June 02, 2005
Flash: Foulkes didn't Meet Foulkes v. Hayes Standard Either

Kenny Foulkes, whose ultimately successful election contest lawsuit of 1977 set the Foulkes v. Hayes precedent for election contests, says that Dino Rossi's case doesn't meet the standard set by the Foulkes case:

Foulkes wishes his case would make the difference. He's a Rossi supporter, but thinks his precedent may not help.

"It's a tough one to prove because they may not be able to prove fraud like me," Foulkes said.

Any comparison to Foulkes v. Hayes (or Hill v. Howell [search here if the link doesn't work]) is a big "so what?" Bear in mind that Kenny Foulkes' case didn't meet the Foulkes v. Hayes standard at the time he argued his case. The Foulkes v. Hayes standard didn't exist yet. It was a new precedent created to deal with the previously uncontemplated circumstances in his lawsuit. Similarly, the circumstances in this lawsuit are also significantly different from previously contemplated cases. Accordingly, I would expect Judge Bridges to forge a new precedent here.

UPDATE: The comment from attorney Shawn Newman is worth highlighting in the main post:

You need to read the entire case and the entire Seattle Times article. Foulkes didn't need to prove fraud - just that there were enough errors, ommissions or problems (leaving the key to the ballot box in the lock). As the Times article indicates, Justice Robert Utter wrote in the unanimous opinion there was no need for Foulkes to show a "smoking gun" — proof of who altered the ballots — because of the evidence of fraud. In fact, the number of altered ballots was less than the margin of victory. But, the court wrote, "the irregularity was such that the actual result of the voting could not be ascertained."

In this case, "Republicans want Chelan County Superior Court Judge John Bridges to use the Foulkes standard. But he has said that they do not have a valid fraud claim and must prove that Rossi would have won if it were not for errors and illegal votes."

So, if Bridges were to apply the Foulkes standard, Rossi wins. If he doesn't, the Supremes could reverse on that grounds. IMHO, Bridges doesn't need to create new precedent here ... he should rely on Foulkes and rule for Rossi.

Posted by Stefan Sharkansky at June 02, 2005 12:06 PM | Email This
Comments
1. Forge

Bad choice of word here, Stefan........ ;o)

Posted by: Scott in Carnation on June 2, 2005 12:08 PM
2. Can't prove fraud? What is an illegal vote by a felon called? How about an illegal vote by an illegal alien? Voting for a dead person? These are all fraudulent actions.

Posted by: Far Star on June 2, 2005 12:14 PM
3. Foulkes obviously wasn't paying any attention to the ruling in his case. The proving of fraud ended up having very little impact on his case, since it couldn't be shown that the fraud actually changed the election. The Republicans have also proved outright fraud (dead people & double voters), which is also not enough to overturn the election, but in both cases, the outright negligence of the election officials demands the same recourse, because it made it impossible to know who won.

Posted by: Timothy on June 2, 2005 12:22 PM
4. You need to read the entire case and the entire Seattle Times article. Foulkes didn't need to prove fraud - just that there were enough errors, ommissions or problems (leaving the key to the ballot box in the lock). As the Times article indicates, Justice Robert Utter wrote in the unanimous opinion there was no need for Foulkes to show a "smoking gun" — proof of who altered the ballots — because of the evidence of fraud. In fact, the number of altered ballots was less than the margin of victory. But, the court wrote, "the irregularity was such that the actual result of the voting could not be ascertained."

In this case, "Republicans want Chelan County Superior Court Judge John Bridges to use the Foulkes standard. But he has said that they do not have a valid fraud claim and must prove that Rossi would have won if it were not for errors and illegal votes."

So, if Bridges were to apply the Foulkes standard, Rossi wins. If he doesn't, the Supremes could reverse on that grounds. IMHO, Bridges doesn't need to create new precedent here ... he should rely on Foulkes and rule for Rossi.

Posted by: Newman on June 2, 2005 12:26 PM
5. What about knowingly falsifying a reconciliation report that caused the canvassing board to certify a result that changed the outcome of the election?

Posted by: Mystified on June 2, 2005 12:28 PM
6. The only reason that fraud would "also not [be] enough to overturn the election," would be if Bridges is not willing to call fraud fraud, and recognize what ALL OF US KNOW -- that the election was stolen.

There is well more than enough to overturn the election and to do otherwise will send a devastating message to the liberal criminals that they are correct in insisting that the end justifies any means. Who knows, maybe it is time for a true revolution. I'm ready.

Either way, no matter what else occurs, failing to overturn this election will be very bad for all of the citizens of Washington State -- especially liberals.

Posted by: Amused by liberals on June 2, 2005 12:34 PM
7. I think the issue has more to do with the remedy for the Foulkes v. Hayes case than meeting the standard involved. Judge Bridges has a clear precedent for setting an election aside and calling for a new election.

If it is ok to have the kinds of discrepancies that King County has exhibited then any election with such a tiny margin of difference should be set aside regardless of who appears to have the most votes.

Posted by: Michael on June 2, 2005 12:39 PM
8. Mystified writes: What about knowingly falsifying a reconciliation report that caused the canvassing board to certify a result that changed the outcome of the election?

The Republicans have provided no evidence, let alone proof, that the false reconciliation report changed the outcome (compared, presumably, with what a correct reconciliation report would have showed). The facts presented show that King County officials, not having (or wanting to get) the figures they needed for the reconciliation report, invented the numbers that would compute. That's bad; they should be punished. But there's no evidence that the election returns were incorrect.

Perhaps you're arguing that if the KC officials had complied with the law, they would have declined to file the reconciliation report. But you provide no evidence that this would have changed the election result. I don't know what would have happened next -- has this ever happened anywhere in the US??? -- but my guess is that a court would have ordered them to certify the election returns as counted, since there was no evidence of fraud.

Posted by: Bruce on June 2, 2005 12:50 PM
9. Bruce, I think Mystified is referring to the fact that Rossi won the election, then based on bad, read, fraudulent information, the results of the election were changed...CG installed as governor.

Mystified, feel free to correct me if I'm wrong, just don't hit me.

Posted by: Danny on June 2, 2005 12:52 PM
10. Danny, you are exactly right. Rossi won the first two counts. Weren't those counts also certified? My point is that Rossi after won twice, fraudulent reports were submitted that turned that around after the Dems got the result they wanted. Sounds like changing an election result to me.

Posted by: Mystified on June 2, 2005 01:12 PM
11. We're dealing with two separate issues here: outright fraud and gross negligence (willful or not). It has been factually established that there is no way to tell who actually won the election, and this is almost exclusively because of the negligence in KC. It has also been factually established that fraudulent documents were used to *enable the certification* of the election.

It has not been established whether the two combined denied Rossi a rightful victory. I think that's irrelevant. More important here is public certainty of fair elections with lawful winners.
Bridges has said he can't call for a revote, only declare a winner. The Foulkes decision calls that into question, and shows precedent for a revote when election results are unknown due to negligence.
I think the outcome is still up in the air, and we need to PRAY for mercy and justice here in Washington. And don't forget, this is the warmup act: the Supremes still get to sing next. Pray, pray pray - and write your papers too... ;-)

Posted by: Rick D on June 2, 2005 01:13 PM
12. Correction. after Rossi, not "Rossi after"

Posted by: Mystified on June 2, 2005 01:14 PM
13. "Republicans want Chelan County Superior Court Judge John Bridges to use the Foulkes standard. But he has said that they do not have a valid fraud claim and must prove that Rossi would have won if it were not for errors and illegal votes."

Bridges is an intelligent person. To prove outright that the fraud cost Rossi the election is impossible. I think there is a standard here that must be such that any reasonable and rational person would conclude that Rossi may well have won the election is a probable standard.

The Dems could just as well say that the fraud was for Rossi but was insufficient to turn the election to him.

One thing is certain; no reasonable and rational person can say that they are confident that Gregoire won. Some people are so partisan that they may say that but they are not reasonable and rational.

Posted by: Ron A. on June 2, 2005 02:51 PM
14. Wouldn't *Democratic* Poll Inspectors - bringing unaccounted Blank Ballots home with them over the weekend prior to the election - then bringing the Poll Books home with them after the election - be equivalent to leaving the key in the lock with respect to Foulkes?

Especially in light of the fact that the Poll Books are not reconcilable?

Posted by: Deborah on June 2, 2005 07:14 PM
15. Bruce wrote "The Republicans have provided no evidence, let alone proof, that the false reconciliation report changed the outcome"

Nor did Mr. Foulkes.

Posted by: Bill on June 3, 2005 08:03 PM
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