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Judicial Watch • Democratic Party of VA v. VA State Board of Elections 01218 Doc 23-1

Democratic Party of VA v. VA State Board of Elections 01218 Doc 23-1

Democratic Party of VA v. VA State Board of Elections 01218 Doc 23-1

Page 1: Democratic Party of VA v. VA State Board of Elections 01218 Doc 23-1


Number of Pages:44

Date Created:October 15, 2013

Date Uploaded to the Library:October 20, 2016

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Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 187 THE UNITED STATES DISTRICT COURT
Plaintiffs, Civil Action No.: 1:13-cv-01218-CMH-TRJ
Comes now, Donald Palmer, and pursuant U.S.C. 1746, makes the following
declaration under penalty perjury: citizen the Commonwealth Virginia, over years age, and competent witness. have personal knowledge the matters set forth this
Declaration, and called witness would testify stated below. the Secretary the Virginia State Board Elections (SBE), position have held since January 28, 2011. this position, responsible for overseeing the
operations and policies the SBE and providing guidance general registrars and electoral
boards about the federal and state requirements for voter registration and election
administration. have had years years experience the field election administration the enforcement voting laws. From 2008-2011, worked the Director Elections
with the Florida Department State and worked the Department Justice, Voting Section trial attorney from 2005-2008.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 188
Since coming SBE, one priorities has been improving Virginias voter
registration rolls. This includes both increasing voter registrations among eligible citizens and
cancelling the registrations those ineligible vote. There clear need for greater and
streamlined access and participation elections through enhanced voter registration well clean existing voter registration records.
The necessity for improved voter registration rolls that eliminate duplicate
voter registrations well documented.
After the 2000 Election and the passage the Help America Vote Act
(HA VA), the Commission Federal Election Refonn (the Carter Baker Commission),
leading nonpartisan authority election policy for over decade, issued report
September 2005 recommending uninamous!y the very steps Virginia
taking with its first
bipartisan legislative initiative 2007:
Current procedures for updating the registration voters who move another state
are weak nonexistent. When people register vote, they are usually asked
provide their prior address, that the jurisdiction where they Jived can notified
delete their names from the voter list. Such notification, however, often does not occur.
When voter moves from Virginia Illinois, for example, four-step process
required update voter registration: election authorities lllinois must ask for
prior address; (2) the voter must provide prior address; (3) lllinois election authmities
must notify
cmi-ect election officials Vrginia; and (4) Virginia election
authorities must remove the voter from its list. Unless all four
are taken, this voter
will remain the voter list Virginia. fact, states often fail share data notify
each other voters who move. result, substantial number Americans are
registered vote more than one state. Report the Commission Election
Reform, Building Confidence U.S. Elections (Sept. 19, 2005), available
This lack effective infonnation interchange, often referred the
election community interoperability, negatively impacts voters placing them risk
delays voting worse
targeted for investigation for registering vote more than
one location (which telrmvin Virginia and other states) and even for double voting. also
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 189
increases the likelihood fraudulent voting the voter registration that active but should cancelled presents opportunity for fraud.
Further demonstration the problems with duplicate registrations and the
need for states work together fix this problem found important report published
November the Pew Charitable Trusts called Upgrading Democracy- Improving
Americas Elections Modernizing States Voter Registration Systems. (The Pew Report copy which attached Exhibit 1). The Pew Charitable Trusts recognized leader the field public policy relation elections. The Pew Report identified that
estimated 2.2 million eligible Americans were unable cast ballots due problems with their
voter registrations. The Pew Report estimated that approximately registrations
nationwide are significantly inaccurate longer valid. The Pew Report also estimates that
approximately million people have registrations more than one state.
There fiscal cost that flows from the findings the Pew Report: [c]osts
for printing and processing forms, handling returned mail inaccurate records, maintaining
registration databases, and other expenses add millions dollars state and local budgets
time when government offices are struggling deliver the highest value for every taxpayer
The Pew report went state that outdated and inaccurate voter rolls and
heavy dependence new voter registrations submitted unregulated third-party groups led troubling questions about the integrity our elections. The Pew report provided
recommended steps that states should take toward modemizing their voter registration systems.
These recommendations included offering online registration, providing improved technology motor vehicle offices and public aid agencies aid registration, and exchanging data with
other states aid removing duplicate and invalid records and removing ineligihle voters.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 190
lam proud how Virginia has responded the problems identified both
the Carter Baker Commission and the Pew Report. the one hand, Virginia has taken great
strides enhance voter registration, including mailings unregistered eligible citizens and
online registration discussed below. With regard duplicate registrations, Virginia
taking responsible and measured approach.
12. 2007, bipartisan legislation sponsored Virginia House Delegates
member Bob Brink Democrat from Arlington) passed the General Assembly unanimously
and included provision authorizing SBE share data with other state voting officials for the
purpose oflist maintenance. Chapter 318 Acts Assembly (2007). Additional legislation
passed 2011and2013 expanded SBEs mandate share this registration data with other
states and specifically take steps prevent the duplication registrations more than one
state jurisdiction. See Va. Code 24.2-404(A)(I and 24.2-404.4.
13. demonstrated both the Pew Repo1i and the Carter Baker Commissions
recommendations, Virginias legislatively mandated process for providing for cancellation
Virginia registration :frlllowing official communication ofregistration another state, coupled
with su!iseqw~nt legislation improving official communication between states, are all vital
protecting voters, candidates and the integrity elections and increasing voter confidence
the registration and electoral process. Improved voter registration lists are also important
the political process SBE has identified errors the voter infonnation data provided
candidates and political parties which have been told negatively affects the campaigns that
rely voter data get their message out.
Virginias interstate data exchange also important step towards
implementing the Carter Bakers 2005 recommendation eliminate duplicate registrations
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 191
they are source potential fraud. Report the Commission Election Reform, supra, 79.
15. result the bipartisan changes the Code Virginia, SBE has begun
implementing these data-sharing recommendations and legislation from the General Assembly. that end, SBE has joined two different consortiums states for the purposes sharing
voter registration data improve the accuracy our voter registration list.
The first project yield any results for SBE was the Electronic Registration
Infonnation Center (ERIC). The ERIC project uses hoth the Virginia Department Motor
Vehicle (DMV) data well SBE voter registration data identify data integrity issues,
dual voter registrations and identify individuals who are not registered vote but who are
likely Virginia residents. Seven states, including Virginia, Maryland, Delaware, Utah,
Colorado, Washington and Nevada, have officially joined the ERIC project. The ERIC project
provided list over 1.6 million unregistered Virginia residents over million unique
mailing addresses. part the ERIC membership agreement, and part
initiative provide for great voter registration, SBE mailed 867 ,852 postcards these
unregistered Virginia residents mailing addresses September 27, 2012. This postcard
informed the recipient that they may eligible vote and provided them with infonnation
how register well infonnation Virginias new voter identification law (to educate
voters the law and counteract various statements the press that opinion not
fairly characterize these laws and may cause confusion). July 2013, based upon legislation drafted and supported SBE, SBE
launched online voter registration portal that allows voters register and update their
registration online with appropriate DMV customer identification number. addition, SBE
has submitted budget request for the next state budget that includes cash investment
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 192
provide improved technology for voter registration and updates the DMV office locations,
allowing for registration applications submitted DMV sent electronically SBE and
the localities. Paper registration inevitably leads applications lost the mail and errors
voters and local election staff inputting data into the registration database. Reasons for these
technology upgrades are improve the accuracy registration data entered into the database,
correct erroneous data, streamline the voter registration access, and generally make voter
registration easier for the voter.
The second data-sharing project get off the ground for SBE was the
Interstate Crosscheck Program (Crosscheck). The Crosscheck process started 2005, and bipartisan effort initiated number Secretaries State, including then-Kansas
Secretary State Ron Thornburg (R) and Secretary State Robin Carnahan (D) from
Missouri. each election, the number states participating the program has increased. 2013, total of22 states participated the program sharing over million voter
registration records. the best knowledge, twenty-six states have joined the
Crosscheck program todays date.
19. January 2013, each state submitted their entire list ofregistcred voters,
including the voters date birth, last four digits their Social Security Number (where
allowed law), cmTent registration address, whether not they had voted the November
2012 General Election, and applicable dates registration activity the voter.
20. February and early March of20!3, SBE received the results from the
Crosscheck match. The preliminary results received from the Crosscheck data revealed the
likelihood that many 308,000 individuals were registered both Virginia and another
state. Nationally, the Crosscheck identified some million records that were questionable
those states and identified some people who voted multiple states. The ERIC project
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 193
made mostly additional states, including Virginia, identified hundreds thousands
other registrations that needed updating.
After further review the data April 2013, SBE staff presented the State
Board initial review the Crosscheck findings. this Board meeting, additional
information was provided the Board indicating potential widespread double-voting
Virginia and another state during the November 2012 General Election. that meeting, the
State Board voted unanimously ask the Office the Attorney General investigate the
possibility voter fraud and double voting result the Crosscheck. copy the
minutes that meeting are attached Exhibit Following the Board meeting, sent
email alt Virginias general registrars and electoral board members explaining them the
Crosscheck and ERIC programs with note expect infonnation upcoming list
maintenance efforts result the Crosscheck and ERIC data. See Exhibit attached
22. July 2013, required the Code Virginia, SBE cooducted Annual
Training for all general registrars and electoral board members and kicked off its annual
federally required National Change Address mailing approximately 250,000 voters. SBE
provided guidance registrars the Crosscheck and other list maintenance activities the
training, weekly calls with leadership the local election ofiicials and other venues.
23. August 23, 2013, direction, Matt Davis ofSBE communicated the
general registrars message that outlined the parameters the Crosscheck program with
instructions link where general registrars could download list records that needed reviewed for possible cancellation. See Exhibit attached hereto. The email
communication stated that general registrars should review the file designated for their locality
and the information provided for each voter soon possible. The email stated that the
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 194
records were handled the same manner other out state cancellation notices that
the general registrars may receive, accordance with state laws and regulations. General
registrars were instructed accomplish final round quality checks the local level before
any official action was taken cancel registration record.
The Crosscheck process part overall mechanism provide out state
registration information registrars. Thus, SBE regularly provides general registrars with
official reports ofregistration other states under Va. Code 24.2-427(B)(iv). Since 2007,
Va. Code 24.2-427(B)(iv) has required general registrars cancel voter registration based official reports registration another state; the official report registration another
state treated equivalent voluntary request for cancellation protecting the voter from
duplicate registration, felony under Va. Code 24.2-1004.
25. implement the Crosscheck program, and direction, SBE staff worked verifying data and eventually worked the larger list over 308,000 potential matches down approximately 57,000 Virginia registered voters registered other states. Sec also the
Declaration Matthew Davis, par. 8-9. was important and therefore stressed both
the Board and staff that Virginias first attempt work with the data based upon full data
matches, thus eliminating from considerations states with large potential matching populations
like Florida, that dont use the Social Secrnity Number for voter registration.
Therefore, all voters identified the Crosscheck were matched based 00% exact match first name, last name, date birth and last four digits their Social
Security Number. Ail these fields had the same their Virginia data and the other
states data included the list. Additional data elements available the local registrar
while conducting their independent review that are the SBE voter registration database
include each voters full Virginia registration, voting and cmTespondence history.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 195
All potential duplicate registrations identified the Crosscheck are acted
only the local level. Each these voters information was sent the general registrar for
independent evaluation the voter record, which duty the general registrar under Va.
Code 24.2-114(12) and 24.2-404(A)(4).
Each voters record examined the registrar would include voting history
subsequent the reported registration another state well subsequent registration
29. registrars independent review voter record raises any question
concern, the CO!Tect practice would for
registrar make inquiry the voter.
The registrars careful independent review may result several alternative
dispositions short cancellation, including action all, sending the voter letter asking
still wants registered Virginia, and that mailing returned undeliverable, noting
the voters records for inclusion the annual address confim1ation process set forth Va.
Code 24.2-428 through 24.2-428.2
Any voter whose registration the registrar determines cancel after careful
independent review the voters record individually mailed notice cancellation inviting
him reapply eligible. Exhibit provides copy the standard fonn letter used for this
The cancellation notice mailed often both the last known Virginia
registration address record and the new state registration address reported Virginia.
Sending the cancellation notice the out state address done provide actual notice
voters who have already failed respond official request confinn their Virginia
residence address under Virginias separate annual address confomation procedure set forth
Va. Code 24.2-428 through 24.2-428.2.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 196
Some voters reported registered other states may have returned reside
Virginia new address without informing the registrar required Va. Code 24.2-424. assure these voters opportunity update address infonnation before books close for the
November election, guidance issued recommended completing action the Crosscheck
lists October 2013, allow any affected individual the opportunity respond notice cancellation before the October 15, 2013 registration deadline and for registrars make
necessary preparations for the November General Election. See Exhibit
34. sure that implementation the Crosscheck was being clone legally and
unifonnly throughout the Commonwealth, prepared and sent the entire election
community Frequently Asked Questions document. This document summarized and
formalized much the advice that staff have been providing registrars individual
statutory responsibilities, this document guided the registrars how process the Crosscheck
reports and also importantly how handle affected voters who might appear vote assure
that elii;,1ble voter was disenfranchised account error.
The Crosscheck should not disenfranchise single Virginia voter and there has
been hann caused the Crosscheck. the contrary, the Crosscheck has served
important governmental purpose cleaning the Virginia registration rolls eliminating
from the rolls over 38,000 individuals who clearly registered another state after registering Virginia.
36. summary the results the Crosscheck demonstrate both its effectiveness
and the accuracy which was implemented. After narrowing down the Crosscheck list
from over 308,000 80,000 and then 57,923 (the actual number sent the field), the
current status those 57,923 individuals: (l) 38,870 were cancelled based
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 197
upon registration another state after Virginia; (2) 138 were lctl the Virginia rolls and
are still active voters; and (3) 7,285 were left the Virginia rolls although they remain
inactive. This statewide cancellation rate percent.
37. the event that someone was removed from the voter rolls error, there are
important procedures that will protect that voters rights. Virginias provisional ballot
procedures provide !i.1rther safeguard protecting against official error the Crosscheck
review process. See Exhibit question 10. the unlikely event that qualified voter was
removed from the voter registration list, they would vote provisional ballot. That
provisional ballot should counted the canvass the day atler Election Day once the
electoral board determines that the voter eligible vote for that election. Moreover,
guidance expressly directs that even after the close books, correct official error,
registration cancelled error may reinstated.
Another important safeguard the Code Virginia voters right
administrative appeal before the registrar. Va. Code 24.2-429. unsatisfied with the result
before the registrar, the voter can further appeal the registrars ruling Circuit Court. Va.
Code 24.2-430. Despite the cancellation over 38,000 voter registrations, unaware
any case which disputed report registration
another state required hearing before
registrar judicial cmTection.
These same safeguards provisional voting and appeals often protect voters
rights when cancelled through error based upon things other than out state registration.
way example, SBE produces list deceased voters based upon data provided the
Social Security Administration. Sometimes, voter wrongfully cancelled deceased.
When that voter shows vote, his vote counted and his registration restored. Based
upon !hose fairly rare e1rors, however, SBE not going halt processing death records -1l
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 198
and should not halt the processing the cancellations issue this case.
Voters typically call SBE seek guidance and complain when they deem
necessary about actions the election community. have asked staff notify any
complaints came concerning implementation the Crosscheck. not aware one
phone call from voter who claimed have been inaccurately cancelled the Crosscheck.
The safeguards developed 2013 provide voters registered multiple states
with even greater protection than existed previously, both tenns clear direction
procedures short cancellation resolve any ambiguities and corrective measures the
event erroneous cancellation.
The Declarations filed the plaintiff this case not change view that
the Crosscheck was handled legally and appropriately. With regard Ms. Wright, was
unfortunate that she was cancelted error, but she received notice and the error was
corrected. The entire voter registration system should not discarded because human
error. officials need work minimize the chances for en-or and has done that.
The statements General Registrar Larry Haake, Ill are troubling. first
points out that half were inactive voters that were somehow problematic, but that would expected with list voters that should reviewed for cancellation (inactive voters have
already not responded least one mailing after notice from postal service authorities
move and sometimes two mailings, one uncleliverahle piece election mail and subsequent
confirmation mailing). More troubling, however, Mr. Haake then effect states that
because believed that 17% his list should have remained the rolls, that decided
unilaterally keep 83% the rolls that clearly should cancelled. This violation
his duties under the Code that require him complete his action later than days after
receipt the Crosscheck (or other) list from
Va. Code 24.2-404(4). the only
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 199
registrar the Commonwealth that refused perform his duty carefully checking the
individuals the lists. And finally and most importantly, expected Mr. Haake and all the
registrars review their lists and only cancel those registrations that should have been
With regard the other statements attributed vmious registrars, SBE never
told the Chesapeake Registrar strike the names the Crosscheck list. Contrast the
Declaration Matthew Weinstein (par. 11) and Nicholas Brana (par. with the Declaration the Chesapeake Deputy Registrar Mary-Lynn Pinkerman. Other statements the plaintiffs
declarations show the registrars are doing their duty checking the names against voter records
and other available data. With regard the few registrars that reportedly stated they had
cancelled all the voters their lists, SBE has followed with those registrars and are
satisfied that correct procedures were followed.
With regard the timing Crosscheck process, because SBE took time
perform intensive quality control measures
data, and had intervening elections, that the
data was sent the field August rather than earlier the year. Registrars then were
mandated the Code complete their work with the lists within days, giving them ample
time perform this prior Election Day and the close voter registration October 15.
Most importantly, SBE was mandated Jaw promptly send this information the
registrars and could not responsibly decide wait until after the election. See Va. Code
SBE has treated every voter equally under the Crosscheck proe,>ram and under
the Code Virginia.
Wl1en asked the registrars use their best judgment, that was not meant
imply (nor think any registrar understood that way) that registrars should not apply well
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 200
accepted standards possible cancellations. Those standards are set forth the Code and
the guidance given over many years how treat cancelations based upon relocation
another state. had and continue have confidence the registrars that they would use their
best judgment review each voter and cancel only those registrations that should
Requiting over 38,000 individuals restored the voting rolls when they
are clearly ineligible vote because they have registered another state would disruptive the upcoming election and will unnecessarily burden the election community. declare under penalty perjury that the foregoing true and correct. Executed
October 15, 2013.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 201
Inaccurate, Costly, and Inefficient
Evidence That Americas Voter Registration System
Needs Upgrade
Our democratic process requires
effective system for maintaining accurate
voter registration information. Voter
registration lists are used assign
precincts, send sample ballots, provide
polling place information, identify
and verify voters polling places, and
determine how resources, such paper
ballots and voting machines, are deployed Election Day. However, these systems
are plagued with errors and inefficiencies
that waste taxpayer dollars, undermine
voter confidence, and fuel partisan
disputes over the integrity our elections.
Voter registration the United States
largely rell.ects its 19th-century origins
and has not kept pace with advancing
technology and mobile society States
systems must brought into the 21st
century more accurate, cost-effective,
and efficient.
Research commissioned the Pew Center the States highlights the extent the
~Approximately million-one
every eight-voter registrations the
United States are longer valid
are significantly inaccurate.
More than 1.8 million deceased
individuals are listed voters.
~Approximately million people
have registrations more than one
Meanwhile, researchers estimate least million eligible U.S. citizens are
unregistered, more than percent
the eligible population.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 202
One reason for these problems that many are unlikely live one voting
precinct all our lives:
About one eight Americans moved
during the 2008 and 2010 election
Some Arne1icans-including those
serving the military, young people,
and those living communities
affected the economic downturnare even more transient. For example,
census and other data indicate that
many one four young Americans
moves given year. time when government budgets are
significantly strained, our antiquated paperbased system remains costly and inefficient. study Pew conducted with Oregon
found that, 2008, stale and local
taxpayers spent $4.11 per active voter process registrations and maintain voter list, $7.67 per transaction
(new updated registrations).
,,~m11:gj~erel ~trtii!ems nearly eligible citizens
are not registered vote.
;m!lats m1t>re:C!!lll!irti%4~A>!r tte eligil>le ~~ulation.
Canada, which uses modern
technology register people
well data-matching techniques
common the private sector,
spends less than cents per voter process regi.strations, and
percent its eligible population
Maricopa County, AZ-which
includes Phoenix and has larger
population than states-saved
more than million over five years providing online voter registration,
reducing the countys dependence
paper and manual data entry. Printing
costs were reduced percent. Each
online registration costs average cents process, compared with
cents per paper form.
These findings underscore the need
for states improve accuracy, costeffectiveness, and efficiency. described the previous report,
Upgrading Democracy: Improving Americas
Elections Modernizing States Voter
Registration Systems, Pew working
with election officials, academics, and
technology specialists help states
improve their registration systems.
Participating states will establish new
ways for voters submit information
online and join together compare
registration lists with more data
sources, using proven, secure matching
techniques and technology increase
data accuracy.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 203
The paper-based processes most
registration systems present several
opportunities for error. typical system,
election officials get information about voters identity, eligibility, address, and
contact information through form
completed public agency, such
county election office motor vehicles
office, through unregulated thirdparty voter registration group, such
campaign advocacy organization. These
are sent election offices, where the data
often are manually entered and names
are added the voter list. voter must
supply any change that information,
such new address, name, party
affiliation, which usually manual1y
entered and processed election officials.
The inability this paper-based process keep with voters they move
die can lead problems with the rolls,
including the perception that they lack
integrity could susceptible fraud.
The Pew Center the States
commissioned RT! International,
prominent nonprofit, nonpartisan
research institute, assess the quality and
accuracy state voter registration lists the United States. RT! used unique
database maintained Catalist, LLC,
leading aggregator and processor voter
information, estimate the number
records that are inaccurate longer
valid. For this report, longer valid
record represents person who the
rolls but longer eligible cast vote,
likely due having moved died.
inaccurate record represents eligible
voter whose file has incorrect data.
Catalist regularly updates its database for
all states and the District Columbia,
thus providing sound basis for making
national-level estimates longer
valid and inaccurate records, duplicate
registrations, and other important measures list quality. The organization buys voter
lists from states and local governments,
and combines that information with data
from other public and commercial sources,
such the National Change Address
database run the U.S. Postal Service, registrations are
significantly inaccurate longer valid.
1.8 million deceased individuals are listed voters.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 204
death records from the Social Security
Administration, and lists from marketing
firms and retailers used commercial
data aggregators. Catalist applies complex
matching process combine and analyze
data verify update records voters.
The resulting database contains robust
set profiles American voters and
nonvoters built from registration lists and
expanded upon with more information.
Because not all states provide complete
records, analysis Catalisls data likely
underestimates the number inaccurate
and longer valid records.
Inaccurate longer valid
The study found millions voter
registration records nationwide that are
either inaccurate longer valid. These
were identified based data indicating
voter died, moved, had been inactive from
2004 March 2011.
Number states which voter registered
Number people
2,688,046 68,725
more than
total 2,758,578
The study identified:
Approximately 12. million records
nationwide that appear out
date and longer reflect the voters
current information.
More than million records for
people who are longer living, but
have registrations voter rolls.
About million records with
incorrect addresses, indicating that
either the voters have moved, that
errors the information file make unlikely the Postal Service can reach
Once duplicates among categories are
eliminated, approximately million
registration records, nearly percent the national total, are estimated
inaccurate longer va!id.
Duplicate registrations
Matching voter information, such name,
age, and other attributes, with data from
sources such the National Change Address tllings makes possible
estimate the number people who appear hold registrations more than one
state. voter could become registered multiple
states when she moves and reregisterslegal!y-without notifying her former
state. Notice this information would
help state keep accurate rolls verifying
residence and eligibility.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 205
This study found that almost million
people appear registered two
states, and more than ,000 people could registered three more. all, more
than million people appear have
multiple registrations.
These findings are consistent with other
research. the 2008 general election,
2.2 million votes were lost because
registration problems, according
survey researchers the California
Institute Technology/Massachusetts
Institute Technology Voting
Technology Project Additionally, 5.7
million people faced registrationrelated problem that needed
resolved before voting, according the Cooperative Congressional
Election Study. Two recent studies also
found that percent percent
registration records contain errors. 2008, Oregon and Washington
compared their registration records
employing more sophisticated datamatching technique than states currently
use. They discovered slightly more than
8,000 potential matches between the
voters the two states.
Costs for printing and processing forms,
handling returned mail from inaccurate
records, maintaining registration databases,
and other expenses add millions dollars state and local budgets Lime when
government offices are struggling deliver
the highest value for every taxpayer dollar.
Registration costs are difficult
determine and analyze because state
laws vary and the division electionadministration responsibilities between
stale and local officials can differ.
officials continue offer new and
innovative ways participate
elections, evaluating and comparing
administrative costs has become
challenging but important exercise.
The Oregon case study
Working closely with state and local
election officials, Pew conducted firstof-its-kind assessment registration
costs, every level government,
single state. are
million registration records,
inaccurate longer valid.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 206
Pew asked Oregon.s state election officials
and its county clerks isolate their
registration expenses from other costs related conducting elections for 2008.
Wyoming spends million per year the
vendor contract for its statewide registration
database. With quarter million active
voters the state, Wyoming spending per active voter just maintaining its
database, before other registration costs are
The cost estimates the counties, secretary states office, and state agencies were added determine statewide cost. This total was
divided the number registered voters
These costs not include the millions spent
for the 2008 general election determine the every election cycle advocacy groups,
community organizations, and political
cost per voter, and all new and updated
registrations recorded Oregons centralized campaigns register voters outside the direct
system determine cost per transaction.
supervision election officials, what
such groups spend private vendors
update lists rife with errors.
The study found that registration Oregon
cost taxpayers more than $8.8 million
during the 2008 election-more than $4.11
per active voter registered, $7.67 per
registration t.ransaction.
Costs U.S. times higher than Canada
The costs maintaining voter list the
United States are high when compared
with our neighboring democracy, Canada,
which spends only cents per active voter create and maintain its lists federal
election year-one-twelfth the cost the
According survey election budgets
the United States conducted the Caltech/
MIT Voting Technology Project, county and
local election offices spend approximately
one-third their budgets just voter
registration. some jurisdictions, the total even higher.
Election officials administer system that fundamentally inefficient number
They generally not have access
modern data-matching techniques
used private industry and other
government agencies compare
records readily available databases
and minimize inaccuracies caused
Americans mobility
They are relegated reacting
incoming information from voters and
third-party organizations, comes them all. Additionally, much presented with inaccuracies and
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 207
INACCURATE, COSTLY, AND INEFFICIENT concentrated period right before
election, when they are responsible
for all other aspects election
They typically receive information
paper that must entered manually
into the voter systems, greatly
increasing the potential introduce
voter registration transaction and ... while
driver license transactions increased,
voter registration transactions fell only
6.5% all driver license transactions
from 2009-20.10.
Additionally, 2008, more than two
million provisional ballots-issued when
voter encounters problem the pollswere cast, requiring election officials
Millions Americans are unaware these
verify each voters eligibility and determine
problems. According the Cooperative
whether their vote counted. Almost half
Congressional Election Study (CCES), the
the uncounted ballots for which there are
largest national survey voter experiences,
detailed data were rejected because the voter
one four voters interviewed about Election was not the registration rolls.
Day 2008 assumed that election officials
the U.S. Postal Service update registrations
The problems with the current
automatically with each move, even
though that almost never the case. The
According data from CCES, people who
same survey found that more than half
moved within the two years preceding
voters were unaware that they could revise
election are most likely have registrationtheir registration information state motor
related difficulties the polls. Mobility
vehicle agencies, mandated the vast
issues particularly affect military personnelmajority states the National Voter
especial1y those deployed overseas and their
Registration Act (NVRA)n
families-who were almost twice likely report registration problems was the
Still, even among those who try register
general public 2008. motor vehicles agency, the results are
mixed, best. For example, nearly
Clark County, NV, which includes Las
percent those who attempted register
Vegas and has been particularly hard hit Maryland Motor Vehicle Administration
home foreclosures, good example the
office 2007-2011 did not make onto the
burden mobility puts election officials.
states voter rolls- Ohio, while requesting six-month period, spanning the end
improved NVRA compliance from Ohios 2009 and the beginning 2010, more
Bureau Motor Vehicles, the secretary
than 150,000 its nearly 700,000 active
state noted that:
registered voters-more than percentmoved from the address file with the
... from 2007-2008 only 9.6% all
county election office.
driver license transactions resulted
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 208
Data released the U.S. Election
Assistance Commission 2011
emphasize the inefficiencies resulting
from our current system. The data
show that the most common reason for
removing person from the voter rolls not that the person provided new
information, but merely that they did not
vote for two consecutive election cycles. other words, officials must react the
absence information.
The burden last-minute,
third-party information
Third-party organizations are most active
close election, and thus submit
millions paper applications just before
registration deadlines. Voter lists rely
upon the information solicited these
groups, but voter moves, election
officials are unlikely learn it,
all, until immediately before the next
registration deadline, when paper forms
again flood election offices.
Far too often, the submitted registration
forms are incomplete, present
duplicate conflicting information. response, local election officials must
redirect limited resources hiring large
numbers temporary data-entry staff
manually process and verify applications.
This comes particularly busy time
when other tasks, such recruiting and
training poll workers and preparing for
Election Day, must done.
Eligible citizens who remain
unregistered difficult for election officials keep with voters who are the
rolls, the system similarly inefficient getting people onto them the first
place. RTI compared the registeredvoter data analyzed from Catalist with
estimates the total U.S. voting-eligible
population. RT! determined that
could quantify the number people
who are eligible but not listed the
rolls. The data indicate that least
million citizens appear unregistered the United States, more than percent the eligible population
Conversely, Canada, which uses
innovative technology and data-matching
methods, has percent its eligible
voters the rolls.
IMll~ill~~ il~l~I
mm~111m11~~ 1t~1~
The Pew Center the States working
with states upgrade voter registration
systems improve the accuracy
records, streamline processes, and
save money, while enhancing the rolls
integrity This effort builds initiatives
already place some jurisdictions.
With guidance from working group experts, including election officials,
academics, and technology specialists
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 209
from more than states, Pew developed comprehensive plan that uses methods
already place the private sector and
other areas government modernize
voter registration. The approach consists
three core elements: Comparing registration lists with
other data sources broaden the
base information used update
and verify voter rolls. Using proven data-matching
techniques and security protocols
ensure accuracy and security: Establishing new ways voters can
submit information online and
minimize manual data entry, resulting lower costs and fewer errors.
sophisticated technology improve the
accuracy, integrity, and cost -effectiveness
the registration process.
Learn more about Pews plan for
modernizing state voter registration
systems onr report, Upgrading
Democracy: Improving Americas
Elections Modernizing States Voter
Registration Systems.
STAY CONNECTED,m/pewstates
Too,rpew combining these elements, states can
phase out many laborious, wasteful,
and error-prone procedures and use
The views and opinions expressed this report are those the author and not necessarily reflect
represent the views and opinions held Catalist Any views expressed the media connection
with this report are solely those the indlviduals organizations expressing such views.
Endnotes The Pew Center the States commissioned RTI U.S. Census Bureau, Geographic Mobility: 2011,
International, nonprofit, nonpartisan research
November 2011,
institute, assess the quality and accuracy state
migration/data/cps/cps201 l.html.
voter registration lists the United States using database maintained Catalist, LLC, leading
aggregator and processor voter information. For the full report, see: The Real Cost Voter
Reg~tration: Oregon Case Study (Washington
Pew Center the States, March 2010); http://www. Ibid. See: U.S. Census Bureau, Mover Rate Reaches Pew Center the States
Record Low, Census Bureau Reports, Nov. 15, 201
with Rennie Molnar, associate deputy director chief
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 210
electoral officer, Elections Canada, December Many voter records fall into two more the
2009. Additional context information was presented
problematic categories examined, which why the
in: Rennie Molnar, Operational Aspects Canadas
number problematic records less than the sum
National Register Electors, PowerPoint presentation
each the subcategories.
given Voter Registration Modernization: Case Study the Canadian Systems Voter Registration, meeting
hosted the Pew Center the States cooperation
with the International Foundation for Electoral
Belinsky; Gabriel Lenz; Charles Stewart III and Thad
Systems, Toronto, Canada, June 4-5, 2009. Matt Barreto, Loren Collingw-ood, Bonnie Glaser,
Karin Mac Donald, Francisco Pedraza and Barry Pump,
Online Voter Registration (OVLR) Systems Arizona and
Washington: Evaluating Public Usage, Public Confidence
and Implementation Processes (Washington, DC: Pew
Center the States, April 2010), 93. See Tom Wrobleski, City Board Elections seeks clear ineligible voters from its rolls, Staten Island
Today, August 17, 2011;
index.ssU201 l/08/city_board_of_elections_seeks.htinl
and Quin Monson, Children and Dead People are
NOT Voting Utah, Utah Data Points, August 16,
2011; le-are-not-voting-in-u tah/. States store and process registration data differently,
and often restrict the amount data provided
Catalist protect voters privacy; for example, some
states provide only month and year for date birth
rather than the full date. Many official records that
could contain inaccuracies, might identify voter having moved died, could thus unidentified
because the original file does not contain enough data match with confidence updated information from
other sources. Such record would considered Michael Alvarez, Stephen Ansolabehere; Adam
Hall, 2008 Survey the Performance American
Elections, Final Report (2008). Available http://!uploadedFiles/
Final%20report20090218.pdf. Stephen Ansolabehere, Voting Experiences,
PowerPoint presentation, July 30, 2009. This
presentation reported findings originally published the Cooperative Congressional Election Study
(Cambridge, MA: Common Content, Release 2009). Stephen Ansolabehere and Eitan Hersh, The
Quality Voter Registration Records: State-by-State
Analysis, (Cambridge, MA: Harvard University, 2010);
Stephen Ansolabehere, Eitan Hersh, Alan Gerber and
David Doherty, Voter Registration list Quality Pilot
Studies: Report Detailed Results and Report
Methodology, (Washington, DC: Pew Center the
States, June 2010). Michael Alvarez, Jeff Jonas, William Winkler
and Rebecca Wright, Interstate Voter Registration
Database Matching: The Oregon-Washington 2008
Pilot Project, (Pasadena, CA: California Institute
TechnologyMassachusetts Institute Technology
Voting Technology Project, August 10, 2009)
working_paper/wp_84_pdf_4acf7a04 3a. pdf.
accurate and active until more data might indicate For the full report, see The Real Cost Voter
Registration: Oregon Case Study (Washington DC:
Pew Center the States, March 2010); http://www.
pewcenteronthestates.orglreporLdetail.aspx?id=564 78. Catalist uses classifications established the
U.S. Postal Service gauge address accuracy and Costs incurred Oregon counties register
mailability. The Postal Service has six categories
people and maintain the voter list included mailings
for addresses, from the most accurate information
and notices voters; full-time and part-time information that cannot verified, including:
staff; facilities and county administrative support;
mailable possibly deliverable unverified. The
included allocating the costs spent registration
available the Postal Services master list addresses.
telephones; faxes; and desktop computers. State costs
final category denotes that mailability information personnel the secretary states office and
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 211
assisting agencies under the National Voter Registration Harvard Lomax, registrar Clark County, NV,
Act such the Department Motor Vehicles and
personal communication, April 30, 2010; and Harvard
the Department Human Services, support and, Inactivation Voters Clark County,
maintenance the centralized registration system,
Memorandum-Election Department, Nevada Secretary
printing and distribution registration cards, State, March 12, 2010.
maintenance Web site where voters can check the
status their registration, and other expenditures. The
technology costs principally involve maintaining and
supporting the centralized registration system. Fully percent people removed from state lists
were removed for failure vote, according data
compiled the U.S. Election Assistance Commission.
The second-highest reason for removal-moved Caltech/MIT Voting Technology Project, Voting:
outside jurisdiction--comes around percent.
What Is, What Could Be, July!, 2001, 51; http://www.
See The Impact the National Voter RegLstration Act
1993 the Administration Elections for Federal Office
2009-2010 (Washington, DC: U.S. Election Assistance Peggy Nighswonger, state election director Wyoming
Commission, June 30, 2011); table 4b.
Secretary State Office, personal communication, Feb.
IO, 2010. Elizabeth Williamson and Brody Mullins,
Democratic Ally Mobilizes Housing C111nch, The
Wall Street journal, July 31, 2008;
article/SB1217 45181676698197.html. Michael Falcone and Michael Moss, Groups
Tally New Voters Was Vastly Overstated, The New
York Times, October 23, 2008; http://www.nytimes.
com/2008/10/24/us/politics/24acorn.html. Additionally,
Rock the Vote said helped 2.6 million people
register via its online tool, grassroots efforts and direct Cooperative Congressional Election Study (Washington,
mail efforts 2008. See also http://www.rockthevote.
DC: The Pew Charitable Trusts Content, 2008).
corn/about/rock-the-vote-2008-prograrn/. !bid. Stephen Ansolabehere, David Doherty, Alan Gerber,
and Eitan Hersh, Voter Registration List Quality Pilot Annie Linskey, Nearly percent MVA voter
Studies: Report Detailed Results (Washington, DC: Pew
registrations fail, The Baltimore Sun, February 20, 2011.
Center the States, June 2010). Jon Husted, Ohio Secretary State, letter The estimates voting-eligible population are
Thomas Charles, director, and Mike Rankin,
produced Michael McDonald George Mason
registrar, Ohio Department Public Safety, August 16,
University, and are available his United States
2011. Provisional Ballots: Imperfect Solution
(Washington, DC: Pew Center the States, July
detail.aspx?initiative1D=54 789. Cooperative Congressional Election Study (Cambridge,
MA: Common Content, Release!, 2009).
Elections Project website
index.htinl. McDonald estimates the voting-eligible
population taking into account voting age, non.citizenship rates, felony disenfranchisement, and other
factors. Molnar, Operational Aspects Canadas National
Register Electors, PowerPoint presentation given Voter Registration Modernization: Case Study the Cooperative Congressional Election Study (Washington,
Canadian Systems Voter Registration, Toronto, Canada,
DC: Pew Charitable Trusts Content, 2008).
June 4-5, 2009.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 212
Pews Elections Initiatives supports innovative research and partnerships achieve the
highest standards accuracy, cost-effectiveness, convenience, and security Americas
system election administration.
The Pew Center the States div1sion The Pew Charitable Trusts that identlfles and
advances effective solutions critical issues facing states. Pew nonprofit organization
that applies rigorous, analytical approach improve public policy, inform the public,
and stimulate civic life.
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 213
The State Board Elections Board Meeting was held Wednesday, April
2013. The meeting was held the General Assembly Building, Room Richmond,
Virginia. attendance, representing the State Board Elections (SBE) was Charles
Judd, Chai:; Kimberly Bowers, Vice Chair; Donald Palmer, Secretary; Joshua Lief,
Senior Assi.stant Attorney General and SBE Counsel; Justin Riemer, Deputy Secretary;
Nikki Sheridan, Confidential Policy Advisor; Chris Piper, Election Services Manager;
Matthew Davis, Information Services Manager; Susan Lee, Election Uniformity
Manager; Sharon Woo, Business Manager; and Matt Abell, Election Services Lead.
Chairman Judd called the meeting order O:OOAM.
The first order business was the approval the Minutes from the State Board Election~. Board Meeting held January 2013. After careful review, Chairman
Judd made
the Board u1animously approved the Minutes.
motion approve the Minutes. Vice Chair Bowers seconded the motion and
The second order business was the Secretarys Report delivered Secretary
Palmer. The Secretarys Report agenda item for each Board meeting describing
recent deveopments SBE. Secretary Palmer reported that testing for the ESS 3.4.0.
which inclu.des the DS850 high speed scanner occurred SBE. Secretary Palmer stated
that SBE awaiting the final results and report testing. Secretary Palmer introduced
Ray Alexander, the new SBE Grants Manager, and extended warm welcome Mr.
Alexander. Secretary Palmer reported that the Governor signed SB1256, photo
identificaticn bill, and that the Governor also issued Executive Order outlining
parameters implementation. Secretary Palmer reported that SBE will working
closely with localities the implementation 1256. Secretary Palmer reported that
there will
will working with stakeholders during all the phases the outreach program.
Secretary Palmer reported that HB234 online voter registration, also passed and SBE
believes that this process will streamline the voter registration process and help improve
the integrit. the voter registration database. Secretary Palmer reported that July
2013 will the implementation date the line electronic registration process.
Secretary Palmer reported that HB2341 will also help voters update their registration
b:~ voter outreach program associated with Executive Order and that SBE COMMONWEALTHS
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 214
information, reduce delays the mailing process, and reduce the amount paper used
the registration process. Secretary Palmer repo1ied that with the passage 1008,
training will required for groups and individuals who wish receive more
registration applications from SBE local general registrars office. Secretary Palmer
stated that training will available online and person the SBE classroom.
Secretary p11mer repmied that with the passage ofHB2022, Virginia will able share
and receiv~ information potential dual registrations Virginia and other states.
Secretary Palmer reported that with the passage 1229, the State Board Elections
will renamed the Department Elections with the position Commissioner
Elections heading the agency and that transition will also change the makeup the SBE
Board. Vice Chair Bowers followed the Secretarys report with some questions
regarding implementation SB1256, including query the financial burdens placed the locaiities result the new law. Secretary Palmer stated that the Governor
encouraged; localities get involved the outreach program and that monies were
appropriate1.l SBE pay for the outreach and installation equipment and production the free photo cards that would available voters who not already possess
acceptable photo ID.
The next order business was the Legal Report delivered Joshua Lief, Senior
Assistant Attorney General and SBE Counsel. The Legal Report agenda item for
each Board Meeting describing non privileged legal issues involving SBE. Mr. Lief
reported .it the Attorney Generals ballot access package presented the General
Assembly passed. Mr. Lief reported that his office working the preclearance
documents .needed support the bills that the Governor has signed. Mr. Lief reported
that the Supreme Court decision Section the Voting Rights Act expected this
summer. Mr. Lief reported that there are two pending cases; the Libertarian Party case
which the court appeals and the Failfax County Democratic Party case against
SBE and the General Registrar Fairfax County.
The next order business was the General Registrar requests for temporary full-
time status for Charles City and Mathews Counties. Deputy Riemer informed the Board
Members fie Electoral Boards submitted the required requests timely manner.
Deputy Ri(mer noted the requests are authorized under Chapter 890, 2012 Acts
Assembly and SBE recommended approval the submitted requests. Vice Chair Bowers
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 215
moved the Board approve the request from the Electoral Board the Charles City
County for the months April, May, and June 2013. Chairman Judd asked there were
any questions. Robin Lind, Virginia Electoral Board Association, stated that was
appreciative the support SBE Board Members provide approving these requests.
Secretary P:ilmer seconded the motion and the Board unanimously approved the motion.
Secretary P,almer moved approve the request from the Electoral Board Mathews
County for the months May and June 2013. Vice Chair Bowers seconded the motion
and the Bonrd unanimously approved the motion. Chairman Judd asked there were any
comments there were none.
The next order business was the drawing the ballot order for the June 2013
Primary Election. Matt Abell, Election Services Lead, explained the process. Mr. Abell
stated that the drawings were for the Lieutenant Governors ballot position the June
2013 Democratic Primary. Vice Chair Bowers drew the first position Ralph Northam
and Secretary Palmer drew the second position Aneesh Chopra. Mr. Abell stated that
there will second drawing for the Republican Primary House District 85. Vice
Chair Byler. C1airman Judd noted that Scott Taylor would placed the third position result his fillings occurring after the simultaneous filings Mr. Walters and Mr.
drew the first position ofT. Jeremy Walters, Secretary Palmer drew Gary
The next order business was the approval the Campaign Finance Summaries
presented Chris Piper, SBE Election Services Manager. Mr. Piper stated that 24.2-
946 the; Code Virginia requires the State Board Elections summarize the
provisions fthe Campaign Finance Disclosure Act of2006 and prepare the summary for
distribution candidates and committees upon request the time that they first
register with agency. Mr. Piper stated that July 2012 the Board approved numerous
updates the Candidate Campaign Committee Summary Laws and Policies. Mr.
Piper stated that the most significant updates were the procedure and civil penalty
schedule for late and fail file campaign finance reports well the incomplete
report policy. Mr. Piper stated that documents provided for Board review conform the
political cmnmittee summaries. Mr. Piper thanked SBE staff member Lindsay Fraser for
her assistm,ce preparing the documents. Chairman Judd asked there were any
comments and there were none. Secretary Palmer moved that the Board approve the
Case 1:13-cv-01218-CMH-TRJ Document 23-1 Filed 10/15/13 Page PageID# 216
proposed update the Political Committees Summary Campaign Finance Laws and
Policies. Vice Chair Bowers seconded the motion and the Board unanimously approved
the motion.
The next order business was the Request Waive Civil Penalties presented
101 Chris Piper, SBE Election Services Manager. Mr. Piper identified the matter for Board
consideraticm the complaint against the American Fire Sprinkler Association Virginia
Chapter (PAC 12-00120). Mr. Piper informed the Board that the committee was
penalized October 16, 2012 for not filing their campaign finance report due October
15, 2012 in!a timely manner. Mr. Piper stated that the committee requests waiver the
penalty due hospitalization relative. Mr. Piper stated that staff recommends
waiving the $100 penalty assessed the request not conflict with official Board
policy stating that extenuating personal circumstances committee treasurer good
cause allowing Board waiver campaign finance civil penalties. Chairman Judd
inquired ,here were any public comments and there were none. Chairman Judd moved
111 waive thr: penalty assessed PAC 12-00120, Vice Chair Bowers seconded the motion
and the Boa.rd unanimously approved the motion.
The next order business was the 2013 Homeland Security Award and Letter
presented Secretary Palmer. Secretary Palmer stated that SBE received this award
from the Secretary Veterans Affairs and Homeland Security. Secretary Palmer thanked
SBE staff members for the preparations leading the general elections and stated that
those prepa. :ations contributed this recognition.
118 order business was the staff report the Interstate Voter Registration
Crosscheck,Program and Electronic Registration Information Center (ERIC) presented
Matthew Davis, Information Services Manager. Mr. Davis stated that 2012 SBE
entered intc agreement share voter registration data with other states. Mr. Davis
stated that (his data sharing was designed look for duplicate registrations. Mr. Davis
reported that the results this data sharing showed matches based last name, first
name, and date birth for over 308,000 possible duplicate registrations. Mr. Davis stated
that SBE h