The New Frontiers of Vote Fraud

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The New Frontiers of Vote Fraud:  Trying to strike down voter ID laws was just the beginning

By Barbara Joanna Lucas, Organization Trends, December 2015 (PDF here)

Summary: The Left seeks power, and at least for the time being, that requires winning elections. So the Left pursues every scheme it can concoct to boost votes for its favored causes and candidates. This report details how the Left not only opposes every law, like voter ID, that aims to ensure honest elections, it is also passing laws and regulations that aim to swamp the polls with Left-friendly voters. And so non-citizens, and illegal immigrants, and underage voters are being welcomed to voting booths, while voter registration and even voting itself are on the road to being made compulsory for every person with a heartbeat.

Where does this notion that anyone with a pulse must vote come from? Why is it that even the most modest measures to ensure an election has integrity provoke hysteria from the Left and shameless comparisons to Jim Crow measures that unconstitutionally denied large numbers of Americans the right to vote?

The Left has long used shrill rhetoric to stifle many electoral integrity laws across the country. More recently, it has become increasingly emboldened as it parades illegal voters to the polls.

There is a simple explanation: Voter fraud and illegal immigrant votes have historically favored Democrats, as we shall see.

The mainstream media and Democrats love dwelling on all the problems facing the Republican Party, the infighting in Congress, and a built-in mathematical disadvantage for Republicans in the Electoral College that decides presidential elections. And it is true that the Electoral College poses a long-term challenge for the GOP, because many large states like New York and California are already in the bag for Democrats before the first vote is even cast. But the presidency is where the Democrats’ advantage ends.

The 2010 and 2014 elections solidified not only large Republican majorities in Congress, but also and more importantly brought Republicans to power in 70 percent of state legislatures across the country, including many swing states, as well as 60 percent of governorships (Vox, Oct. 19, 2015).

Cokie Roberts startled some politics watchers at the beginning of this year when she said on ABC’s “This Week” that President Obama has “lost almost 70 Democrats [in Congress] since he’s been president and more than 900 state legislators.” PolitiFact, a high-profile fact-checking website not known for being kind to Republicans, put Roberts’ claim under the microscope. The statement earned the best possible rating, “TRUE,” on its “Truth-O-Meter.” PolitiFact concluded that “Democrats have lost 910 seats since Obama took office” (Jan. 25, 2015).

The website explained that it “compared the number of Democratic seats in early 2009, when Obama took office, to the number of seats after the 2014 midterms. The bottom line: Republicans now control about 56 percent of the country’s 7,383 state legislative seats, up 12 percentage points since 2009. Thirty-five states posted double-digit seat losses for the Democrats in state legislatures, including more than 50 seats each in Arkansas, New Hampshire and West Virginia. Democrats actually gained a few seats over the course of Obama’s presidency in New Jersey (one) and Illinois (three), and the number of Democratic seats stayed the same in California.”

State elections last month generated even more losses for Democrats.

Voters in the Commonwealth of Kentucky, which had elected only one Republican governor in the last four decades, elected Tea Party movement-backed Republican Matt Bevin. The state’s attorney general Democrat Jack Conway, lost by 53 to 44 percent. Kentucky Auditor Adam Edelen (D) was defeated by Mark Harmon (R). Edelen spent almost $900,000 on his campaign, more than 20 times the roughly $40,000 Harmon spent.

In Virginia, Republicans hung on to their majority in the House of Delegates and fended off a Democrat attempt to capture the state Senate that was underwritten with millions of dollars of contributions from former New York Mayor Michael Bloomberg. Democrats, who wanted to aid Gov. Terry McAuliffe (D) in his never-ending quest for harsher gun control, needed a net gain of only one seat, but they didn’t get it.

Though they receive far less press attention than federal contests, these state legislature races select who will draw the lines designating federal and state legislative districts, which means the GOP is likely to have a long-term hold on the U.S. House of Representatives. This state dominance also creates a larger bench for the party, which allows the GOP to compete reasonably well in future presidential years, despite the disadvantage it faces in the Electoral College.

Democratic operatives and politicians know this. They don’t talk about it in public, but it scares them that America—for the most part—remains a center-right country.

The Left does have unelected judges making law on the bench and unelected bureaucrats imposing regulations, which have long been important avenues that allow the Left to bypass voters. But eventually, democracy kicks in.

Another way to deal with the Left’s democracy problem is to change the demographics. Democrats have long sought amnesty laws that would create a pathway for undocumented Democrats to vote eventually. And for the less scrupulous on the left, there is yet one more avenue to achieve their agenda: Find a way to make sure non-citizens and illegal immigrant voters turn out on Election Day, even if you haven’t yet changed the law to permit them to vote.

The first option—putting the undocumented on a legal path to citizenship—has been pushed by Democrats for decades in various forms. In 1965 President Lyndon Johnson signed a major immigration bill championed by the late Sen. Ted Kennedy (D-Mass.), and in 1986, Democrats succeeded in passing another major immigration law, the Simpson-Mazzoli Act, with bipartisan support. More recently, Presidents George W. Bush and Barack Obama sought such laws, which failed in Congress.

“Motor Voter” and the Cloward-Piven Strategy
Left-wing activists and academics have pushed the idea for some time that legal resident non-citizens and illegal aliens alike should have the same voting rights as citizens. But now it has moved beyond theory into law.

In the nation’s largest state, a new “motor-voter” law is expected to allow illegal immigrants to vote on a grand scale in federal, state, and local elections. The nation’s original motor-voter law was the National Voter Registration Act that President Bill Clinton signed into law a few months after his inauguration in 1993.

Looking back, journalist John Fund recalls how Clinton “had just won an election in which the country had seen the largest increase in voter turnout in a generation.” And yet “President Clinton declared a ‘crisis’ in civic participation and proceeded to ram the proposed law through Congress.”

As Matthew Vadum, the editor of this publication, has written, radical academics Richard Cloward and Frances Fox Piven “were strong advocates for the law.”

“Enlisting millions of new and politicized voters is the way to create an electoral environment hospitable to fundamental change in American society,” Cloward and Piven argued in a 1983 article that makes clear the direct political goals that they and their fellow travelers in the Democratic Party sought: “Toward a Class-Based Realignment of American Politics: A Movement Strategy.”

Cloward and Piven added:

An enlarged and politicized electorate will sustain and encourage the movements in American society that are already working for the rights of women and minorities, for the protection of the social programs, and for transformation of foreign policy. Equally important, an enlarged and politicized electorate will foster and protect future mass movements from the bottom that the ongoing economic crisis is likely to generate, thus opening American politics to solutions to the economic crisis that express the interests of the lower strata of the population…. The objective is to accelerate the dealigning forces already at work in American politics, and to promote party realignment along class lines.

President Obama has continued this effort in his aggressive outreach to low-information voters. Despite fawning coverage from the mainstream news media, Obama would nevertheless avoid what few tough questions he might get by going on “Entertainment Tonight,” MTV, E! and other silly entertainment venues answering the most friendly questions and looking cool while doing it.

Obama also “used the Cloward and Piven class warfare-based electoral strategy in 1992 when he worked for ACORN’s Project Vote affiliate.” He said, “All our people must know that politics and voting affects their lives directly,” and “If we’re registering people in public housing, for an example, we talk about aid cuts and who’s responsible.”

Back in 1993, Clinton made clear the underlying agenda of Motor-Voter when he had Cloward and Piven as official guests at the bill’s signing ceremony. Soon additional state and local government offices were conscripted into the voter registration drive.

Compulsory Voting
As Vadum observed, Peter Orszag, who headed the Office of Management and Budget under Obama, brought up the idea of mandatory voting during the 2012 presidential election, “when it looked like Obama was on the ropes.” Orszag claimed that even if America “prides itself as the beacon of democracy … it’s very likely no U.S. president has ever been elected by a majority of American adults. It’s our own fault — because voter participation rates are running below 60 percent, a candidate would have to win 85 percent or more of the vote to be elected by a majority.”

He continued, “Beyond simply raising participation, compulsory voting could alter the role of money in elections. Turn-out-the-vote efforts, often bankrolled by big-money groups, would become largely irrelevant. Negative advertising could be less effective, because a central aim of such ads is to discourage participation in the opponent’s camp.”

Liberals claim they want a more participatory democracy, but Obama said at a March town hall meeting in Cleveland, Ohio, that he thinks it would be fun to force people to vote—an idea which ignores the fact that not voting is also a choice.

“In Australia and some other countries, there is mandatory voting. It would be transformative if everybody voted,” Obama said. “That would counteract money more than anything. If everybody voted, then it would completely change the political map in this country, because the people who tend not to vote are young. They are lower income. They are skewed more heavily toward immigrant groups and minority groups.”

Obama added, “there is a reason some people try to keep them away from the polls.”
“We want to get them into the polls. That may be a better strategy in the short term,” Obama said. “In the long term, I think it would be fun to have a constitutional amendment process about how our financial system works. But realistically, that would be a long-term proposition.” White House spokesman Josh Earnest later said that Obama was not making a policy proposal about mandatory voting, simply making an observation.

Democratic presidential candidate Hillary Clinton, struggling in the polls, took the same view at a June campaign event at Texas Southern University. “I’m calling for universal automatic voter registration,” Clinton said. “Every citizen in every state in the Union should be automatically registered to vote when they turn 18, unless they choose to opt out.”

Such a proposal clearly poses problems, one leading election expert said. “Automatic registration, I’m afraid, would result in increasing the number of ineligible registrations as well as duplicate registrations,” said Hans von Spakovsky, a former member of the Federal Election Commission and now a senior legal fellow at the Heritage Foundation. “Many people are on government databases in more than one state,” he said. “We already have a problem in the current system with people being registered to vote in more than one state” (TheBlaze, June 6, 2015).

But pressing people to vote, much less requiring it under penalty of law, isn’t necessarily good for society. Some on the left, like Lisa Hill, a politics professor at the University of Adelaide in Australia, complain “America has a serious voter turnout problem,” and therefore “American democracy is dying.”

But it’s clear that democracy is not uppermost in her mind. Hill is just another left-winger who believes the electoral system should be used as a vehicle for the redistribution of wealth. Legally mandated voting in the U.S. would aid the redistributionist cause, she openly admits:

The most decisive means for arresting turnout decline and closing the socioeconomic voting gap is mandatory voting: in fact, it is the only mechanism that can push turnout anywhere near 95 percent. Places with mandatory voting also have less wealth inequality, lower levels of political corruption and higher levels of satisfaction with the way democracy is working than voluntary systems.

As Matthew Vadum summarized at FrontPageMag (March 18, 2015):

Boiled down to its essence, Professor Hill’s phony, self-serving, good-government claptrap, promotes the growth of government and involuntary transfers of wealth. Besides, close to 100 percent voter turnout isn’t necessarily a sign that democratic culture is thriving in a country, contrary to Hill’s implication. History suggests the opposite. Sky-high voter participation is associated with despotic regimes that punish citizens for not voting.

Meanwhile, various cities, including New York and San Francisco, have pushed to give voting rights to non-citizens for local elections, while localities in Maryland already allow voting by non-citizens and minors, and Chicago allows non-citizens to vote in school board elections.

Like nearly everything progressive politicians push for the sake of gaining power, this crusade is couched in appeals to so-called social justice. But the threat to electoral integrity cannot be ignored. As we will see below, studies by supporters and opponents of non-citizen voting have shown that non-citizen votes can tilt state elections, even the Electoral College votes in one state. The institution of citizenship is undermined when those who either aren’t in this country legally or those who haven’t gone through the same naturalization process that other legal immigrants went through to earn their voting rights are allowed to vote. Most importantly, these non-citizen votes cancel out the votes of American citizens, including legal immigrants who went through the citizenship process the right way.

California’s ‘State-Sanctioned’ Fraud
Shortly after Oregon Secretary of State Kate Brown (D) was sworn in as that state’s governor this year, taking over from her scandal-plagued predecessor, John Kitzhaber (D), she signed a first-in-the-nation law that automatically registered anyone in the state who receives a driver license. For those concerned about voter integrity, this law certainly raises red flags. (For the fall of Gov. Kitzhaber, forced to resign in the wake of financial improprieties, see Green Watch, November and December 2015.)

“This bill is about making government work better, treating citizens as customers and giving them access to the service they expect,” she said when signing the bill. “When someone moves to Oregon, why should they have to fill out multiple forms for multiple agencies? They should be able to complete one form, one time.” Note that the only time liberals want less governmental red tape is when it comes to piling on more potential Democratic voters.

The Oregon statute will likely make it easier for some people who shouldn’t be able to legally vote to register to vote. Commenting on the problems with this kind of law, Kansas Secretary of State Kris Kobach (R) told the Wichita Eagle such a law could produce “a perfect storm of errors.”

“I just think it’s a virtual certainty that they will see hundreds or thousands of people mailed two or more ballots, and that can be a very tempting situation where some people may succumb to the temptation to fill out both ballots and vote twice,” Kobach said.

At least Oregon has some mechanism that, if you believe the Oregon Secretary of State’s office, will ensure that persons seeking a driver’s license will have to show they are citizens or legal residents, and the Department of Motor Vehicles will make a distinction between the two groups. Theoretically, that distinction will matter when drivers’ information is sent to the Secretary of State’s office to automatically add new drivers to the voter rolls (Los Angeles Times, March 17, 2015).

Oregon’s arrangements look good, compared to California’s. In October, California Gov. Jerry Brown (D) signed AB 1461 into law, the Golden State’s new motor-voter law that also automatically registers Californians to vote when they obtain a driver license.

The big difference is that California issues driver licenses to illegal immigrants and has done so since January. Moreover, the legislation seems to go out of its way to ensure that the state does not have an effective way to weed out those not eligible to vote.

Senate amendments to the legislation eliminated a provision which resembled part of the Oregon law, because it would have required the California DMV to provide the state’s Secretary of State’s office with “the document code or equivalent identifier associated with the document the person provided to prove that his or her presence in the United States is authorized under federal law and that the applicant is a citizen of the United States” (San Diego Union-Tribune, Oct. 5, 2015).

Not only does the California legislation not distinguish between citizens and non-citizens, it goes a step further to ensure no penalty is levied against an illegal voter. Section 2269 of the statute says:

“If a person who is ineligible to vote becomes registered to vote pursuant to this chapter and votes or attempts to vote in an election held after the effective date of the person’s registration, that person shall be presumed to have acted with official authorization and shall not be guilty of fraudulently voting or attempting to vote pursuant to Section 18560, unless that person willfully votes or attempts to vote knowing that he or she is not entitled to vote.”

The rationale given for the legislation was that it would make voter registration easier for the 6.6 million eligible Californians who are not registered. But were there truly that many obstacles to registering to vote in the Golden State before?

California driver licenses issued to non-citizens without legal immigration status in the U.S. bear the words, “federal limits apply,” and “not valid for official federal purposes.” So that would stop voter fraud—if California had a voter ID law. But that’s never going to happen.

More importantly, California’s DMV database doesn’t store records that differentiate based on citizenship status and doesn’t plan to start, according to True the Vote, an electoral integrity organization. This means all these names could be sent to the Secretary of State’s office. California is already violating federal law by failing to have a functioning database of registered voters, thus the state’s record-keeping is a mess from the start.

It seems unlikely that Gov. Jerry Brown and the Democrats in the state legislature didn’t see the likely illegal voting, benefitting Democrats, that could arise when the state decided to issue driver licenses to illegal aliens and then followed up by tying voter registration to driver licensing. The Public Policy Institute found that among unregistered adults in California, 49 percent lean Democrat compared to just 22 percent who would support Republicans (Breitbart News, Oct. 12, 2015).

Expect this to be a trend that will boost the Democratic turnout, because 11 states, as well as the District of Columbia, already provide driver licenses to illegal immigrants (Washington Times, Oct. 11, 2015).

California Secretary of State Alex Padilla (D) was absolutely giddy about the law and also smeared other states’ for their willingness to ensure clean elections. “Citizens should not be required to opt-in to their fundamental right to vote,” Padilla said after Brown signed the bill. “We do not have to opt-in to other rights, such as free speech or due process. The right to vote should be no different.”

“The New Motor Voter Act will make voter registration a seamless process and result in the largest sustained voter registration drive in our nation’s history. As we celebrate the 50th anniversary of the federal Voting Rights Act, Governor Brown has affirmed California’s commitment to strengthening voting rights,” Padilla continued.

“It is not lost on me that many states are restricting voting rights with the clear goal of preventing citizens from voting. I am proud that California is again demonstrating leadership and providing a shining example of how our nation can and should expand access to the polls.”

Linda Paine, head of the Election Integrity Project of California, shot down Padilla’s demagoguery, saying the law amounts to “state sanctioned” voter fraud. “It is not the citizen voters who are empowered by this law; it is the non-citizen ‘voters,’ who also receive a ‘get out of jail free’ clause [sic] along with an unobstructed, automatic registration to vote,” she said.

“The fundamental right to vote is bestowed upon citizens, NOT ‘all who apply for a driver’s license.’ Californians who meet the qualifications specified in our Constitution and laws (must be 18 years of age and a CITIZEN of CA and the USA) have the RIGHT to REGISTER and then VOTE. The State has no right to force registration on its citizens, as this law does, and certainly has no right to facilitate registration and voting by non-citizens.”

Former New Jersey Superior Court judge Andrew Napolitano told Fox News on Oct. 13, “If you are an illegal alien in California, get a driver’s license, register to vote, you can vote in local, state, and federal elections in California and those votes count.” The paid Fox contributor added, “All 50 states limit voting to citizens except when the state allows you to sort of sneak in without proving your citizenship by getting a driver’s license instead.”

Executive Amnesty and the Vote
After Republicans took control of the U.S. Senate in November 2014, President Barack Obama wasted little time in pushing executive actions to shield about 5 million illegal aliens from deportation. He did this primarily by expanding on his deferred action program.

The executive actions are now being challenged in the courts, but some state election officials were immediately concerned that the actions would make it easier for illegals to vote. The executive amnesty allows some illegal immigrants to obtain a Social Security number and a driver license. This makes it more likely they could fraudulently register to vote.

In January, the chief election official of the most fiercely contested battleground state of all, Ohio Secretary of State Jon Husted, wrote a letter to President Obama, expressing his concerns.

“In spite of our diligence maintaining accurate voter registration rolls, however, the recent executive actions could jeopardize their integrity by making it much easier for people who are not U.S. citizens to illegally register and cast ballots. As the chief elections official for the state of Ohio, I simply cannot allow this expanding loophole to go unaddressed,” Husted wrote.

“The source of the problem is that the recent executive actions enable millions of non-U.S. citizens to obtain valid Social Security numbers and driver’s licenses,” the letter continued.

“Under federal law, any person with a valid Social Security number or driver’s license can register to vote, so long as they attest to their eligibility to do. As a result, the recent executive actions dramatically expand the opportunities for illegal voter registrations in Ohio and other states by non-citizen voters who have valid forms of identification and who willingly or negligently affirm their eligibility to vote … In short, by enabling millions of non-citizens to access valid forms of the types of identification required to register to vote, the recent executive actions have increased the risk that non-citizens may illegally register to vote and vote in our elections.”

He went on to acknowledge Ohio’s central role in electing presidents. “Voter confidence is paramount in all states, but magnified in swing states where our democratic system is put under the national and world microscope,” the letter continued.

“If the recent executive actions remain in force, it is imperative that state elections officials be given real-time access to accurate, searchable, electronic databases of non-citizens who have valid Social Security numbers in order to distinguish between citizens and lawfully-present non-citizens.”

Husted and Kobach of Kansas, both Republicans, testified before the U.S. House Oversight and Government Reform Committee in February to say they won’t have the resources to stop illegal immigrants from registering to vote.

Beginnings of a Movement
Before the 1920s, non-citizens could vote in 22 states and federal territories. However, through duly enacted laws, that was tamped down with laws in virtually every state that prohibited non-citizen voting, according to Think Progress.

In 2006, Ron Hayduk, a political science professor at Queens College, wrote, “Democracy For All: Restoring Immigrant Voting Rights in the United States,” which argued for affirming voting rights for everyone physically inside the country, including non-citizens.

Hayduk wrote,

Creation of a truly universal suffrage would create conditions conducive to forming progressive coalitions … Imagine the progressive political possibilities in jurisdictions of high numbers of immigrants such as New York City; Los Angeles; Washington, D.C. and Chicago—as well as in such states—if non-citizens were re-enfranchised.

Hayduk added, “Noncitizen adults already comprise over 10 percent of the voting-age population in seven states and the District of Columbia, and 19 percent of all California voters. If these non-citizens were enfranchised, they could yield decisive power in state races.”

Jamie Raskin, a law professor at American University, Maryland state senator, and currently a Democratic candidate in Maryland’s 8th congressional district, was a leading figure in securing the right to vote for non-citizens in local elections for Takoma Park, Maryland. “It makes them feel like they’re part of the community,” Raskin told the Center for American Progress’s blog Think Progress. He said local citizens support foreign voting because “there’s a neighborly dimension to this.”

Raskin pushed for New York City to adopt the same policy at a time when the New York City Council was considering it in 2013. The initiative in the Big Apple failed, but will likely return for another vote.

Raskin was quoted in a Think Progress article titled, “Why You Have Nothing To Fear From Non-Citizen Voting,” saying he doubts that New York’s experience would be much different from Takoma Park’s, for a few reasons. Among those is the fact that the non-citizen population is transient and disproportionately poor, a contributing factor in their low turnout rates in other municipalities.

Other localities in Maryland also allow non-citizens to vote in local elections: Burnsville, Martin’s Additions, Somerset, Garrett Park, and parts of Chevy Chase. Chicago allows non-citizens to vote in school board elections, while City Heights, Calif., allows non-citizen voting in the city’s Planning Committee elections. San Francisco officials have long considered allowing illegal aliens to vote in local elections, but even this liberal bastion hasn’t approved the law just yet. New York City allowed non-citizens to vote in school board elections from 1968 to 2002 (“A Report from the Public Service Management Program at the Colin Powell School of Civil and Global Leadership, Non Citizen Voting in New York City,” The City College of New York, June 2014; https://www.ccny.cuny.edu/sites/default/files/psm/upload/NonCitizenFinal.pdf).

Raskin wrote an article for the University of Pennsylvania Law Review in 1993 titled, “Legal Aliens, Local Citizens: The Historical Constitutional and Theoretical Meanings of Alien Suffrage.”

“The U.S. citizenship voting qualification ropes off the franchise in every American state from participation by non-U.S. citizens,” Raskin wrote. “As a marker at the perimeter of the American body politic, the citizenship qualification carries the aura of inevitability that once attached to property, race, and gender qualifications.”

So, at least some on the left view restricting voting to U.S. citizens as akin to preventing women or African-Americans from voting.

Two other academics made the case for non-citizen voting in 1993. Louis DeSipio, of the University of California, Irvine, and Rodolfo de la Garza, at the University of Texas, called for allowing non-citizens to vote for a five-year period, during which time they wouldn’t be eligible for naturalization. After the five years, they would lose the right to vote, but would still be able to naturalize. Upon gaining citizenship, they would gain the right to vote along with all the other rights of citizens.

They actually disagreed on a key point. De la Garza believed voting for non-citizens should be limited to local elections, while DeSipio explained that this distinction would cause a huge problem for election administrators, who would have to deal with two list of voters and print two separate ballots.

Still they tried to allay concerns by saying not that many non-citizens would bother showing up on Election Day: “We think that regardless of one’s philosophical attitudes toward noncitizen voting in the contemporary political environment it has one serious flaw: Few non-citizens would use the right” (Stanley A. Renson; “Debate Over Non-Citizen Voting: A Primer;” Center for Immigration Studies; April 2008; citing DeSipio and de la Garza’s Making Americans, Remaking America. p. 100; http://cis.org/noncitizen_voting_primer.html#25).

Even if limited to the local level, non-citizens could be decisive in local elections. The Center for Immigration Studies points out that non-citizens make up about one-third of the population in Los Angeles, 22.9 percent in New York City, 16.4 percent in Chicago, 16.7 percent in San Francisco, 22.9 percent in Houston, and 22.2 percent in Dallas.

Already Shifting Elections
De la Garza and DeSipio, despite their claims that non-citizens would have low turnout, continued in their 1993 argument to assert that non-citizens could be a decisive voting bloc in a presidential election.

“It must be noted that the only national race—the campaign for the presidency—is in fact just fifty state races in which the winner takes all of the states’ electoral votes. Thus in a very close race that is determined by the votes of the larger states (most of which are immigrant receiving states), an empowered noncitizen electorate could swing the election.”

Significant evidence now exists that non-citizens have swayed various elections. Obama might have lost the state of North Carolina in 2008 had it not been for the non-citizen vote, according to the non-partisan Cooperative Congressional Election Study. Its 2014 study found that of the sampling of 2008 and 2010 non-citizen voters, 80 percent favored Democrats. Non-citizen voters might have also tilted the 2008 Minnesota Senate race to Democrat Al Franken. The researchers determined that 6.4 percent of non-citizens voted in 2008 and 2.2 percent of non-citizens voted in 2010.

Another researcher has made similar findings. “It is also possible that non-citizen votes were responsible for Obama’s 2008 victory in North Carolina,” writes Jesse Richman, director of the Old Dominion University Social Science Research Center, and David Earnest, a political science professor at Old Dominion. “Obama won the state by 14,177 votes, so a turnout by 5.1 percent of North Carolina’s adult non-citizens would have provided this victory margin.” (Obama would have won the 2008 election even if he had lost North Carolina.) “Non-citizen votes could have given Senate Democrats the pivotal 60th vote needed to overcome filibusters in order to pass health-care reform and other Obama administration priorities in the 111th Congress,” the researchers add.

“Sen. Al Franken (D-Minn.) won election in 2008 with a victory margin of 312 votes,” the Old Dominion researchers continue. Votes cast by just 0.65 percent of Minnesota non-citizens could account for this margin” (Washington Post, Oct. 24, 2014).

Illegal voting could also help Democrats counter the built-in advantage Republicans have in redistricting, mentioned earlier. The Census Bureau counts illegal immigrants, legal residents, and citizens in determining population, which ultimately determines House apportionment and Electoral College votes.

It would be different if only citizens were counted, according to American University communication professor Leonard Steinhorn, whose research found that California would lose five House seats and therefore five Electoral College votes, too. New York and Washington would lose one seat each, and thus two Electoral College votes total. All of these states are safely Democrat in presidential years. For Republican states it would mean two fewer House seats/Electoral College votes from Texas. All told, 10 states would gain Electoral College votes, seven of which are safe or likely Republican. These states are Iowa, Indiana, Louisiana, Michigan, Missouri, Montana, North Carolina, Ohio, Oklahoma, and Pennsylvania (Politico, Oct. 3, 2015).

Seven states allow people registering to vote to use individual taxpayer identification numbers if they do not have a Social Security number, according to the Federation for American Immigration Reform. FAIR has also pointed out cases where non-citizens and illegal immigrants made a big difference in past elections during congressional testimony in 2006, referencing several cases.

A House task force that investigated a 1996 California U.S. House race where Loretta Sanchez (D) beat Bob Dornan (R) by 984 votes found evidence that 748 illegal votes had been cast by non-citizens. This did not, however, reverse the Democrat’s victory, FAIR president Dan Stein told the House Committee on Administration in 2006 (http://www.fairus.org/testimony/non-citizen-voting-in-u-s-elections-and-identification-requirements).

In 2004 in Wisconsin, FAIR had two people pose as illegal immigrants who wanted to register to vote. They were able to register in two separate counties. The advocacy group Voces de la Frontera signed them up even though the individuals said they were not citizens, according to Stein’s congressional testimony.

A 2005 investigation by Utah Legislative Auditor General John Schaff found that more than 58,000 illegal immigrants had Utah driver licenses, and of that, about 400 of them used their license to register to vote, FAIR’s Stein told the congressional committee in 2006.

For the Left, the ends always justify the means, particularly when it comes to stealing elections. For a long time, this meant allowing dead voters. The Left won’t have to be so creative, when they can just crank out ineligible living, breathing voters to cast votes.

Barbara Joanna Lucas is a writer in Virginia who writes regularly for the Capital Research Center. She blogs at TheSharpBite.blogspot.com.

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