy Reynolds, D-Charleston. “It’s basically a 19th century system for the 21st century.”

Florida: Activists push to restore voting rights to ex-felons in Florida | Orlando Sentinel

Altamonte Springs resident LaShanna Tyson has been invited into the White House, but she can’t help pick the person who lives there. Tyson lost her voting rights back in the late 1990s, when she was convicted as the getaway driver in a deadly convenience store holdup. It was the first crime on her record, and as she served her sentence, she dreamed about one day being reunited with her three children, going back to college and reclaiming her place in society. After 13 years behind bars, she walked out of prison, but the freedom she expected wasn’t waiting for her on the other side. As one of more than 1.6 million Floridians barred from voting because of a felony conviction, she gathered Monday in Orlando with a group of activists and community leaders pushing to overhaul laws that are among the nation’s most restrictive for ex-felons looking to re-enter the polling booth. “There was a system set up to keep me and others like me from getting jobs, from getting housing, from getting second chances, and even from being able to vote,” the 45-year-old woman said.

Editorials: Virginia’s Century-Old Mentality on Race | The New York Times

The Virginia Supreme Court erred earlier this month when it ruled that Gov. Terry McAuliffe’s blanket executive order restoring the voting rights of more than 200,000 people who had been barred from voting for felony convictions violated the state Constitution. The poorly reasoned ruling — which holds that the governor can legally restore voting rights only on a case-by-case basis — has no legitimate basis in the state Constitution. To his credit, Mr. McAuliffe has vowed to reinstate voting rights to those Virginians even if it means signing the restoration orders one at a time. When he issued the blanket order in April, Mr. McAuliffe acknowledged what politicians in Virginia and elsewhere have long lacked the courage to admit: The disenfranchisement law was expressly designed to permanently bar as many African-Americans as possible from the polls.

Virginia: ‘Why don’t they want us to vote?’ Felons cope with losing voting rights twice in Virginia | The Washington Post

Louise Benjamin, 48, looked forward to casting her first ever ballot in Virginia this November, after Gov. Terry McAuliffe restored her voting rights and those of more than 200,000 other convicted felons who had also completed their sentences. She saw voting as a chance for redemption after serving time for assault charges. Then, last week, the state Supreme Court decided she couldn’t vote after all. “I was so hurt. I couldn’t even believe it,” said Benjamin, after the state’s highest court ruled that McAuliffe had overstepped his authority by restoring voting rights en masse instead of on a case by case basis. “Why they don’t want us to vote?” Across the state, more than 13,000 ex-offenders who had registered to vote after McAuliffe signed his wholesale clemency order in April have been thrust into a kind of voting limbo. “They have felt like they just had their rights restored and before they could even savor that for long, here comes the court just swooping in and taking it all away again,” said Tram Nguyen, co-executive of New Virginia Majority which has been registering ex-offenders including Benjamin. “A lot of them are hearing the message that they don’t belong, they don’t deserve a voice.” The court directed the state elections commissioner, Edgardo Cortés, to cancel the registrations by Aug. 25 of the 13,000 felons and add their names to a list of prohibited voters.

Virginia: McAuliffe Vows To Restore Voting Rights Of Some 200,000 Virginia Felons One At A Time | AlexandriaNews

Just after a divided Virginia Supreme Court declared Gov. Terry McAuliffe’s executive order restoring the rights of more than 200,000 Virginia felons unconstitutional, McAuliffe vowed to restore those voting rights one individual at a time. Chief Justice Donald Lemons wrote the majority opinion for the Court. Relying on his clemency power under Article V, Section 12 of the Constitution of Virginia, Governor McAuliffe’s Executive Order sought “to restore the political rights of any persons disqualified by Article II, Section 1.” J.A. at 1. The voter-disqualification provision in Article II, Section 1 of the Constitution of Virginia provides: “No person who has been convicted of a felony shall be qualified to vote unless his civil rights have been restored by the Governor or other appropriate authority.” Felons may request that their civil rights be restored, and Article II, Section 1 grants the Governor the power to consider and act on those requests.

Editorials: Virginia’s voting rights debacle | The Washington Post

The Virginia Supreme Court ruling that Gov. Terry McAuliffe (D) overstepped his powers in restoring voting rights to 206,000 felons who have completed their sentences is a model of pretzel-twisted reasoning that glosses over the plain language of the state’s constitution and elides recent state history to arrive at a conclusion whose effects are as heedless of national trends as they are racially retrograde. Writing for the majority in a 4-to-3 decision, Chief Justice Donald W. Lemons upended the governor’s executive order — challenged by political rivals whose legal standing to sue is shaky at best — mainly on the basis of history and tradition. Yet in doing so, he failed to cite any constitutional language that would contravene Mr. McAuliffe’s power to issue his directive. And while acknowledging that its analysis was rooted more in history than the constitution, which explicitly empowers Virginia governors to restore voting rights, the court seemed oblivious that the state’s history — tainted as it is by profound racial injustice — has evolved radically.

Virginia: Governor Says Fight for Felons’ Voting Rights Is Not Over | The New York Times

When Gov. Terry McAuliffe of Virginia ordered the blanket restoration of voting rights to more than 200,000 former felons in April, Republicans who control the state legislature swiftly filed a petition in court, accusing him of exceeding his authority. And when the state’s highest court agreed on Friday, voiding the governor’s declaration in a biting ruling, that briefly seemed to put the matter to rest. But Mr. McAuliffe is not giving up so easily. And the decision may have laid the groundwork for more legal and political maneuvering in a state that both presidential campaigns regard as a major prize. After the Virginia Supreme Court said on Friday that the governor could restore voting rights only on a case-by-case basis, Mr. McAuliffe said he would forgo his blanket declaration — and, instead, individually sign about 206,000 restoration orders for ex-felons, including 13,000 who had registered after his April order. “I cannot accept that this overtly political action could succeed in suppressing the voices of many thousands of men and women,” the governor said in a statement. “The struggle for civil rights has always been a long and difficult one, but the fight goes on.”

Virginia: Supreme Court Decision Creating Trouble for Voting Registrar | WVIR

Thousands of Virginia felons who had their voting rights restored have had them stripped away again and the back and forth is creating quite a mess for state registrars. In April, Democratic Virginia Governor Terry McAuliffe restored the voting rights of all of Virginia’s formerly convicted felons. On Friday, the Virginia Supreme Court ruled the order unconstitutional. That puts thousands of felons and registrars in limbo. “There’s general confusion about how this is going to be handled,” said Anne Hemenway the president of the city of Charlottesville Board of Elections. Of the 200,000 felons of what their voting rights restored, 13,000 already registered to vote. “There’s never been a situation where this many have been challenged at the same time this close to an election too,” said Hemenway.

Virginia: Felons Lose Voting Rights as Virginia Supreme Court Rules Against Governor | The New York Times

A divided Virginia Supreme Court on Friday overturned a series of executive orders issued by Gov. Terry McAuliffe that had restored the voting rights of more than 200,000 convicted felons. The court, in a 4-to-3 decision, disputed the governor’s assertion that his clemency power was absolute under the state’s Constitution. “We respectfully disagree,” the majority justices wrote. “The clemency power may be broad, but it is not absolute.” The court ordered that the state’s Elections Department and its commissioner delete from voter rolls all felons who may have registered as a result of the executive orders, which were issued on April 22, May 31 and June 24. More than 11,000 felons registered to vote under the orders, The Associated Press reported. The majority opinion, written by Chief Justice Donald W. Lemons, noted that none of the 71 preceding governors had issued a clemency order of any kind — including pardons, reprieves, commutations and restoration orders — to a group of unnamed felons without considering the nature of their crimes.

Virginia: Virginia Supreme Court Blocks Voting Rights for Felons | Wall Street Journal

The Virginia Supreme Court on Friday voided Gov. Terry McAuliffe’s effort to restore voting rights to 206,000 people with felony records. Mr. McAuliffe issued an order in April to restore voting rights to convicted felons who have served their sentences while also completing parole and probation, and followed with similar orders in May and June. He cast felon-disenfranchisement laws as a troubling tool that whites had wielded to suppress votes among blacks. The state’s high court in a 4-3 ruling struck down all the orders, ruling they violated Virginia’s constitution. The court’s majority said the “unprecedented scope, magnitude, and categorical nature” of the governor’s actions violated the legal limits on his clemency powers. Mr. McAuliffe can use those clemency powers on a case-by-case basis to restore a felon’s civil rights, but “that does not mean he can effectively rewrite the general rule of law” in Virginia that says convicted felons are disqualified from voting, the court said.

Virginia: State Supreme Court strikes down McAuliffe’s order on felon voting rights | Richmond Times-Dispatch

The Supreme Court of Virginia on Friday struck down Gov. Terry McAuliffe’s executive order restoring voting rights to 206,000 felons, dealing a severe blow to what the governor has touted as one of his proudest achievements in office. In a 4-3 ruling, the court declared McAuliffe’s order unconstitutional, saying it amounts to a unilateral rewrite and suspension of the state’s policy of lifetime disenfranchisement for felons. The court ordered the Virginia Department of Elections to “cancel the registration of all felons who have been invalidly registered” under McAuliffe’s April 22 executive order and subsequent orders. As of this week, 11,662 felons had registered to vote under McAuliffe’s orders. The court gave a cancellation deadline of Aug. 25. McAuliffe, a Democrat, took the sweeping action in April, saying he was doing away with an unusually restrictive voting policy that has a disproportionate impact on African-Americans. In a legal challenge, Republican leaders argued McAuliffe overstepped his power by issuing a blanket restoration order for violent and nonviolent felons with no case-by-case review. The court majority found that McAuliffe did indeed overstep his authority.

Virginia: High court hears Republican voting-rights lawsuit | Reuters

In a case that could have an impact on the November presidential election, the Virginia Supreme Court heard arguments on Tuesday over a Republican lawsuit challenging the blanket restoration of voting rights for 206,000 felons by Democratic Governor Terry McAuliffe. If upheld, McAuliffe’s order could help tip Virginia, a swing state where the vote is traditionally close in presidential elections, in favor of presumptive Democratic presidential candidate Hillary Clinton. Lawyers for leaders in the Republican-controlled state legislature argued that McAuliffe exceeded his authority by restoring voting rights en masse, rather than on a case-by-case basis. “Never in Virginia’s 240-year history has a governor exercised clemency power en masse,” Charles Cooper, an attorney for the plaintiffs, told the court.

Virginia: Will Virginia Supreme Court restore felon voting rights? | CSMonitor

The Supreme Court of Virginia heard arguments Tuesday in a lawsuit filed by Assembly Republicans who are seeking to block an executive order from Democratic Gov. Terry McAuliffe that restored voting rights to more than 206,000 Virginians who had previously been convicted of felonies. State Republicans say Mr. McAuliffe exceeded his authority with the order and the state’s constitution only allows governors to restore rights, including voting rights, on a case-by-case basis. The executive order granted voting rights to those who had served their time and completed any parole or probation requirements by the date of his order. The executive order revised the state’s previous policy, which required all citizens with felony convictions to apply for voting rights restoration before being permitted to vote. With the order, Virginia joins 39 other states and the District of Columbia in allowing citizens with past criminal convictions to vote, and more than 11,000 felons in Virginia have since registered.

Editorials: Virginia Needs to Fix Its Racist Voting Law | Dale E. Ho/The New York Times

The Virginia Supreme Court will hear arguments on Tuesday in a lawsuit that aims to strip the right to vote from more than 206,000 people, including one in five African-American adults in the state. If state lawmakers win, they will keep Virginia trapped in a shameful part of history: when former Confederate states passed felon disenfranchisement laws after Reconstruction to suppress black political power. Under Virginia’s Constitution, a person with a single felony offense can’t vote unless the governor restores his or her voting rights. This wasn’t always the case. Virginia’s 1870 Constitution, passed during Reconstruction, barred voting for those convicted of corruption or treason. But delegates to Virginia’s 1902 constitutional convention adopted new voting restrictions, including a ban on voting for all felons, poll taxes and a literacy test. They were not shy about their intentions. Virginia’s new constitution would “eliminate the darkey as a political factor,” explained Carter Glass, a convention delegate and, later as a United States senator, an author of the Glass-Steagall banking law. Their goal was to ensure “complete supremacy of the white race in the affairs of government.”

Virginia: Battle over felons’ voting heads to Virginia Supreme Court | Associated Press

Cheryl Fleming can’t wait to vote in November. The 54-year-old who lives in Fairfax County had her voting rights restored in April by Gov. Terry McAuliffe after losing them in 1989 for forging checks to buy drugs. She has never seen the inside of a polling booth. “I was so excited I was screaming in the house,” Fleming said of hearing that she got her voting rights back. “I’ve put my life back together and this was still being held against me,” said Fleming, who now works as an Uber driver. If Republican lawmakers are successful in their legal challenge to McAuliffe’s executive order, Fleming and more than 200,000 ex-felons who’ve completed their sentences could again be stripped of the ability to vote. At issue when the Virginia Supreme Court meets Tuesday to hear the case is whether the state’s constitution allows governors to restore political rights en masse or requires them to be handled on a case-by-case basis.