Supreme Court Stays Out of Partisan Gerrymandering Cases - For Now

In a victory - at least for now - for courts staying out of partisan gerrymandering disputes, the Supreme Court today decided two of the three redistricting cases pending before it.

In Gill v. Whitford, a challenge to Wisconsin's congressional district map, the Court unanimously dismissed the case for lack of standing (citations omitted):

Certain of the plaintiffs before us alleged that they had such a personal stake in this case, but never followed up with the requisite proof. The District Court and this Court therefore lack the power to resolve their claims. We vacate the judgment and remand the case for further proceedings, in the course of which those plaintiffs may attempt to demonstrate standing in accord with the analysis in this opinion. . . . 

Regarding standing, the court held that the plaintiffs had a “cognizable equal protection right against stateimposed barriers on [their] ability to vote effectively for the party of [their] choice.” It concluded that Act 43 “prevent[ed] Wisconsin Democrats from being able to translate their votes into seats as effectively as Wisconsin Republicans,” and that “Wisconsin Democrats, therefore, have suffered a personal injury to their Equal Protection rights.” The court turned away the defendants’ argument that the plaintiffs’ injury was not sufficiently particularized by finding that “[t]he harm that the plaintiffs have experienced . . . is one shared by Democratic voters in the State of Wisconsin. The dilution of their votes is both personal and acute.” . . . 

In cases where a plaintiff fails to demonstrate Article III standing, we usually direct the dismissal of the plaintiff ’s claims. This is not the usual case. It concerns an unsettled kind of claim this Court has not agreed upon, the contours and justiciability of which are unresolved. Under the circumstances, and in light of the plaintiffs’ allegations that Donohue, Johnson, Mitchell, and Wallace live in districts where Democrats like them have been packed or cracked, we decline to direct dismissal.  

We therefore remand the case to the District Court so that the plaintiffs may have an opportunity to prove concrete and particularized injuries using evidence—unlike the bulk of the evidence presented thus far—that would tend to demonstrate a burden on their individual votes. We express no view on the merits of the plaintiffs’ case. We caution, however, that “standing is not dispensed in gross”: A plaintiff ’s remedy must be tailored to redress the plaintiff ’s particular injury. 

While this may seem like the Court side-stepped the issues in the case, the standing decision was integral to the court's deciding in favor of the plaintiffs below.  By reversing the court's questionable conclusions on standing being shown through statewide partisan voting results, the Court today made it more difficult for future claimants to bring claims under such novel legal theories by properly placing the evidentiary burden on map challengers to show concrete and particularized injury.  (It is also worth noting that the length of Justice Roberts' opinion for the Court demonstrates how complicated standing doctrine and the law in general are in the area of redistricting.)  This is clear in the liberal justices' concurrence.

Justice Kagan, joined by Justices Ginsburg, Breyer, and Sotomayor, lamented that the plaintiffs did not argue the case appropriately to let the Court decide questions of proper district lines on political grounds, which liberals are desperate to do (citations omitted):

Partisan gerrymandering, as this Court has recognized, is “incompatible with democratic principles.” More effectively every day, that practice enables politicians to entrench themselves in power against the people’s will. And only the courts can do anything to remedy the problem, because gerrymanders benefit those who control the political branches. None of those facts gives judges any excuse to disregard Article III’s demands. The Court is right to say they were not met here. But partisan gerrymandering injures enough individuals and organizations in enough concrete ways to ensure that standing requirements, properly applied, will not often or long prevent courts from reaching the merits of cases like this one. Or from insisting, when they do, that partisan officials stop degrading the nation’s democracy. . . .

Courts have a critical role to play in curbing partisan gerrymandering. Over fifty years ago, we committed to providing judicial review in the redistricting arena, because we understood that “a denial of constitutionally protected rights demands judicial protection.” Indeed, the need for judicial review is at its most urgent in these cases. For here, politicians’ incentives conflict with voters’ interests, leaving citizens without any political remedy for their constitutional harms. Of course, their dire need provides no warrant for courts to disregard Article III. Because of the way this suit was litigated, I agree that the plaintiffs have so far failed to establish their standing to sue, and I fully concur in the Court’s opinion. But of one thing we may unfortunately be sure. Courts—and in particular this Court—will again be called on to redress extreme partisan gerrymanders. I am hopeful we will then step up to our responsibility to vindicate the Constitution against a contrary law.  

Justices Thomas and Gorsuch concurred but would have dismissed the case without allowing the plaintiffs another attempt at proving standing.

In a per curiam decision in Benisek v. Lamone, the Court affirmed a district court decision not to issue a preliminary injunction on a First Amendment retaliation partisan gerrymandering challenge to a single district in Maryland (citations omitted):

In addition, the District Court emphasized that it was concerned about “measuring the legality and constitutionality of any redistricting plan in Maryland . . . according to the proper legal standard.” In the District Court’s view, it would be “better equipped to make that legal determination and to chart a wise course for further proceedings” after this Court issued a decision in Gill. Plaintiffs ask this Court to vacate the District Court’s order and remand for further consideration of whether a preliminary injunction is appropriate. . . .

Even if we assume—contrary to the findings of the District Court— that plaintiffs were likely to succeed on the merits of their claims, the balance of equities and the public interest tilted against their request for a preliminary injunction. . . .  

On top of this time constraint was the legal uncertainty surrounding any potential remedy for the plaintiffs’ asserted injury. At the time the District Court made its decision, the appeal in Gill was pending before this Court. The District Court recognized that our decision in Gill had the potential to “shed light on critical questions in this case” and to set forth a “framework” by which plaintiffs’ claims could be decided and, potentially, remedied. . . . In these particular circumstances, we conclude that the District Court’s decision denying a preliminary injunction cannot be regarded as an abuse of discretion.

One line in Benisek regards the fact that the plaintiffs did not challenge the 2011 district map until 2016 (emphasis added):

In considering the balance of equities among the parties, we think that plaintiffs’ unnecessary, years-long delay in asking for preliminary injunctive relief weighed against their request.

This may prove to be extremely important in future litigation, as Democrats and liberals are still filing new cases challenging the maps enacted after the 2010 census.

But for now, the Supreme Court has decided to stay out of partisan gerrymandering claims, against the wishes of its liberal members to use the Court to judge the wisdom of political balances of power in the states.  That is a temporary victory for the proper role of the courts, temporary only because the liberals and Democrats will continue to bring these claims until the Court issues a decision explicitly barring courts from deciding them.  But today's decisions in Gill and Benisek have established justiciability standards that raise the bar for bringing those claims.

Supreme Court Hears Oral Arguments in Benisek v. Lamone, Maryland Redistricting Case

This morning, the Supreme Court heard oral arguments in Benisek v. Lamone, a First Amendment retaliation challenge to Maryland's 6th Congressional district lines.  This is the second partisan gerrymandering case the Court has heard this term, after Gill v. Whitford in October.  

The facts and arguments in Benisek are unique from those in Whitford, though both are partisan gerrymandering claims:

For two decades, the predominantly Republican district was represented in Congress by Republican Roscoe Bartlett, but in 2011, redistricting altered the political composition of the 6th district; the following year, Democrat John Delaney beat Bartlett by over 20 percentage points. The plaintiffs in the case live in the 6th district and contend that Democrats in Maryland engaged in partisan gerrymandering – that is, drawing a redistricting map to favor one political party at the expense of another – to retaliate against them for their past support of Republican candidates like Bartlett. And that, they argue, violated their First Amendment rights of speech and association. Maryland officials deny that any gerrymandering occurred. But even if it did, they maintain, courts should stay out of these kinds of First Amendment retaliation claims because there are no manageable standards for them to use to determine when partisan gerrymandering goes too far.

The Court has refrained from ruling on partisan gerrymandering cases in the past, and it is unclear how the Justices will rule on this set of cases:

If spectators had hoped that today’s oral argument might shed some light on how the justices had voted on the Wisconsin case, they were – unless the justices have excellent poker faces – largely disappointed. Instead, it seemed entirely possible that the justices were counting on the oral argument to give them new insight into a solution to the thorny problem of partisan gerrymandering. But before they even got that far, justices of all ideological stripes expressed doubt about whether they should rule on the partisan-gerrymandering question at all when the case came to them as a request for preliminary relief, rather than for a decision on the merits, and their ruling would come too late for any changes to the state’s congressional maps before the upcoming 2018 election. . . . 

When the justices did eventually turn to the question of partisan gerrymandering itself, the concern at the heart of the Wisconsin case resurfaced: How should courts evaluate claims of partisan gerrymandering? As Justice Samuel Alito stressed to Kimberly, the Supreme Court has recognized that redistricting is an inherently partisan process, and that a desire to give the party in power an advantage is not, standing alone, problematic. 

Moreover, there was no obvious consensus among the justices on how courts should determine when politics has played too strong a role in redistricting. . . . 

As RNLA Executive Director Michael Thielen wrote last week, courts are not the proper venue for resolving the political disputes inherent in redistricting.  But since it is unlikely that courts will re-invoke the political question doctrine and no longer decide redistricting cases, everyone on all sides of this issue agrees that the Court needs to provide clear guidance to prevent courts from acting arbitrarily when deciding redistricting cases.

Supreme Court Grants Cert in Maryland Redistricting Case

To the surprise of Supreme Court observers and election lawyers, on Friday the Supreme Court agreed to hear a second political gerrymandering case this term, this time out of Maryland:

In October, the justices heard oral argument in a challenge to the redistricting plan passed by Wisconsin’s Republican-controlled legislature in 2011 [Gill v. Whitford]. Today they agreed to weigh in on Benisek v. Lamone, a challenge to another redistricting plan enacted in 2011, in which the plaintiffs allege that Democratic election officials in Maryland gerrymandered the state’s 6th congressional district in retaliation for the plaintiffs’ support for Republican candidates – specifically, Roscoe Bartlett, who represented them in Congress for two decades.

Most Court observers assumed that the justices would not hear Benisek, or any other political gerrymandering cases, until they had decided the currently pending case, Gill v. Whitford.  While the plaintiffs in Whitford challenged the map for the entire state, the Benisek plaintiffs are challenging just one district:

The plaintiffs told the justices that “the mapdrawers reshuffled fully half of the district’s 720,000 residents—far more than necessary to correct the mere 10,000-person imbalance in the district’s population following the 2010 census.” As a result, they explained, “registered Republicans’ share of the electorate fell from 47% to 33%,” and Bartlett lost his seat to a Democrat, John Delaney.

The claim is slightly different in Benisek as well, as it is based in the First Amendment.  A dispute over what must be proven under such a claim and whether the Court has the authority to hear the case are before the Court:

The issues before the court center on what plaintiffs in a First Amendment retaliation challenge to partisan gerrymandering must show for their case to go forward. According to the plaintiffs in this case, the district court would have required them to show that “each and every outcome is (and will continue to be) singularly attributable to gerrymandering.” But all they should have to show, the plaintiffs maintain, is that they have suffered some injury.

The decision to grant cert in this case, in addition to Whitford, may indicate that the justices will issue a broad, joint opinion laying out the rules for political gerrymandering claims.  Or, the Court may decide the cases separately and on very narrow grounds (perhaps on a jurisdictional issue, instead of reaching the claims on the merits).  While this Supreme Court term previously had the potential to change the legal landscape for redistricting, that is even more true now that another partisan gerrymandering case is before the Court.  Oral argument in Benisek has not yet been scheduled.

How Governor Larry Hogan is Changing Maryland

2014 saw a record-breaking Republican wave. Disappointed with Obama-era policies, Republicans had a net gain of nine seats in the United States Senate, the largest for either party since 1980. They also gained 13 seats in the House of Representatives, giving them their largest majority in the House since 1928. On the state-level, Republican Governors won two seats previously occupied by Democrats, a net gain of two seats.

The most unexpected and unlikely Republican gubernatorial pickup? Maryland. When the dust from the party primaries cleared, Republicans chose Larry Hogan, a member of Governor Ehrlich’s Cabinet who had never held elected office before, against sitting Lieutenant Governor Anthony Brown. Brown was the handpicked successor of Governor Martin O’Malley. In a state where Democratic registered voters outnumber Republicans by a two-to-one margin, there seemed to be little hope for the real estate executive from Anne Arundel County.

But as the campaign wore on, Mr. Hogan was staying competitive against all odds. Even Maryland Democrats seemed uninspired by four more years of Martin O’Malley. Focusing on taxes and the economy, he pulled a huge five-point upset. Now came the real challenge of being a Republican Governor in an overwhelmingly Democratic state.

Despite battling cancer early in his term, Governor Hogan delivered on a promise to cut $1.7 billion in waste from the state government. He rolled back road, tunnel, and bridge tolls, and pared back fees paid to some state agencies.  He has signed three consecutive budgets without a tax increase. Since he took office, Maryland went from losing 100,000 jobs to creating over 110,000 new jobs by bringing new private sector opportunities to Maryland that will position the state for further growth. All these changes have moved Maryland from 49^th in job creation to 10^th. 

As Governor Hogan has said, “we can disagree without being disagreeable.” He is evidence that we all have the same noble goal of a prosperous economy that provides opportunity, but different ways and paths to get there. Marylanders are seeing after eight years of full party Democratic control what a Republican Governor has done in less than three years. Focusing on commonsense reforms like small government and fiscal responsibility, Governor Hogan provides a bright path for all in the Old Line state, truly showing that Maryland is open for business.   

The RNLA is pleased to have Governor Hogan speak at its September luncheon in Washington, D.C. this Friday, September 1 at noon at the Capitol Hill Club.  More information is here, but this event is now sold out.

This blog post was written by RNLA Maryland Chapter Chair Brian Bennett.

Another Maryland City Considers Allowing Non-Citizens to Vote

Several Maryland cities currently allow non-citizens to vote in local elections, and College Park is considering such a proposal:

The Prince George’s County city, home of the flagship University of Maryland campus and some 30,000 residents, is considering a measure to let noncitizens cast ballots for mayor and City Council — making it the latest target in a movement that has had more success in Maryland than anywhere else in the United States. . . . 

Supporters of the College Park measure say local elections center on trash collection, snow removal and other municipal services that affect people regardless of their citizenship status. The proposal, like those already approved in other small Maryland cities and towns, would not allow undocumented immigrants to vote for president, senator, congressman or governor. . . . 

Opponents say immigrants — even those in the country legally, such as green-card holders — should not be able to have a say in the direction of the community until they complete the process of becoming a citizen. . . . Jeff Werner, who advocates tighter restrictions on immigration with the group Help Save Maryland, said people who are in the country legally should have a voice in their communities, but if they are not citizens, their participation should not extend as far as voting.

Federal law controls who is eligible to vote in federal elections (U.S. citizens), but by state law in Maryland (and many other states), localities can determine eligibility requirements for local elections.  So while allowing non-citizens to vote in Maryland is completely legal (though perhaps surprising for many citizens), it is a bad policy decision.  Allowing non-citizens on the local voting rolls increases the likelihood that they will mistakenly be allowed to vote in state and federal elections.  States that allow 16- and 17-year-olds to pre-register to vote find with alarming frequency that if those underage citizens show up at the polls, they are allowed to vote.  The College Park proposal does not distinguish between legal residents and illegal immigrants, meaning that if someone has broken the law in his or her manner of entering the country, their vote would carry equal weight in local elections with a taxpaying citizen (and remember, local races are often won by very small margins).  Non-citizens are often transient and not as invested in the community as citizens.

It is unfortunate to see cities in Maryland bowing to liberal pressure to embrace this so-called "diversity" and "inclusiveness" at the expense of their citizens and at great risk to the integrity of their elections and to see increasing calls for similar laws in California and other liberal enclaves.

Bipartisan Support in Senate for Gorsuch Confirmation

Today, two Democratic senators announced support not only for a vote for cloture on Judge Neil Gorsuch's nomination to the Supreme Court but also for his confirmation.  

Senator Joe Manchin from West Virginia said:

After considering his record, watching his testimony in front of the Judiciary Committee and meeting with him twice, I will vote to confirm him to be the ninth justice on the Supreme Court. . . . Throughout Judge Gorsuch’s career, he has come to his legal rulings objectively, through the letter of the law rather than through his own opinion. 

During his time on the bench Judge Gorsuch has received praise from his colleagues who have been appointed by both Democrats and Republicans.  He has been consistently rated as a well-qualified jurist, the highest rating a jurist can receive, and I have found him to be an honest and thoughtful man.  I hold no illusions that I will agree with every decision Judge Gorsuch may issue in the future, but I have not found any reasons why this jurist should not be a Supreme Court Justice.

Senator Heidi Heitkamp from North Dakota said:

After doing my due diligence by meeting with Judge Gorsuch and reviewing his record and testimony before the Senate Judiciary Committee, I've decided to vote in favor of his confirmation.  He has a record as a balanced, meticulous, and well respected jurist who understands the rule of law.  He has unique and critical experience with tribal sovereignty, Indian law, and public lands issues in the west, and has received the endorsement of numerous tribes and major Native American organizations.  During our meeting and at his hearing, he reinforced the importance of a judiciary that remains independent of the executive and legislative branches of government - and that acts as a proper check and balance on the other two branches of government.

Other Democratic senators demonstrated some further cracks in the hardline Trump resistance movement today.  Senator Claire McCaskill of Missouri recognized that the Democrats' gridlock strategy for the Supreme Court is likely to backfire, and Senator Ben Cardin said that the Democrats should not filibuster Gorsuch.

Senators Heitkamp and Manchin are up for reelection in 2018 in states that voted for Donald Trump in 2016, and perhaps these senators have recognized the political consequences of voting against an eminently qualified judge like Judge Gorsuch.  Perhaps they have decided to listen to their constituents instead of the radical progressive special interest groups that increasingly control the Democratic Party.  Or perhaps, tellingly, they considered his extensive judicial record and made their decision on that basis, unlike their Democratic colleagues who have not bothered to review his record.  

Whatever the reason, we applaud Senators Heitkamp and Manchin for questioning the blind obstruction of the current Democratic Party and for supporting an extremely well-qualified and well-respected nominee for the Supreme Court.

Republican Wins in Maryland, Democrats Turn to Murderers, Rapists and Criminals to Prevent It From Happening Again

Maryland is commonly known as the “Free State” and yet many also know it as the “Old Line State”. The latter being a reference to the Maryland line's consistency and unwavering dedication during the American Revolution. As National Review discusses, Governor Larry Hogan is still attempting to “hold the line” in a battle that has been waging over a felon's "right to vote": 

If you aren’t willing to follow the law yourself, then you can’t demand a role in making the law for everyone else, which is what you do when you vote. We don’t let everyone vote — not children, not non-citizens, not the mentally incompetent, and not felons — because we have certain objective, minimum standards of responsibility and commitment to our laws that must be met before someone is given a role in the solemn enterprise of self-government. People who have committed a serious crime against their fellow citizens don’t meet those standards.

The right to vote can be restored to felons, but it should be done carefully, on a case-by-case basis after a person has shown that he or she has really turned over a new leaf, not automatically on the day someone walks out of prison — let alone when parole and probation have not yet been served. After all, the unfortunate truth is that most people who walk out of prison will be walking back in. Deep down, the Left knows all this; that’s why, though it is happy to let felons vote, it is somehow reluctant to restore their Second Amendment rights.

The real reason for this fight is not some noble cause for felons who have served their time.  It is pure crass politics to make it even harder for a Republican like Larry Hogan to win an election.  As a recent study concluded:

[A] study of how criminals vote found that most convicts register Democratic, a key reason in why liberal lawmakers and governors are eager for them to get back into the voting booth after their release.

“Democrats would benefit from additional ex-felon participation,” said the authoritative study in The Annals of the American Academy of Political and Social Science.

As a new legislative session begins, Governor Hogan’s veto of the bill in question is under partisan fire. Democrats have continued their attempt override it. Let us hope that the Governor’s veto holds.   

Two Votes for Illegal Aliens to One for US Residents in Maryland

There should not be disenfranchisement of legal voters through fraud or chaos.  Some cities in Maryland are allowing 16 and 17 year olds to vote and now want to allow legal AND illegal aliens to vote.  Not only does this effectively disenfranchise the votes of legal US residents but as a result 16/17-year-old illegal aliens may get two votes:

A year ago, the city lowered the voting age to 16, which allowed 15-year-olds to pre-register. The election board said introducing this legislation could essentially result in some people being registered twice, which would give them two votes.

Another problem is keeping multiple voting rolls for municipal elections and another for state and federal elections.  This guarantees a mess that will lead to long lines, potential fraud, and quite frankly a mess. 

Of course, another bigger issue is when you vote in an election you should have some connection to the locality, state, or country.  It is incredible that it is even debatable that legal and illegal aliens are given the privilege of voting.  With Maryland recently electing a Republican Governor, the real reason for this may be the fact that non-resident "voters" (including illegal aliens) vote overwhelmingly Democrat.  This set of fraudulent voters led to the passage of Obamacare according to a study by two Professors. 

Even the liberal city council members recognize a potential problem.  Illegal aliens may be in the US for a short period or likely have loyalty to their home country, as one liberal councilman noted:

Councilmember Tom Wright (Ward 3) said he was on the fence about non-citizen voting because of feedback from citizens. “I also understand the concern of those residents … concerned about allowing people who may be just transient effectively [to] create legislation,” he said.

Instead of working on turning out legal voters, Democrats and liberals often work on turning out illegal “voters” -- in this case by trying to legalize illegal aliens for voting purposes.  

Tougher Voting Laws Needed in Maryland

Recently, two Maryland women were indicted on charges of vote fraud in the 2012 election causing Maryland Republicans as well as many others to suggest that tougher voting laws are needed in the state. 

Linda Wells was indicted in July for impersonating a voter to register in the name of the voter, attempting to vote under a false name and impersonating another person in an attempt to vote.  Ms. Wells called the county Board of Elections impersonating her dead mother and reactivated her mother’s registration the day before the election and then voted provisionally as her mother on election day.  In this case, luckily, the provisional ballot was not counted according to the statement announcing the indictment. 

Vote fraud in Maryland is not an uncommon thing as it was discovered that Wendy Rosen, a former congressional candidate who tried to unseat Andy Harris, was caught voting in both Maryland and Florida.  Rosen dropped out of the race when her double voting was discovered.  she was later fined a minimal amount ($5000) and given 1,000 hours of community service-a mere slap on the wrist for knowingly breaking the law. 

Maryland Delegate Kathy Szeliga (District 7):

“To have a candidate arrogant enough to run for Congress and having committed voter fraud proves there’s voter fraud,” 

She along with other state delegates have tried to repeatedly to bring the issue to the foresight of the Maryland state legislature, especially with its recent voter overhauls. 

“Every illegal vote takes away from a legitimate vote,” said Del. Kathy Afzali (Dist. 4A)…Requiring voters to have ID and purging the voter rolls would help, she said. “We have a lot of dead people ... or people who have moved or left the state [who are] still on the rolls.”

Afzali and other Republicans have tried repeatedly to make fraudulent voting a felony in Maryland, punishable with a fine of up to $10,000.

“Keep in mind, if it’s a felony, the person who commits the crime is prohibited from voting in future,” she said. “And to me, that person should lose the right to vote.”

Many believe that cleaning up the voter rolls would also help to curb potential fraud. Election Integrity Maryland, a citizen watchdog group, says it has found numerous inaccuracies with the Maryland voter rolls and that it is not complying with the National Voter Registration Act. The group scanned 39,000 names and found 1,100 problems. If there are that many problems with 1% of the voter rolls what is the true potential for fraud? While the State Board of Elections denies the accusations, the fact remains that fraud like that perpetuated by Ms. Wells above would not have happened had the Board of Elections properly did their job and checked before reactivating the mother’s registration. 

Election Integrity Maryland is one of the many groups who believe that a voter ID bill in Maryland would be a great start to curbing the potential for fraud and any inaccuracies on the voter rolls.  However with the Democrat controlled Maryland General Assembly it is bills like this, bills that would only help to safeguard one of our most important and special rights that we as American’s have, that are killed because some democratic opponents believe that it could potentially prevent a person who is unable to get an ID from exercising their right to vote even though examples cannot be found in other states who have ID laws.  

Bloated Voter Rolls in Maryland

The extent of another state's bloated voter rolls recently came to light when the Maryland Republican Party released a report about the states voter rolls. Twenty thousand deceased Marylanders remain on voter registration rolls, 268,000 voters are registered at addresses where they don’t live, and 48 are listed with record ages higher than 114 years old.

The party used data collected from current state election files, the U.S. Department of Commerce, U.S. Postal Office National Change of Address information and commercial information available on the web.

“We want to share our findings with the State Board of Elections to make sure voter rolls are cleansed properly,” said Maryland Republican Party Executive Director David Ferguson. “This is not an attack on the state board, they are just a repository for all 24 counties. It’s very difficult to remove someone from the voter file.”

He said the findings illustrate that there might need to be changes in Maryland law, or that elections officials need to go above and beyond the current system in order to make sure the voter rolls accurately reflect Maryland voters.

Of the 268,004 registered names with different addresses than those on file, the Maryland Republican Party found that approximately 167,113 now live at a different location within Maryland and approximately 100,891 have filed change of address forms stating they now live out of state. Ferguson said the research group compared voter data against a National Change of Address search through the Postal Service.

The report found 11,170 individuals currently on the voter rolls have changed their address to Virginia, 4,352 to Delaware, 11,113 to Pennsylvania, and 3,696 to New York. Media reports say that the world’s two oldest people are 114 and 116 — making it extremely unlikely that Maryland has 48 people aged 114 or older, as the analysis found on the voter rolls.

In releasing their findings, state party chair Diana Waterman said, 

“It is time to open the books and cleanse our list of the deceased and those no longer residing in Maryland to make sure we fully understand who is voting in our elections.”

Removing from the voter rolls those who are ineligible is of vital importance to the integrity of elections.  Just last month a scheme was uncovered by activists in New York to take advantage of such ineligible voters.