U.S. DISTRICT COURTS UPHOLD RESTRICTIVE BALLOT ACCESS LAWS IN GEORGIA AND OKLAHOMA

On April 30, U.S. District Court Judge David Russell upheld Oklahoma's petition requirement for independent presidential candidates, which is so difficult it hasn't been used since 1992. And on May 26, U.S. District Court Judge Robert L. Vining upheld Georgia's petition requirement for independent candidates for U.S. House, which is so difficult, it has not been used since 1964. Both decisions ignore the U.S. Supreme Court decisions that say the constitutionality of ballot access laws should be judged by often they are used. Both the Oklahoma and Georgia cases will be appealed. Fortunately, in each case, the record has the needed historical facts.

In 1968, the U.S. Supreme Court struck down Ohio's procedures for new parties and independent candidates, noting that they had not been used (for president) in the 17 years since they had existed.

In 1971, the Supreme Court upheld Georgia's laws for independent candidates, and the candidates of unqualified parties, noting that they had been used statewide in 1966 and 1968 (the 1966 instance was a Republican Party petition; the law required Republicans either to petition, or to administer their own primary).

Therefore, from the beginning of federal ballot access jurisprudence, the key factor in judging whether a ballot access law is too hard is whether it gets used or not.

In 1974 the Court made it explicit. In Storer v Brown, 415 U.S. 724, the Court said, "There will arise the inevitable question for judgment: could a reasonably diligent independent candidate be expected to satisfy the signature requirement, or will it be only rarely that the unaffiliated candidate will succeed in getting on the ballot?

"Past experience will be a helpful, if not always an unerring, guide: it will be one thing if independent candidates have qualified with some regularity and quite a different matter if they have not." (page 742). Because the record did not say how often independent candidates had qualified in California, the Court sent the case back to lower courts and said to re-hear it. However, no court ever re-heard it, since California's legislature then voluntarily eased independent candidate ballot access, and the case was dismissed by the plaintiffs.

The Supreme Court applied the usage test again in 1977, in Mandel v Bradley, 432 U.S. 173. The record in that case also lacked data on how often independent candidates had qualified in Maryland. Once again, the Court sent the case back to lower courts and said to re-do it. The lower court then struck down Maryland's March petition deadline.

In 2008, Justice Scalia mentioned the usage test in his concurrence in Crawford v Marion County Election Board. He said, "In Storer v Brown we observed that the severity of the burden of a regulation should be measured according to its ‘nature, extent, and likely impact. We therefore instructed the District Court to decide on remand whether a reasonably diligent independent candidate could be expected to satisfy the signature requirements, or will it be only rarely that the unaffiliated candidate will succeed in getting on the ballot?"

Also, in 1983, the Supreme Court had said in Anderson v Celebrezze, 460 U.S. 780, that when a lower court is judging whether a ballot access law is constitutional or not, it "must identify and evaluate the precise interests put forward by the State as justifications for the burden imposed by the rule.

"In passing judgment, the Court must not only determine the legitimacy and strength of each of those interests, it also must consider the extent to which those interests make it necessary to burden the plaintiff's rights. Only after weighing all these factors is the reviewing court in a position to decide whether the challenged provision is constitutional." (page 789).

Neither the recent Oklahoma decision, not the recent Georgia opinion, mentioned any of these opinions. Nor did either decision mention any of the evidence. The Oklahoma decision is eight pages and the Georgia decision is three pages. They merely said that the laws at issue had been upheld in the past.

The Oklahoma case is Barr v Ziriax, civ-08-730-R. Judge Russell is a Reagan appointee. The Georgia case is Coffield v Handel, 1:08-cv-2755. Judge Vining is a Carter appointee.

The evidence in the Oklahoma case includes the fact that Oklahoma is the only state in which voters have not been permitted to vote for president at either of the last two general elections, unless they vote for the Republican or Democratic nominee.

The evidence in the Georgia case includes the fact that not only has no independent completed the 5% petition requirement since 1964, but also that back in 1964 petitioning was much easier for U.S. House because no county except Fulton County was split into more than one district. U.S. House petitions always have low validity rate when the boundaries of the districts are complicated and not keyed to county boundaries, because people know what county they live in but generally they don't know which U.S. House district they live in. Also, back in 1964, the deadline was October and petitions were not checked.

Judge Sonia Sotomayor, President Obama's choice for U.S. Supreme Court, has a good record on most of the ballot access cases that have come before her.

She was the first federal judge to give any relief whatsoever to any write-in candidate, after the U.S. Supreme Court had ruled in 1992 that states are not required to permit write-ins if their ballot access laws are easy. Lower courts then seemed to interpret this as a signal that no lawsuit concerning write-ins could ever win. For example, in 1993, U.S. District Court Judge David Russell had upheld Oklahoma's ban on write-ins, even though Oklahoma has very tough ballot access laws for president.

But in 1995, Judge Sotomayor ruled partially in favor of Irving Gelb, a write-in candidate in the Democratic primary for Bronx Borough President. He had filed a federal lawsuit complaining that New York City was not printing write-in space on primary ballots for certain offices, and also that they weren't permitting write-ins on absentee ballots. Most federal judges would have dismissed his case, but Sotomayor kept it alive (Gelb v Board of Elections, 888 F Supp. 509). Gelb was a pro se taxi driver. Eventually he lost his first case because the Board of Elections claimed that it would do better next time. However, the Board did not improve its procedures, so in 1997 Gelb filed a second case (which went to another judge) and won.

In 2006, Sotomayor voted to strike down New York's ballot access laws for candidates for Delegate to party judicial nominating conventions, in Lopez Torres v Board of Elections, although she didn't write that decision. In 2008 the U.S. Supreme Court reversed that decision.

Unfortunately, in 2006, she voted to deny injunctive relief in a case challenging the New York definition of "political party". Person v Board of Elections, 467 F.3d 141. No one knows who wrote that decision, since it is only signed "per curiam."

Carl Person, who was a member of the Green Party, had filed a lawsuit saying that since the Green Party of New York had polled over 50,000 votes for some statewide offices in 2002 (but not the required 50,000 votes for Governor), the party should be on the ballot automatically for 2006.

Person was not a Green Party candidate, nor an officer of the party, and the Court should have said he lacked standing. Instead it said that the definition of "political party" (requiring 50,000 votes for Governor) is probably constitutional because otherwise the ballot would be too crowded. No evidence had been submitted in that case about the increase in the number of parties if the law had covered any statewide race instead of just Governor.

Assuming Sotomayor is confirmed by the Senate, she will probably be a good justice for minor parties. She is socially acquainted with some Independence Party activists in New York city. When the White House annouced her selection, the press release said, "Her favorite project is the Development School for Youth Program, which sponsors workshops for inner city high school students. Every semester, approximately 70 students attend 16 weekly workshops that are designed to teach them how to function in a work setting."

The Development School for Youth Program was created out of the Allstars Talent Show Network in New York city, by Lenora Fulani and her associates. One reason the U.S. Supreme Court has been so unhelpful to minor parties and independent candidates is that (probably) none of the justices is socially acquainted with any minor party members or activists. Sotomayor appears to be someone who does know people who believe in election activity outside the two major parties. And even without such acquaintanceship, any judge from New York state is likely to be far more accepting of minor parties than judges from intolerant states such as Georgia or Illinois, the home states of other prospects who were on Obama's short list.

The Oklahoma bill to ease ballot access for new or previously unqualified parties passed both Houses of the legislature, but the two houses passed different versions. Then the legislative conference committee failed to agree on one version of the bill, and the legislature adjourned. However, Oklahoma has two-year legislative sessions, so the bill will receive attention in January 2010. The bill is HB 1072. The Senate version of the bill would have lowered the number of signatures from 5% of the last vote cast, to 3% of the last gubernatorial vote. The House version was 5% of the last gubernatorial vote.

Oklahoma did make it easier for initiatives to get on the ballot this year. On May 26, the Governor signed SB 800, to provide that any challenge to the substance of an initiative proposal must be settled before the proponents collect the signatures. Also passing this year was SJR 13, which lowers the number of signatures for a statutory initiative from 8% of the last vote cast, to 8% of the last gubernatorial vote. Since the number of signatures is in the State Constitution, SJR 13 will not take effect unless the voters vote for it in November 2010.

A third bill also passed the legislature to ease ballot access for initiatives. It is HB 2246, cutting the number of dats for an initiative petition from 90 days to one year. Governor Brad Henry has until June 7 to sign or veto that bill.

On May 8, West Virginia Governor Joe Manchin signed HB 2981, the bill that improves ballot access. This bill is certainly the most significant improvement in ballot access made by any state legislature this year. It moves the non-presidential petition deadline from May to August, and cuts the number of signatures from 2% of the last vote cast, to 1%.

Arizona: the Secretary of State plans to amend SB 1091 (his omnibus election law bill) to move the independent presidential petition deadline from June to early September. The bill will also be amended to say that out-of-state circulators may work for an independent presidential candidate. However, the bill will not change the existing ban on out-of-state circulators for other types of petitions. The motivation for these changes is because Arizona lost the lawsuit Nader v Brewer last year.

Louisiana: HB 420, giving independent presidential candidates a somewhat later deadline for getting on the ballot, has passed the House Committee on House & Governmental Affairs and is set for a vote in the House on May 29. Existing law reaquires the paperwork by the first Tuesday in September; the bill changes that to the first Friday after the first Tuesday in September.

Maine: LD 1169, making it easier for a voter to cast a write-in vote, passed the legislature on May 26. It deletes the requirement that the voter include the candidate's town. LD 1041, which eases the test for a party to remain ballot-qualified, has passed the Legal & Veterans Affairs Committee.

Oregon: SB 326, which makes it possible for primary voters to sign an independent candidate's petition, passed the Senate on May 14.

Texas: HB 1193, which gives qualified parties more time to certify the names of their presidential and vice-presidential nominees, passed the legislature on May 26.

Since the May 1 B.A.N., bills to establish the National Popular Vote Plan for presidential elections have passed the Connecticut House, the Rhode Island Senate, and been signed into law in Washington.

On May 7, the Libertarian Party and the Green Party filed a federal lawsuit over many New Mexico ballot access laws and practices. Woodruff v Herrera, cv-09-449. Alan Woodruff, the lead plaintiff, is a Libertarian nominee for U.S. House in 2010. One of the other co-plaintiffs, Daniel Fenton, wants to run for U.S. House in 2010, but he is not registered to vote, so New Mexico law does not permit him to qualify. However, New Mexico is in the 10^th circuit, and in 2001 the 10^th circuit ruled that states cannot require candidates for Congress to be registered voters.

The lawsuit also attacks the refusal of the New Mexico Secretary of State to supply petition forms for new parties to qualify, or petition forms for their nominees to qualify, until October of odd-numbered years. New Mexico is the only state that requires one petition to qualify the party, and then additional petitions from each of that party's nominees. No law controls when either of these types of petition may begin to circulate, but the Secretary of State refuses to let groups create their own petitions, and she won't let them have the state petition forms now.

There are many other issues in the case also, including the Secretary of State's refusal to put a "straight-ticket" device on the ballot for any parties other than the two major parties, a practice started in 2006. The lawsuit has been assigned to Judge William Johnson, a Bush Jr. appointee.

Louisiana: HB 776 was defeated on May 27. It would have eliminated the primary for small qualified parties. Oddly, it would not have authorized any other means for them to nominate. The bill was defeated in Committee after witnesses from the Libertarian Party, the Green Party, the NAACP, and College Republicans testified against the bill.

Minnesota: SF 1331 was vetoed by the Governor on May 22. It would have moved petition deadlines for independent and minor party candidates to earlier dates. The non-presidential petition deadline would have moved from July to June; the presidential petition from September to August; and the petition to recognize a new party from May to April.

On May 18, the U.S. Supreme Court refused to hear Stevo v Keith, 08-1187, the case challenging the number of signatures for independent candidates for the U.S. House in Illinois. Illinois requires exactly 5,000 signatures in years ending in "2", but approximately 10,000 in other years.

The chart below lists each state, and tells the most recent year in which a minor party or independent candidate won a lawsuit to have a ballot access law declared unconstitutional.

The news in this issue of B.A.N., regarding court decisions on ballot access, is not good. But the chart shows that lawsuits are effective for making progress against restrictive ballot access laws, over time. Note that 47 states have had at least one ballot access law (relating to minor parties or independent candidates) declared unconstitutional. And it is possible that pending lawsuits against Montana and New Hampshire laws will also win. If so, that would leave Mississippi as the only state in which no minor party or independent candidate has won a constitutional lawsuit. Mississippi has such a tolerant law for minor parties, this is no surprise. Ever since Mississippi created the government-printed ballot in 1890, the state has let any party onto the ballot as long as it registers with the state. No petition is needed. And for independent candidates, no independent ever needs more than 1,000 signatures.

STATE	YEAR	CASE NAME AND HOLDING
Ala.	1991	New Alliance Party v Hand: April deadline for new party petition is too early
Alas.	1983	Vogler v Miller: 10% vote test for a party to remain on the ballot is too difficult
Ariz.	2008	Nader v Brewer: June deadline for independent candidate petition is too early
Ark.	2006	Green Party v Daniels: 3% petition for a party to get on the ballot is too difficult
Calif.	1988	Fulani v Eu: 60 day period for independent presidential petition is too short
Colo.	2001	Campbell v Davidson: state can't require a candidate for Congress to be a registered voter
Conn.	1992	A Ct. Party v Kezer: state must let a new party run for Justice of the Peace
Del.	1976	McCarthy v Tribbett: state must have procedures for independent candidates
D.C.	1974	Kamins v Bd. of Elections: state must print write-ins space for president on November ballots
Fla.	1992	Fulani v Krivanek: state can't charge to check signatures of minor political party
Ga.	2002	Parker v Barnes: state can't require normal number of signatures when petitioning period is shorter
Hi.	1973	Peoples Party v Ariyoshi: petition to qualify new party can't have county distribution requirement
Ida.	1976	McCarthy v Andrus: state must have procedures for independent presidential candidates
Ill.	2006	Lee v Keith: December of year before election for independent candidate petitions is too early
Ind.	1983	Warrick v Condre: February petition deadline for new party petitions is too early
Iowa	1992	Oviatt v Baxter: can't require more signatures for office in part of state than for statewide office
Kan.	2002	Natural Law Party v Thornburgh: must let party have two words in its name
Ky.	1991	Libertarian Party v Ehrler: February deadline for new party candidate petitions is too early
La.	1979	Socialist Workers Party v Hardy: oath that candidate is not a subversive person is unconstitutional
Me.	1999	Stoddard v Quinn: April deadline for independent candidates is too early
Md.	2003	Maryland Green Party v Bd Elec: state can't require party nominees to submit a petition
Mass.	1985	Serrette v Connolly: May deadline for independent candidates is too early
Mich.	1984	Goldman-Frankie v Austin: state must have procedures for indp. candidates for state office
Minn.	2004	Candidacy of Independence v Kiffmeyer: state can't require minimum number of votes in primary
Miss.	- - -	never
Mo.	1976	McCarthy v Kirkpatrick: April petition deadline for independent candidates is too early
Mt.	- - -	never
Neb.	1984	Libertarian Party v Beermann: petition for new party can't say signers pledge to support that party
Nev.	1992	Fulani v Lau: June petition deadline for new parties, independent candidates, is too early
N.H.	- - -	never
N.J.	2007	Green Party v State: out-of-district circulators must be allowed to petition
N.M.	2004	Gladstone v Vigil-Giron: pres. cand. may run in some states as an indp and in others as pty nominee
N.Y.	2004	Chou v Bd. Elections: out-of-district circulators must be allowed to petition
No.C.	2004	DeLaney v Bartlett: can't require more signatures for a statewide indp. than for a new party
No.D.	1980	McLain v Meier: 15,000 signatures is too many for a new political party
Ohio	2008	Nader v Blackwell: state can't bar out-of-state circulators
Okla.	1984	Libertarian Party v Elec. Bd: 90 day period is too short for new party petition
Ore.	2002	Freedom Soc. Party v Bradbury: party can use its own name even if is similar to another party name
Pa.	2003	Belitskus v Pizzingrilli: mandatory filing fee can't be imposed on poor candidates
R.I.	1978	McCarthy v Garrahy: independent statewide petition can't have county distribution requirement
So.C.	2006	Working Families Party v Elec. Comm: new parties can't be required to hold meetings in March
So.D.	2000	Nader 2000 Primary Comm. v Hazeltine: June petition deadline too early for indp. pres. candidates
Tenn.	1976	MacBride v Hassler: minor party pres. candidate must be permitted to use independent procedure
Tex.	1996	Texas Indp. Pty v Kirk: indp. petition need not carry each voter's voter affidavit number
Utah	1984	LaRouche v Monson: April petition deadline too early for independent presidential petitions
Vt.	1976	McCarthy v Salmon: if town clerks don't check signatures, candidate must be put on ballot
Va.	1989	El-Amin v State Bd Elec II: independent candidate supporters may substitute a new nominee
Wash.	1974	Orians v James: groups that advocate violent overthrow of government can't be kept off ballot
W.V.	2003	McClure v Manchin: petitioners need not carry credentials that identify them
Wis.	2003	Frami v Ponto: out-of-state circulators must be allowed to petition
Wy.	1984	Blomquist v Thomsen: state must have procedure for new parties to get on ballot

STATE	REQUIREMENTS		SIGNATURES COLLECTED				DEADLINES
	FULL PARTY	CAND	LIB'T	GREEN	CONSTI	WK FAM	Party	Indp.
Ala.	37,513	37,513	100	0	0	0	June 1	June 1
Alaska	(reg) 9,786	#3,128	*6,500	*2,583	0	0	June 1	Aug. 24
Ariz.	20,449	(est) #25,500	already on	*5,000	*300	0	Mar. 11	unsettled
Ark.	10,000	10,000	0	0	0	0	June 30	May 3
Calif.	(reg) 88,991	173,041	already on	already on	in court	0	Jan. 6	Aug. 6
Colo.	(reg) 1,000	1,000	already on	already on	already on	0	June 1	June 15
Conn.	no procedure	#7,500	already on	already on	can't start	can't start	- - -	Aug. 11
Del.	(est) (reg) 300	(est) 6,200	already on	already on	already on	already on	Aug. 10	July 15
D.C.	no procedure	#3,000	can't start	already on	can't start	can't start	- - -	Aug. 25
Florida	be organized	pay fee	already on	already on	already on	0	Apr. 30	Apr. 30
Georgia	57,582	#44,089	already on	can't start	can't start	can't start	July 13	July 13
Hawaii	692	25	already on	0	*10	0	Apr. 1	July 19
Idaho	13,102	1,000	already on	can't start	already on	can't start	Aug. 27	March 19
Illinois	no procedure	#25,000	can't start	already on	can't start	can't start	- - -	June 21
Indiana	no procedure	#32,742	already on	0	0	0	- - -	June 30
Iowa	no procedure	#1,500	0	0	0	0	- - -	Aug. 13
Kansas	16,994	5,000	already on	0	0	0	June 1	Aug. 2
Ky.	no procedure	#5,000	can't start	can't start	can't start	can't start	- - -	Aug. 10
La.	(reg) 1,000	pay $500	already on	already on	*500	0	May 20	Aug. 20
Maine	27,544	#4,000	0	already on	0	0	Dec 11, 09	Aug. 8
Md.	10,000	(est) 35,000	already on	already on	already on	0	Aug. 2	Aug. 2
Mass.	(est) (reg) 40,000	#10,000	already on	7,522	80	5,534	Feb. 1	July 27
Mich.	38,024	30,000	already on	already on	already on	0	July 15	July 17
Minn.	145,519	#2,000	0	0	0	0	July 20	July 20
Miss.	be organized	800	already on	already on	already on	0	April 9	April 9
Mo.	10,000	10,000	already on	0	already on	0	July 26	July 26
Mont.	5,000	#15,359	already on	0	already on	0	Mar. 18	in court
Nebr.	5,921	4,000	0	0	0	0	Aug. 2	Aug. 24
Nev.	9,083	9,060	already on	0	already on	0	April 12	April 12
N. Hamp.	20,394	#3,000	0	0	0	0	Aug. 4	Aug. 4
N.J.	no procedure	#1,300	0	0	0	0	- - -	June 2
N. M.	4,151	16,764	0	0	already on	0	Apr. 1	June 3
N.Y.	no procedure	#15,000	can't start	can't start	can't start	already on	- - -	Aug. 17
No. Car.	85,379	69,734	already on	0	0	0	May 14	June 10
No. Dak.	7,000	#4,000	0	0	0	0	Apr. 9	Sep. 3
Ohio	unsettled	5,000	*unsettled	*unsettled	*unsettled	0	unsettled	May 3
Okla.	73,134	pay fee	0	0	0	0	May 1	July 15
Oregon	20,640	(est) 19,000	already on	already on	already on	already on	Aug. 26	Aug. 26
Penn.	no procedure	(est) #25,000	can't start	can't start	can't start	can't start	- - -	Aug. 2
R.I.	23,589	#1,000	can't start	can't start	can't start	can't start	May 28	July 22
So. Car.	10,000	10,000	already on	already on	already on	already on	May 2	July 15
So. Dak.	8,389	3,356	0	0	already on	0	Mar. 23	June 2
Tenn.	in court	25	0	0	0	0	unsettled	April 1
Texas	43,991	43,991	already on	can't start	can't start	can't start	May 24	May 10
Utah	2,000	#1,000	already on	0	already on	0	Feb. 15	March 15
Vermont	be organized	#500	already on	0	already on	0	Jan. 1	Sep. 10
Virginia	no procedure	#11,000	0	0	0	0	- - -	June 8
Wash.	no procedure	pay fee	0	0	0	0	- - -	May 15
West Va.	no procedure	*#7,250	0	already on	0	0	- - -	May 10
Wisc.	10,000	#2,000	already on	already on	can't start	can't start	June 1	July 13
Wyo.	4,981	4,988	already on	0	*500	0	June 1	Aug. 23
TOTAL STATES ON			27	16	16	4	`	`

#partisan label is permitted on the ballot (other than "independent").
Mississippi, New Jersey, Virginia, and West Virginia have no statewide race in 2010, so the entry is for a full slate of U.S. House nominees. *change from the Dec. 1, 2008 chart.

Recent special elections for important office in New York and California have shown higher than usual showings for minor parties.

New York: at the March 31, 2009 special election to fill the vacant U.S. House seat in the 20^th district, the results were: Democratic 43.64%; Republican 42.73%; Conservative 7.04%; Independence 4.20%; Working Families 2.39%.

By contrast, in 2008 in this same district, the vote had been: Democratic 57.43%; Republican 32.06%; Conservative 3.23%; Independence 2.57%; Working Families 4.70%. The New York Conservative Party's showing in the special election was its best percentage for any U.S. House race in the state since 2006.

California: at the May 19 special election to fill the vacant State Senate seat, 26^th district, the vote was: Democratic 70.44%; Republican 21.12%; Peace & Freedom 8.43%. That was the highest showing for a Peace & Freedom state legislative candidates (excluding races with only one major party nominee) since 1978. Back in 1978, a Peace & Freedom nominee for Assembly in Santa Cruz had polled 9.90%.

Last time this seat was up, in November 2006, the vote had been: Democratic 89.09%; Libertarian 10.91%.

Puerto Rico elects its governor in every presidential election year. In 2008, the Independence Party of Puerto Rico failed to poll as much as 3% for Governor, so it lost its place on the ballot. However, on May 13, the Puerto Rico Election Commission announced that the party's petition to get back on the ballot had succeeded. Puerto Rico requires a petition signed by 5% of the number of registered voters to qualify parties, a requirement that is more difficult than any state in the United States.

At the end of April 2009, both the Republican Party and the Green Party suffered from the defection of a high-ranking elected official. U.S. Senator Arlen Specter of Pennsylvania left the Republican Party, and Arkansas State House member Richard Carroll left the Green Party.

Mark Swaney, Arkansas Green Party coordinator, speaking to the press about Carroll's switch to the Democrats, reacted by saying, "We like Richard Carroll. We think he is an excellent legislator. We're very pleased with his work in the Legislature and we agreed with all the bills he introduced." Swaney thus kept the door open for a continuing friendly relationship between Carroll and the Green Party. It is always possible that Carroll will return to the Green Party some day. Already a Democratic State Senator who is term-limited out of running for re-election in 2010 has indicated he may run against Carroll in the 2010 Democratic primary for Carroll's House seat.

By contrast, Republican National Chairman Michael Steele was quoted in the press as saying that Senator Specter had "flipped the bird to his Republican colleagues." He also said, "Get ready to go to the mat, baby, because we're coming after you and taking you out."

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Free & Equal, founded early this year by Christina Tobin to work for better treatment for minor party and independent candidates, has already made generous financial contributions. Free & Equal contributed $1,850 toward the salary for a professional lobbyist who has been working for the Oklahoma ballot access bill. Also, Free & Equal is made an even bigger donation to launch a publicity tour for Theresa Amato's upcoming book, Grand Illusion: The Myth of Voter Choice in a Two-Party Tyranny.

Another generous contributor to the expenses in Oklahoma is Bill Redpath, national chair of the Libertarian Party. During May, he made a personal contribution of $1,500.

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