MarketFish v. Kobach
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Fish v. Kobach

Fish v. Kobach was a 2018 bench trial in the United States District Court for the District of Kansas in which five Kansas residents, the ACLU and the League of Women Voters contested the legality of the Documentary Proof of Citizenship (DPOC) requirement of the Kansas Secure and Fair Elections (SAFE) Act, which was enacted in 2011 and took effect in 2013.

Timeline
• 2011-04-18: The Kansas Secure and Fair Elections (SAFE) Act was passed by the Kansas legislature in 2011 and signed by the Governor. • 2013-01-01: The law takes effect. • 2016-02-18: The American Civil Liberties Union filed suit against it. The League of Women Voters officially supported that lawsuit. • 2016-05-17: The United States District Court for the District of Kansas issued a preliminary injunction against enforcement of the Documentary Proof of Citizenship (DPOC) provisions of the SAFE act. • 2016-05-24: Kobach appealed this ruling to the United States Court of Appeals for the Tenth Circuit. • 2016-10-18: The appellate court upheld the injunction. • 2017-07-05: Kobach appealed the contempt ruling. • 2017-07-25: Chief District Judge Julie Robinson denied Kobach's appeal. • 2018-06-19: Judgment by Timothy O'Brien, Clerk of the District Court • 2018-07-02: Kobach appealed these findings and conclusions to the United States Court of Appeals for the Tenth Circuit. ==Witnesses==
Witnesses
Judge Robinson further generally found the plaintiff's expert witnesses credible while expert witnesses for the defense were often found to be not credible. Defense Jesse Richman Kris Kobach hired Jesse Richman as a paid expert witness in 2018 for Fish v. Kobach. ProPublica summarized Judge Julie Robinson's assessment of Richman's conclusions as "'confusing, inconsistent and methodologically flawed,' and adding that they were 'credibly dismantled' by Ansolabehere. She labeled elements of Richman’s testimony 'disingenuous' and 'misleading,' and stated that she gave his research 'no weight' in her decision." Richard Hasen called parts of Richman's testimony "social science at its worst." Hans von Spakovsky Hans von Spakovsky, a member of Trump's voter fraud commission, was another expert witness for Kobach whose testimony ProPublica described as having been 'lacerated' by Judge Julie Robinson. She accused him of unsupported and misleading statements as well as false assertions. She said his opinions were based on preconceived beliefs related to his advocacy. "Defendant's expert Hans von Spakovsky is a senior legal fellow at The Heritage Foundation, 'a think tank whose mission [is to] formulate and promote conservative public policies. ... [He] cited a U.S. GAO study for the proposition that the GAO 'found that up to 3 percent of the 30,000 individuals called for jury duty from voter registration roles over a two-year period in just one U.S. district court were not U.S. citizens.' On cross-examination, however, he acknowledged that he omitted the following facts: the GAO study contained information on a total of 8 district courts; 4 of the 8 reported that there was not a single non-citizen who had been called for jury duty; and the 3 remaining district courts reported that less than 1% of those called for jury duty from voter rolls were noncitizens. Therefore, his report misleadingly described the only district court with the highest percentage of people reporting that they were noncitizens, while omitting mention of the 7 other courts described in the GAO report, including 4 that had no incidents of noncitizens on the rolls. ... While [Mr. von Spakovsky's] lack of academic background is not fatal to his credibility ...., his clear agenda and misleading statements ... render his opinions unpersuasive." Richard Hasen said Spakovsky had a serious credibility problem with a history of not retracting false claims. ==Rebukes of Kobach by the Judge==
Rebukes of Kobach by the Judge
Trial by ambush During the first three days of the trial, Robinson repeatedly warned Kobach about trying to introduce evidence that had not been shared with the plaintiffs during discovery. Kobach complained that the discussions "are relying on numbers that are stale". After three days, Robinson said, "We're not going to have a trial by ambush here... You're stuck with what you provided to [the plaintiffs] by the deadline". Contempt hearing Secretary Kobach had been fined $1,000 in 2017 for violating previous court orders in this case. In the March 20, 2018, contempt hearing Judge Julie Robinson was visibly agitated when it was revealed that he had still not complied with her 2016 court orders in two specific ways: • In 2016 Judge Robinson ordered Kobach to update the state's election manual to make it clear that newly registered voters are exempt from the state's proof-of-citizenship requirements, at least until there is a different judicial ruling in this case. The manual was taken offline but had not yet been updated. Judge Robinson asked, "Isn't one of the advantages of having the manual online is that they can be modified quickly?" She later added it was a "ridiculous system" to take so long to change a few sentences in the manual. In the March 2018 hearings, Kobach claimed he had given verbal instructions to that effect but acknowledged that some county election offices may not have complied with this ruling. Robinson said that Kobach had assured her in telephone hearings that he had instructed his office to order county election officials to mail the postcards to all voters covered by her order. Kobach claimed she had not put that requirement in writing. She replied, "Why would I order something in writing that you've told me is being taken care of? ... (As an officer of the court) you are under an ethical obligation to tell me the truth.'" (Governor Jeff Colyer, who lost to Kobach in the 2018 Republican primary for Governor, said Kobach should be required to personally pay those fees that had been awarded. Secretary Kobach's office said that Kobach is shielded from any such liability.) == Findings of fact and conclusions of law ==
Findings of fact and conclusions of law
On June 18 and 19, 2018, Judge Robinson published 118 pages of "Findings of fact and conclusions of law" in this case. In broad strokes, she sided with the plaintiffs on most of the major points in question and with the defense on a few relatively minor points. Substantive rulings Most importantly, "the Court finds in favor of the Plaintiffs in the Fish case," establishing that the National Voter Registration Act of 1993 (the "motor voter" act) takes precedence over the Kansas DPOC requirements. In addition, the "Court further finds in favor of Plaintiff Bednasek in his constitutional challenge", concluding that the DPOC violated the fourteenth amendment. In particular, "Defendant shall strictly comply with the directives in this Order meant to enforce the Court's permanent injunction of the DPOC law and K.A.R. sec. 7-23-15. It is further ordered that Defendant shall attend 6 hours [of continuing legal education (CLE) on civil rules of procedure or evidence] in addition to any other CLE education required by his law license for the 2018-2019 reporting year." Lesser findings and rulings In addition to findings regarding the witness testimony above: Defendant Nick Jordan, Kansas Secretary of Revenue, was dismissed from the case. Mr. Fish's complaint was declared moot, because "in September or October 2016, he relocated within Douglas County and changed his address with the DOV in person. ... He is now registered to vote ... not due to the Court's preliminary injunction, but his voluntary action of reapplying to register to vote at which time he provided DPOC." Magnitude of the problems "The voting rate among purported noncitizen registrations on [a Kansas temporary driver license] match list is around 1%, whereas the voting rate among registrants in Kansas more generally is around 70%." By comparison, "Defendant already has prosecutorial authority over Kansas election crimes. Yet, since obtaining this authority, and despite claiming to have located 129 instances of noncitizen registration in Kansas, Defendant has filed zero criminal complaints against noncitizens for registering to vote." But "looking closely at those [129] records reduces that number to 67 at most. Even these 67 instances are a liberal estimate because it includes attempted registrations after the DPOC law was passed, a larger universe than what the Tenth Circuit asked the Court to evaluate. Only 39 successfully registered to vote. ... And several of the individual records of those who registered or attempted to register show errors on the part of State employees, and/or confusion on the part of applicants." Moreover, those 39 represent only "0.002% of all registered voters in Kansas as of January 1, 2013 (1,762,330). Defendant Kobach "insists that [published numbers of noncitizens voting] are just 'the tip of the iceberg.' This trial was his opportunity to produce credible evidence of that iceberg, but he failed to do so. ... Instead, the Court draws the more obvious conclusion that there is no iceberg; only an icicle, largely created by confusion and administrative error." Summary of impact on democracy in Kansas The court found that "31,089 total applicants ... were denied registration for failure to provide DPOC, ... [which] represented 12.4% of new voter registrations between January 1, 2013 and December 11, 2015". Meanwhile, Kansas Secretary of State Kobach, who claimed this was a massive problem, provided evidence of only 39 cases of non-citizens having registered to vote in Kansas, which represented only "0.002% of all registered voters". == References ==
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