Where are they now? Supreme Court clerks, OT2005

Following up on posts on a ten-year retrospective on the Supreme Court clerks from October Term 2003 and October Term 2004, here's what the clerks from October Term 2005 are doing. This list is probably unreliable and has not been fact-checked in any way, except for the links provided (and these links often aren't the best source material). Note that Chief Justice William Rehnquist passed away at the beginning of the term and was replaced by Chief Justice John Roberts, and clerks for both are designated under the Roberts clerks. Also note that Justice Samuel Alito replaced Justice Sandra Day O'Connor in the middle of the term, and I did the best I could breaking down their clerks.

Chief Justice John G. Roberts

Daniel P. Kearney, Jr. (Yale 2004 / J. Roberts (D.C. Cir.)), counsel at WilmerHale

Mark W. Mosier (Chicago 2004 / Rehnquist / Tacha), partner at Covington

Ann E. O'Connell (George Washington 2004 / Rehnquist / Magill), assistant to the Solicitor General, DOJ

Michael S. Passaportis (Virginia 2004 / Rehnquist / Wilkinson), unknown

Kosta Stojilkovic (Virginia 2004 / J. Roberts (D.C. Cir.)), AUSA, E.D. Va.

Justice John Paul Stevens

Jean Galbraith (Berkeley 2004 / Tatel), professor at Penn

Daniel J. Lenerz (Stanford 2002 / S. Williams / Thompson (M.D. Ala.)), civil division, appellate staff, DOJ

Sarah Eddy McCallum (Georgetown 2002 / Walker (2d Cir.) / Rakoff), AUSA, S.D.N.Y.

Samuel Spital (Harvard 2004 / H. Edwards), partner at Holland & Knight

Justice Sandra Day O'Connor

Tali Farhadian Weinstein (Yale 2003 / Garland), AUSA, E.D.N.Y.*

Benjamin J. Horwich (Stanford 2003 / Becker / V. Walker (N.D. Cal.)), attorney at Munger Tolles**

Amy N. Kapczynski (Yale 2003 / Calabresi), professor at Yale

Sasha Volokh (Harvard 2004 / Kozinski), professor at Emory**

*Also clerked for previous term with Justice O'Connor.

**Also clerked for Justice Alito upon his confirmation.

Justice Antonin Scalia

John C. Demers (Harvard 1999 / O'Scannlain), VP & assistant GC, Boeing

Scott P. Martin (Columbia 2004 / Kozinski), partner at Gibson Dunn

D. John Sauer (Harvard 2004 / Luttig), partner at Clark & Sauer

Evan A. Young (Yale 2004 / Wilkinson), partner at Baker Botts

Justice Anthony Kennedy

David M. Cooper (Stanford 2004 / J. Roberts (D.C. Cir.)), counsel at Quinn Emanuel

Randy J. Kozel (Harvard 2004 / Kozinski), professor at Notre Dame

Jeffrey A. Pojanowski (Harvard 2004 / J. Roberts (D.C. Cir.)), professor at Notre Dame

Zachary S. Price (Harvard 2003 / Tatel / Blake (D. Md.)), professor at Hastings

Justice David H. Souter

Jeanne C. Fromer (Harvard 2002 / Sack), professor at NYU

Meaghan McLaine VerGow (Harvard 2004 / Garland), counsel at O'Melveny

Jon D. Michaels (Yale 2003 / Calabresi), professor at UCLA

Allison Orr Larsen (Virginia 2004 / Wilkinson), professor at William & Mary

Justice Clarence Thomas

Chantel Febus (George Washington 2002 / E. Jones / Lamberth (D.D.C.)), counsel at Proskauer

James C. Ho (Chicago 1999 / J. Smith (5th Cir.)), partner at Gibson Dunn

John M. Hughes (Chicago 2004 / Luttig), partner at Bartlit Beck

Ashley E. Johnson (Vanderbilt 2004 / Luttig), counsel at Gibson Dunn

Justice Ruth Bader Ginsburg

Lori Alvino McGill (Columbia 2003 / Tatel), partner at Quinn Emanuel

Joshua Civin (Yale 2003 / Reinhardt), counsel,  Montgomery County Public Schools

Rebecca Deutsch (Yale 2002 / Katzmann / Rakoff (S.D.N.Y.)), assistant general counsel for law and policy, Consumer Financial Protection Bureau

Anna-Rose Mathieson (Michigan 2003 / Boudin), partner at California Appellate Law Group

Justice Stephen Breyer

Danielle Gray (Harvard 2003 / Garland), partner at O'Melveny

Kathryn E. Judge (Stanford 2004 / Posner), professor at Columbia

Jonathan Kravis (Yale 2004 / Garland), AUSA, D.D.C.

John H. Longwell (Georgia 1999 / D. Ginsburg / V. Walker (N.D. Cal.)), counsel, ING

Justice Samuel Alito

Adam G. Ciongoli (Georgetown 1995 / Tatel / Bea), counsel, Campbell Soup Company

Horwich (from O'Connor)

Hannah Clayson Smith (BYU 2001 / Thomas (S. Ct.) / Alito (3d Cir.)), counsel, The Becket Fund for Religious Liberty

Volokh (from O'Connor)

A few thoughts:

The law professor drought is over! Well, last year, I wondered about a sharp drop-off in academic placements, from 14 for OT2003 to just 3 for OT2004. They're back! Nine are teaching at top flight law schools.

Who needs to become a partner? I count 6 former clerks working at law firms in an attorney or counsel role rather than as partner.

Otherwise, it's the usual mix of government or public interest lawyers, private practitioners, and academics one might otherwise expect.

Fictional Attorney of the Month: Rudy Baylor

In 1997, Francis Ford Coppola directed a cinematic version of John Grisham's novel, The Rainmaker. The all-star cast is led by Matt Damon as Rudy Baylor, a newly minted lawyer from Memphis who escaped a life of poverty and lands the case of a lifetime.

Rudy takes a job as an ambulance chaser--literally visiting victims in the hospital to try to get clients--before running into Deck Shifflet, played by Danny DeVito. Rudy finds an insurance case involving Donny Ray, a 22-year-old dying of leukemia whose claims had been denied. Deck helps him out, and the two take on a powerful insurance company and its suite of attorneys.

The film has a number of roles and smaller story lines that slowly intertwine in Rudy's development. It offers not simply a very realistic look at the hard life of a novice plaintiff's attorney scrapping for fringe cases and confronting a powerful and slippery defense team, but also the ethical and moral questions that a new attorney confronts in his own life and in the practice of law generally. It is not exactly an uplifting film for the young lawyer. But Rudy's tenacity, skill, and introspection are worth of thoughtful examination.

California bar votes to cut exam from three days to two

In March, I covered the news that the California bar was considering cutting the length of the bar exam from three days to two. Today, Above the Law reports that the bar's board of trustees has unanimously approved the change, which should take effect July 2017.

The proposal (PDF) called for five one-hour essay questions and a 90-minute performance test on one day, and the 200-question multistate bar exam (MBE) on another day. The essays and the multiple choice component would each receive half the weight in the final score.

This post has been updated.

Fictional Attorney of the Month: The King of Hearts

Alice's Adventures in Wonderland tells of a rather silly kingdom. And Alice observes the trial of the Knave of Hearts.

She easily identifies the King of Hearts as the judge "because of his great wig." She watches jurors writing their names in the event they forget them before the end of the trial.

As the trial begins, the judge/king accuses the Knave of Hearts of stealing the queen's tarts. But the King of Hearts has little sense in running a trial.

"Consider your verdict," the King said to the jury.

"Not yet, not yet!" the Rabbit hastily interrupted. "There's a great deal to come before that!"

"Call the first witness," said the King; and the White Rabbit blew three blasts on the trumpet, and called out, "First witness!"

At one point, the King of Hearts warns the Hatter to give his evidence or face execution on the spot, or that the Hatter must remember evidence or be executed. Certainly an intemperate judge. And then, as judge, he cross-examines a witness on the contents of the tarts, only to complain to the Queen, "Really, my dear, you must cross-examine the next witness. It quite makes my forehead ache!" And when Alice takes the stand (by now, a giantess), the king cites "Rule Forty-two. All persons more than a mile high to leave the court," which he claims is the oldest rule in the book, until Alice remarks that it ought to be numbered one if that were the case.

An executive acting as judge? This month's Fictional Attorney of the Month.

Quick thoughts on Arizona State Legislature v. Arizona Independent Redistricting Commission

Sixteen months ago, I highlighted a largely-unnoticed case in which Arizona's state legislature challenged a delegation of power over its power to draw congressional districts from itself to an independent redistricting commission, a delegation that occurred via ballot initiative. I noted the three-judge panel district court's decision, was the first to mention Paul Clement's involvement in the case, and had a few thoughts from oral argument. Now have a decision (PDF).

The opinion written by Justice Ginsburg, in a 5-4 vote, affirmed the three-judge panel and permits the independent redistricting commission. (This vote total is deceptive: two justices would have dismissed the case for lack of jurisdiction, effectively allowing the law to remain on the books; so, in theory, 7 justices agreed with the result in some remote way, but only 5 agreed on the merits of the constitutional claim.)

First, the case permits the legislature to have standing, distinguishing it from Raines v. Byrd, in which individual members attempted to assert standing. This, I think, portends poorly for the legislators suing in Hickenlooper v. Kerr, the Guarantee Clause case I've written about before.

Second, the opinion spends a substantial amount of time emphasizing that federal statute permits the exercise of power here. But that only addresses half the question: the other half the constitutional question, because if Congress lacked the power to authorize such an exercise of power, then the statute would fall, too.

Third, on the Elections Clause issue, the bulk of the analysis turns on a generous definition of the word "legislature," including the power to delegate authority:

To restate the key question in this case, the issue centrally debated by the parties: Absent congressional authorization, does the Elections Clause preclude the people of Arizona from creating a commission operating independently of the state legislature to establish congressional districts? The history and purpose of the Clause weigh heavily against such preclusion, as does the animating principle of our Constitution that the people themselves are the originating source of all the powers of government.
...
As well in Arizona, the people may delegate their legislative authority over redistricting to an independent commission just as the representative body may choose to do.

Fourth, Chief Justice Roberts pens the principle dissent relying on several core arguments: that the word "Legislature" relating to the election of Senators is instructive; the definition of the legislature; etc.

But, he also writes about the power of delegation, with some doubt:

The majority concedes that the unelected Commission is  not “the Legislature” of Arizona. The Court contends instead that the people of Arizona as a whole constitute “the Legislature” for purposes of the Elections Clause, andthat they may delegate the congressional districting authority conferred by that Clause to the Commission. Ante, at 25. The majority provides no support for the delegation part of its theory, and I am not sure whether the majority’s analysis is correct on that issue. But even giving the Court the benefit of the doubt in that regard, the Commission is still unconstitutional.

Fifth, the sides dispute the functionalist definition of "legislature." From Justice Ginsburg:

THE CHIEF JUSTICE, in dissent, features, indeed trumpets repeatedly, the pre-Seventeenth Amendment regime in which Senators were “chosen [in each State] by the Legislature thereof.” Art. I, §3; see post, at 1, 8–9, 19. If we are right, he asks, why did popular election proponents resort to the amending process instead of simply interpreting “the Legislature” to mean “the people”? Post, at 1. Smiley, as just indicated, answers that question. Article I, §3, gave state legislatures “a function different from that of lawgiver,” 285 U. S., at 365; it made each of them “an electoral body” charged to perform that function to the exclusion of other participants, ibid. So too, of the ratifying function. As we explained in Hawke, “the power to legislate in the enactment of the laws of a State is derivedf rom the people of the State.” 253 U. S., at 230. Ratification, however, “has its source in the Federal Constitution” and is not “an act of legislation within the proper sense of the word.” Id., at 229–230.
Constantly resisted by THE CHIEF JUSTICE, but well understood in opinions that speak for the Court: “[T]he  meaning of the word ‘legislature,’ used several times in the Federal Constitution, differs according to the connection in which it is employed, depend[ent] upon the character of the function which that body in each instance is called upon to exercise.” Atlantic Cleaners & Dyers, Inc. v. United States, 286 U. S. 427, 434 (1932) (citing Smiley, 285
U. S. 355). Thus “the Legislature” comprises the referendum and the Governor’s veto in the context of regulating congressional elections.

Chief Justice Roberts also addresses the functionalism argument of "legislature":

As a matter of ordinary language and common sense, however, a difference in function does not imply a difference in meaning. A car, for example, generally serves a transportation function. But it can also fulfill a storage function. At a tailgate party or a drive-in movie, it may play an entertainment function. In the absence of vacancies at the roadside motel, it could provide a lodging function. To a neighbor with a dead battery, it offers an electricity generation function. And yet, a person describing a“car” engaged in any of these varied functions would undoubtedly be referring to the same thing.

Sixth, the Court struggles with congressional election precedent (more on this later--I have much to say!). It examine Baldwin v. Trowbridge, as Congress examined whether to seat someone elected pursuant to the state legislature's rules or the constitutional rules. From Justice Ginsburg:

The House Elections Committee, in a divided vote, ruled that, under the Elections Clause, the Michigan Legislature had the paramount power.
As the minority report in Baldwin pointed out, however,the Supreme Court of Michigan had reached the opposite conclusion, holding, as courts generally do, that state legislation in direct conflict with the State’s constitution is void. Baldwin, H. R. Misc. Doc. No. 152, at 50. The Baldwin majority’s ruling, furthermore, appears in tension with the Election Committee’s unanimous decision in Shiel just five years earlier. (The Committee, we repeat,“ha[d] no doubt that the constitution of the State ha[d]fixed, beyond the control of the legislature, the time for holding [a congressional] election.” Shiel, H. R. Misc. Doc. No. 57, at 351.) Finally, it was perhaps not entirely accidental that the candidate the Committee declared winner in Baldwin belonged to the same political party as all but one member of the House Committee majority responsible for the decision.

And from Chief Justice Roberts:

The House Elections Committee explained that the Elections Clause conferred power on “the Legislature” of  Michigan to prescribe election regulations. “But,” the Committee asked, “what is meant by ‘the legislature?’ Does it mean the legislative power of the State, whichwould include a convention authorized to prescribe fundamental law; or does it mean the legislature eo nomine, as known in the political history of the country?” Id., at 47. The Committee decided, and the full House agreed,that “the Legislature” in the Elections Clause was the “legislature eo nomine”—the legislature by that name, a representative body.
...
The report cites a Michigan Supreme Court precedent that allegedly reached a contrary result, but that case turned entirely on state constitutional questions arising from a state election—not federal constitutional questions arising from a federal election. . . . In any event, to the degree that the two precedents are inconsistent, the later decision in Baldwin should govern
[n.3] The majority’s suggestion that Baldwin should be dismissed as an act of partisanship appears to have no basis, unless one is willing to regard as tainted every decision in favor of a candidate from the same party as a majority of the Elections Committee.

Seventh, Justice Scalia (joined by Justice Thomas) writes that this is not within the Article III power of the courts, particularly citing the shaky foundation of Coleman v. Miller as a basis for asserting authority over the case. And Justice Thomas (joined by Justice Scalia) noted that this case is not truly about deferring to state ballot initiatives, as the Court has felt comfortable striking down such regulations before.

Not many surprises in the opinions, I don't think. But, there is much to delve into in the months ahead.

Scalia, Roberts discuss the Elections Clause in dueling King v. Burwell opinions

King v. Burwell (PDF) is a statutory interpretation case about health care exchanges, but the Elections Clause makes an appearance.

From Justice Scalia's dissent:

To see the error in this reasoning, one need only consider a parallel provision from our Constitution: “The Times, Places and Manner of holding Elections for Senators and Representatives, shall be prescribed in each State by the Legislature thereof; but the Congress may at any time by Law make or alter such Regulations.” Art. I, §4, cl. 1 (emphasis added). Just as the Affordable Care Act directs States to establish Exchanges while allowing the Secretary to establish “such Exchange” as a fallback, the Elections Clause directs state legislatures to prescribe election regulations while allowing Congress to make “such Regulations” as a fallback. Would anybody refer to an election regulation made by Congress as a “regulation prescribed by the state legislature”? Would anybody say that a federal election law and a state election law are in all respects equivalent? Of course not. The word “such” does not help the Court one whit.

And Chief Justice Roberts's response in footnote 2:

The dissent argues that the phrase “such Exchange” does not suggest that State and Federal Exchanges “are in all respects equivalent.” Post, at 8. In support, it quotes the Constitution’s Elections Clause, which makes the state legislature primarily responsible for prescribing election regulations, but allows Congress to “make or alter such Regulations.” Art. I, §4, cl. 1. No one would say that state and federal election regulations are in all respects equivalent, the dissent contends, so we should not say that State and Federal Exchanges are. But the Elections Clause does not precisely define what an election regulation must look like, so Congress can prescribe regulations that differ from what the State would prescribe. The Affordable Care Act does precisely define what an Exchange must look like, however, so a Federal Exchange cannot differ from a State Exchange.

 

Challenges implementing federal automatic voter registration

Last week, Hillary Clinton proposed automatic voter registration at a campaign event. I'd like to focus less on the wisdom of such a proposal and more about the challenges that would confront an actual piece of legislation. Fortunately, we have that bill, H.R. 2694, the Automatic Voter Registration Act. It was introduced yesterday, June 9, by David Cicilline of Rhode Island, and currently has 42 co-sponsors (all Democrats).

The bill would amend the National Voter Registration Act of 1993 for automatic voter registration of anyone who registers with a state's department of motor vehicles for a driver's license, unless that person opts out. The following information would be collected:

(a)(2)(A) The individual’s legal name.

(B) The individual’s age.

(C) The individual’s residence.

(D) The individual’s citizenship status.

(E) The individual’s electronic signature.

I pause to wonder what this means for the myriad other things that come along with voter registration. Some states ask for your party affiliation; would all automatically-registered voters simply not be affiliated with a party (and perhaps be ineligible to vote in a state primary unless they took the affirmative step to affiliate)? Many states forbid ex-felons from voting (which is probably less problematic for 16-year-olds applying for driver's licenses but could impact other applicants). Would automatic registration force states to ignore ex-felon status?

Indeed, the proposed law would actually abolish Section 5 of the current NVRA, which requires states to provide a form that would include "the minimum amount of information necessary to (i) prevent duplicate voter registrations; and (ii) enable State election officials to assess the eligibility of the applicant and to administer voter registration and other parts of the election process." (That form has led to some recent litigation of note.) So it appears that the "federal form" would no longer exist under such a proposal, and a smaller quantum of information would be provided for registration.

Of course, another sticky point is citizenship status. Some states have moved away from requiring proof of citizenship status to obtain a driver's license, and others have sought more aggressive citizenship investigation in their own states. The law would qualify the collection and use of this information:

(3) Restriction on use of information on citizenship status. A State may not use any identifying information regarding an individual’s citizenship status which is transmitted under this subsection for any purpose other than determining whether the individual is eligible to vote in elections for Federal office.

It would allow states to collect information on citizenship status, but then forbid them for using that information for any reason other than voter registration.

And the final twist is that this law, like others, would only apply to federal elections. Arizona disapproved of the federal form so strongly regarding its own proof of citizenship that it developed a federal-only ballot for those acting pursuant to the Election Assistance Commission's directive, and a ballot for its state and federal elections for those who could also comply with state law apart from the EAC. There's some risk that an undertheorized--or, perhaps, simply unpopular--"automatic" voter registration that affects only federal races would prompt states to create a dual track for ballots. (Whether that could be mitigated with conditional federal funding or other types of incentives is another matter.)

Again, the purposes of this discussion is not to address the underlying merits of automatic voter registration. Instead, it's simply to highlight some of the challenges that may exist in actually implementing it at a federal level--and, with an actual bill now before Congress (with, admittedly, little likelihood of enactment), it's a point for some actual discussion.

Notable pending election law bills in the 114th Congress

Here's the list of notable election law bills in the 114th Congress. ("Notable," in that I've decided they're notable?) It does not include any proposed constitutional amendments.

Two trends notable among these notables. First, none have made it out of committee. Second, I'd guess a majority are have serious constitutional doubts anyway, so maybe it's better that way?

H.R. 12: Voter Empowerment Act of 2015 (introduced March 19, 2015, by John Lewis; 178 co-sponsors). "To modernize voter registration, promote access to voting for individuals with disabilities, protect the ability of individuals to exercise the right to vote in elections for Federal office, and for other purposes."

H.R. 20: Government By the People Act of 2015 (introduced January 21, 2015, by John Sarbanes; 147 co-sponsors). "To reform the financing of Congressional elections by broadening participation by small dollar donors, and for other purposes."

H.R. 154: Close the Floodgates Act (introduced January 6, 2015, by Derek Kilmer; 87 co-sponsors). "To repeal the provisions of the Consolidated and Further Continuing Appropriations Act, 2015, which amended the Federal Election Campaign Act of 1971 to establish separate contribution limits for contributions made to national parties to support Presidential nominating conventions, national party headquarters buildings, and recounts."

H.R. 367: Campaign Sunlight Act of 2015 (introduced January 14, 2015, by Theodore Deutch; 7 co-sponsors). "To amend the Federal Election Campaign Act of 1971 to require the Federal Election Commission to establish and operate a website through which members of the public may view the contents of certain political advertisements, to require the sponsors of such advertisements to furnish the contents of the advertisements to the Commission, and for other purposes."

H.R. 411: Streamlined and Improved Methods at Polling Locations and Early (SIMPLE) Voting Act of 2015 (introduced January 20, 2015, by Steve Cohen; 27 co-sponsors). "To amend the Help America Vote Act of 2002 to promote early voting in elections for Federal office and to prevent unreasonable waiting times for voters at polling places used in such elections, and for other purposes."

H.R. 412: To reduce Federal spending and the deficit by terminating taxpayer financing of presidential election campaigns (introduced January 20, 2015, by Tom Cole; 1 co-sponsor).

H.R. 425: Stop Super PAC-Candidate Coordination Act (introduced January 21, 2015, by David Price; 6 co-sponsors). "To amend the Federal Election Campaign Act of 1971 to clarify the treatment of coordinated expenditures as contributions to candidates, and for other purposes."

H.R. 599: Stop Targeting of Political Beliefs by the IRS Act of 2015 (introduced January 28, 2015, by Paul Ryan; 13 co-sponsors). "To prohibit the Internal Revenue Service from modifying the standard for determining whether an organization is operated exclusively for the promotion of social welfare for purposes of section 501(c)(4) of the Internal Revenue Code of 1986."

H.R. 714: Leadership PAC Limitation Act (introduced February 4, 2015, by Michael Capuano; 2 co-sponsors). "To amend the Federal Election Campaign Act of 1971 to prohibit the conversion of leadership PAC funds to personal use."

H.R. 871: Formerly Incarcerated Voter Registration Act of 2015 (introduced February 11, 2015, by Hakeem Jeffries; 1 co-sponsor). "To amend title 18, United States Code, to direct the Bureau of Prisons to provide certain voting information to Federal prisoners upon their release from prison."

H.R. 885: Voting Rights Amendment Act of 2015 (introduced February 11, 2015, by Jim Sensenbrenner; 64 co-sponsors). "To amend the Voting Rights Act of 1965 to revise the criteria for determining which States and political subdivisions are subject to section 4 of the Act, and for other purposes."

H.R. 951: State Sovereignty in Voting Act (introduced February 12, 2015, by Matt Salmon; 4 co-sponsors). "To amend the National Voter Registration Act of 1993 to permit a State to require an applicant for voter registration in the State who uses the Federal mail voter registration application form developed by the Election Assistance Commission under such Act to provide documentary evidence of citizenship as a condition of the State's acceptance of the form."

H.R. 1346: Redistricting Transparency Act of 2015 (introduced March 10, 2015, by Jim Cooper; 19 co-sponsors). "To require States to carry out Congressional redistricting in accordance with a process under which members of the public are informed of redistricting proposals and have the opportunity to participate in the development of such proposals prior to their adoption, and for other purposes."

H.R. 1347: John Tanner Fairness and Independence in Redistricting Act (introduced March 10, 2015, by Jim Cooper; 14 co-sponsors). "To prohibit States from carrying out more than one Congressional redistricting after a decennial census and apportionment, to require States to conduct such redistricting through independent commissions, and for other purposes."

H.R. 1518: Let It Go Act (introduced March 19, 2015, by Mark Takano; 1 co-sponsor). "To amend the Federal Election Campaign Act of 1971 to provide for a limitation on the time for the use of contributions or donations, and for other purposes."

H.R. 2143: EMPOWER Act (introduced April 30, 2015, by David Price; 1 co-sponsor). "To amend the Internal Revenue Code of 1986 to reform the system of public financing for Presidential elections, and for other purposes."

H.R. 2173: Redistricting Reform Act of 2015 (introduced April 30, 2015, by Zoe Lofgren; 35 co-sponsors). "To require States to conduct Congressional redistricting through independent commissions, and for other purposes."

H.R. 2392: Restoring Important Voter Eligibility Requirements to States Act of 2014 (introduced May 18, 2015, by John Culberson; 1 co-sponsor). "To amend the National Voter Registration Act of 1993 to require an applicant for voter registration for elections for Federal office to affirmatively state that the applicant meets the eligibility requirements for voting in such elections as a condition of completing the application, to require States to verify that an applicant for registering to vote in such elections meets the eligibility requirements for voting in such elections prior to registering the applicant to vote, and for other purposes."

H.R. 2501: Citizens’ Districts Preservation Act (introduced May 21, 2015, by Dana Rohrabacher; 15 co-sponsors). "To require certain States to retain the Congressional redistricting plans in effect as of the first day of the One Hundred Fourteenth Congress until such States carry out a redistricting plan in response to the apportionment of Representatives resulting from the regular decennial census conducted in 2020."

S. 212: LINE Act of 2015 (introduced January 21, 2015, by Barbara Boxer; 3 co-sponsors). "A bill to amend the Help America Vote Act of 2002 to ensure that voters in elections for Federal office do not wait in long lines in order to vote."

S. 229: Democracy Is Strengthened by Casting Light On Spending in Elections Act of 2015 (introduced January 21, 2015, by Sheldon Whitehouse; 42 co-sponsors). "A bill to amend the Federal Election Campaign Act of 1971 to provide for additional disclosure requirements for corporations, labor organizations, Super PACs and other entities, and for other purposes." (See also H.R. 430.)

S. 366: Senate Campaign Disclosure Parity Act (introduced February 4, 2015, by John Tester; 37 co-sponsors). "A bill to require Senate candidates to file designations, statements, and reports in electronic form."

S. 457: Civil Rights Voting Restoration Act of 2015 (introduced February 11, 2015, by Rand Paul; 1 co-sponsor). "A bill to secure the Federal voting rights of non-violent persons when released from incarceration." (See also H.R. 1556.)

S. 772: Democracy Restoration Act of 2015 (introduced March 18, 2015, by Ben Cardin; 10 co-sponsors). "A bill to secure the Federal voting rights of persons when released from incarceration." (See also H.R. 1459.)

S. 1088: Voter Registration Modernization Act (introduced April 27, 2015, by Kirsten Gillibrand; 5 co-sponsors). "A bill to amend the National Voter Registration Act of 1993 to provide for voter registration through the Internet, and for other purposes."

S. 1139: Same Day Registration Act (introduced April 30, 2015, by Amy Klobuchar; 1 co-sponsor). "A bill to amend the Help America Vote Act of 2002 to require States to provide for same day registration."