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New State Voting Laws II: Protecting the Right to Vote in the Sunshine State

The Brennan Center for Justice submitted written testimony for a U.S. Senate hearing examining Florida’s new election law, H.B. 1355, stating that the law’s onerous restrictions on community-based voter registration drives are unconstitutional and offering solutions for modernizing the state’s voter registration system.

Published: January 27, 2012

Down­load full testi­mony [pdf]

The Bren­nan Center for Justice at New York Univer­sity School of Law thanks Chair­man Leahy and the Senate Judi­ciary Subcom­mit­tee on the Consti­tu­tion, Civil Rights, and Human Rights for provid­ing this oppor­tun­ity to submit writ­ten testi­mony in advance of the import­ant field hear­ing, “New State Voting Laws II: Protect­ing the Right to Vote in the Sunshine State.”

The Bren­nan Center is a nonpar­tisan think tank and legal advocacy organ­iz­a­tion that focuses on issues of demo­cracy and justice. Among other things, we seek to ensure fair and accur­ate voting proced­ures and systems and to promote policies that maxim­ize citizen enfran­chise­ment and parti­cip­a­tion in elec­tions. We have done extens­ive work on a range of issues relat­ing to voting rights, includ­ing work to remove unne­ces­sary barri­ers to voter regis­tra­tion; to make voting machines more secure, reli­able, usable, and access­ible; and to expand access to the fran­chise. Our work on these topics has included the public­a­tion of stud­ies and reports; assist­ance to federal and state admin­is­trat­ive and legis­lat­ive bodies with respons­ib­il­ity over elec­tions; and, when neces­sary, parti­cip­a­tion in litig­a­tion to compel states to comply with their oblig­a­tions under federal law and the Consti­tu­tion. We submit this testi­mony today in our capa­city as national advoc­ates of voting rights commit­ted to (1) prevent­ing efforts, such as Flor­id­a’s H.B. 1355 (altern­at­ively “the Law”), to constrict voter regis­tra­tion and parti­cip­a­tion and (2) promot­ing improve­ments that will make our elec­tion system secure and access­ible to all eligible Amer­ic­ans.  

The harm caused by HB 1355 to Flor­ida voters and community-based voter regis­tra­tion groups is so severe that several organ­iz­a­tions and indi­vidu­als have been forced to turn to the courts for relief. In Flor­ida v. United States, the Bren­nan Center is co-coun­sel[1] to the League of Women Voters of Flor­ida (“LWVF”) and the National Coun­cil of La Raza (“NCLR”), who oppose HB 1355 because of the harm it will cause to minor­ity voters.[2]  The Bren­nan Center also repres­ents[3] LWVF, Rock the Vote (“RTV”), and Flor­ida Public Interest Research Group’s Educa­tion Fund (“FL PIRG”) in LWVF v. Brown­ing, a broad chal­lenge to the Law on the basis that its provi­sions viol­ate the U.S. Consti­tu­tion, the National Voter Regis­tra­tion Act, and the Voting Rights Act.

In this state­ment, the Bren­nan Center will detail why the discrim­in­at­ory provi­sions of HB 1355 should be struck down. We will also suggest long-term improve­ments to Flor­id­a’s anti­quated paper-based regis­tra­tion system that would save the State signi­fic­ant money and time processing paper regis­tra­tion forms, while also increas­ing the inclus­ive­ness and accur­acy of the voter rolls.


HB 1355 is the third and most heavy-handed set of rules and penal­ties enacted by the State of Flor­ida in the past six years to regu­late the community-based voter regis­tra­tion activ­it­ies of indi­vidu­als and organ­iz­a­tions who advoc­ate for greater voter parti­cip­a­tion and who help their fellow citizens register to vote. HB 1355’s newly enhanced and tightened restric­tions on those consti­tu­tion­ally protec­ted efforts were adop­ted with barely the pretense of justi­fic­a­tion, other than to erect addi­tional and unwar­ran­ted barri­ers to regis­tra­tion and voting.

Despite the devast­at­ing impact HB 1355 would have on voter parti­cip­a­tion, this latest step in Flor­id­a’s serial effort to repress the voter regis­tra­tion activ­it­ies of community-based groups sped through the legis­lat­ive process in 2011. The Flor­ida Legis­lature considered no evid­ence demon­strat­ing that such grave restric­tions were neces­sary to prevent voter regis­tra­tion fraud or preserve the integ­rity of the elec­tion process. Nor did HB 1355’s proponents offer any basis at all to conclude that the exist­ing legal regime, includ­ing the voter regis­tra­tion law passed just three years ago, has been inad­equate to address whatever dangers may exist.

Restric­tions on voter regis­tra­tion are partic­u­larly trouble­some in light of Flor­id­a’s declin­ing voter regis­tra­tion rates. In 2004, before Flor­ida began restrict­ing community-based voter regis­tra­tion drives, Flor­ida ranked 33rd in the nation in voter regis­tra­tion rates, with 71.7% of voting age citizens registered. In 2010, Flor­ida dropped to 38th in the nation in voter regis­tra­tion rates, with only 63% of voting age citizens registered.[4] Simil­arly, the over­all number of regis­tra­tion forms received in Flor­ida has stead­ily declined. From 2000 to 2004, Flor­ida received over 8.6 million voter regis­tra­tion forms. From 2006 to 2010, after restric­tions on community-based regis­tra­tion efforts were imple­men­ted, the total number of voter regis­tra­tion forms received dropped to just under 3 million.

HB 1355 can only exacer­bate these down­ward trends. And unfor­tu­nately, the impacts of this law will fall most heav­ily on the shoulders of Flor­id­a’s voters of color.

In general, community-based voter regis­tra­tion drives register signi­fic­ant numbers of citizens to vote in Flor­ida. Accord­ing to the U.S. Census Bureau’s Current Popu­la­tion Survey, as of the Novem­ber 2010 elec­tion, 7.3% of all registered voters, which would trans­late to 585,004 Flor­ida citizens, had been registered to vote through such third-party drives in Flor­ida. Those numbers are signi­fic­antly higher for communit­ies of color.

As of 2010 in Flor­ida, 10% of African-Amer­ican registered voters and 12% of Hispanic registered voters in Flor­ida were registered through drives, compared to only 5.3% of non-Hispanic white registered voters.[5] Simil­arly, African Amer­ic­ans and Lati­nos registered to vote through voter regis­tra­tion drives at approx­im­ately twice the rate as white voters in 2004 and 2008. The large emphasis on voter regis­tra­tion drives in Flor­ida is one major reason why racial dispar­it­ies in voter regis­tra­tion are lower in Flor­ida than most states. But, due to HB 1355, many organ­iz­a­tions and indi­vidu­als, includ­ing those that specific­ally reach out to minor­ity communit­ies, have been forced to suspend or severely curtail their voter regis­tra­tion efforts.  

Unsur­pris­ingly, during its consid­er­a­tion by the legis­lature, HB 1355 was strongly opposed by minor­ity lead­ers in Flor­ida. And, because of HB 1355’s dispar­ate impact, numer­ous civil rights organ­iz­a­tions and indi­vidu­als have inter­vened in Flor­ida v. United States to illus­trate how the law harms minor­ity voters.[6]

The Law Severely Burdens Community Voter Regis­tra­tion Efforts

The exper­i­ences of the League of Women Voters of Flor­ida (LWVF), Rock the Vote (RTV) and Flor­ida Public Interest Research Group Educa­tion Fund (FL PIRG)—three volun­teer-driven, non-profit organ­iz­a­tions with long histor­ies of help­ing to register voters in Flor­id­a—il­lus­trate the myriad burdens imposed by HB 1355.

  • The LWVF is the Flor­ida affil­i­ate of the national League of Women Voters. Cent­ral to the group’s mission is encour­aging the informed, active parti­cip­a­tion of citizens in govern­ment, includ­ing voter regis­tra­tion. LWVF has approx­im­ately 2,800 current dues-paying members, and a list of about 9,000 members, support­ers, and volun­teers who receive regu­lar commu­nic­a­tions. LWVF conducts voter regis­tra­tion drives via 29 local chapters through­out Flor­ida. These local voter regis­tra­tion efforts are wholly volun­teer-run and are cent­ral to LWVF’s abil­ity to engage with its member­ship and volun­teers. Voter regis­tra­tion goes hand-in-hand with virtu­ally all of LWVF’s public educa­tion efforts, as well as many of their advocacy activ­it­ies.

Many of LWVF’s outreach activ­it­ies are direc­ted at tradi­tion­ally under­rep­res­en­ted communit­ies. For instance, the Orange County League spear­headed the “Vamos A Votar Coali­tion,” a nonpar­tisan campaign to increase Hispanic voter parti­cip­a­tion in Cent­ral Flor­ida and statewide. And, the Miami/Dade County League reaches out to histor­ic­ally under­rep­res­en­ted communit­ies in their county by publish­ing regis­tra­tion inform­a­tion in English, Span­ish, and Creole. Simil­arly, some local Leagues, includ­ing the Jack­son­ville/First Coast League, regu­larly attend natur­al­iz­a­tion cere­mon­ies in their communit­ies. There, they intro­duce new U.S. citizens to one of the most import­ant oppor­tun­it­ies and respons­ib­il­it­ies of citizen­ship by assist­ing them in regis­ter­ing to vote.

  • RTV is a national organ­iz­a­tion whose funda­mental mission is to build polit­ical power for young people by increas­ing their regis­tra­tion and voter turnout rates. Crit­ical to that mission are the organ­iz­a­tion’s efforts to register young people to vote and to encour­age them to vote on elec­tion days. RTV has approx­im­ately 1.5 million members in its national data­base, includ­ing approx­im­ately 82,000 members in Flor­ida. RTV makes voter regis­tra­tion forms and instruc­tions avail­able on its website and conducts in-person regis­tra­tion drives staffed by volun­teers at college campuses and in other loca­tions.

RTV also offers a “Demo­cracy Class” curriculum for local educat­ors that teaches students about the import­ance of voting and offers regis­tra­tion oppor­tun­it­ies. RTV provides a “toolkit” of mater­i­als that teach­ers can use to supple­ment their class instruc­tion about civic engage­ment and the right to vote. It includes a video about the right of 18-year-olds to vote, lesson plans for staging a mock elec­tion in class, and a set of voter regis­tra­tion mater­i­als for the students.

  • FL PIRG is an affil­i­ate of the national Public Interest Research Group and strives to ensure equal access to the polit­ical process by, among other things, regis­ter­ing voters. FL PIRG focuses its voter regis­tra­tion efforts on student popu­la­tions within Flor­ida, and since the 2004 elec­tion cycle, it has registered approx­im­ately 23,000 Flor­idi­ans. FL PIRG hires and trains campus organ­izers, often recent college gradu­ates, to plan and organ­ize voter regis­tra­tion drives at college campuses around the coun­try. FL PIRG also conducts door-to-door regis­tra­tion drives.

FL PIRG’s voter regis­tra­tion efforts have been partic­u­larly success­ful in enga­ging minor­ity citizens. For example, in 2008, 42% of the citizens FL PIRG registered self-iden­ti­fied as members of a racial or ethnic minor­ity group.

Voter regis­tra­tion is clearly a cent­ral part of each of these groups’ missions. HB 1355 creates a laun­dry list of restric­tions that severely impede such community-based voter regis­tra­tion efforts, and trans­forms the act of assist­ing others to register to vote into an exceed­ingly complex and highly risky activ­ity. For example, HB 1355 imposes, under threat of severe finan­cial penal­ties and poten­tial crim­inal prosec­u­tion, a require­ment on any person (not just on organ­iz­a­tions) to pre-register with the State in order to “soli­cit” or “collect” voter regis­tra­tion applic­a­tions, and requires such persons or organ­iz­a­tions to track and report on every single voter regis­tra­tion applic­a­tion that they handle, includ­ing applic­a­tions that are never completed or collec­ted.[7] HB 1355 also requires that every completed voter regis­tra­tion applic­a­tion be delivered to the State within an arbit­rar­ily narrow and unne­ces­sar­ily prohib­it­ive 48-hour window, under the penalty of strict monet­ary fines.[8] Moreover, HB 1355 sets forth vague but omin­ous penal­ties for even a minor, unin­ten­tional act of noncom­pli­ance with any provi­sions of the Law.[9]

As detailed in their sworn affi­davits submit­ted in support of a motion seek­ing a federal court order to enjoin the Law,[10] because of its burden­some restric­tions, LWVF, RTV, and FL PIRG have all ceased, or dramat­ic­ally cut back, their voter regis­tra­tion efforts in Flor­ida.    

  • Ms. Macnab, Pres­id­ent of the League of Women Voters of Flor­ida, explains: “As a result of the new Law, LWVF has ordered a statewide cessa­tion of voter regis­tra­tion until the Law is enjoined or limited in such a way as to substan­tially reduce the organ­iz­a­tional and finan­cial risk to the League, its members, and volun­teer­s…The local Leagues oper­ate on a decent­ral­ized model with an all-volun­teer force, which has success­fully registered tens of thou­sands of Flor­idi­ans to vote over the last 72 years without incid­ent. The 48-hour require­ment would require LWVF and its local Leagues to dramat­ic­ally revise their proced­ures in a manner that would require volun­teers to become detailed time­keep­ers and create strict sched­ules to ensure that forms were handed in before the clock strikes 48 hours—and do all this under the tick­ing time bomb of civil penal­ties and fines.” Moreover, “[m]any LWVF volun­teers are elderly and depend on others for trans­port. They may have a partic­u­larly hard time meet­ing the 48-hour dead­line.” Ms. Macnab goes on to explain how voter regis­tra­tion activ­ity is crucial to the LWVF’s abil­ity to recruit new volun­teers and retain active members: “Help­ing other Flor­idi­ans to register to vote is one of the most popu­lar and effect­ive volun­teer oppor­tun­it­ies with LWVF, and it has consist­ently been one of the best ways to get new volun­teers inves­ted in our work…I have come to believe that indi­vidu­als who begin volun­teer­ing even a few hours help­ing to register their fellow citizens to vote find the activ­ity extremely reward­ing and feel a sense of purpose and connec­tion to their demo­cracy. Many, if not most, of our seasoned volun­teers, stal­wart support­ers, and State Board members began volun­teer­ing their time at a LWVF voter regis­tra­tion drive table. My own very first hour spent volun­teer­ing with LWVF was behind such a table.”     

See Exhibit B for Ms. Macnab’s full affi­davit detail­ing HB 1355’s impacts on the LWVF’s voter regis­tra­tion activ­ity.

  • Rock the Vote’s community-based voter regis­tra­tion activ­ity in Flor­ida has also ceased in the face of HB 1355’s extreme require­ments. In the words of Pres­id­ent Heather Smith, “RTV is extremely concerned that the Law will make it exceed­ingly diffi­cult to encour­age student volun­teer­ism with us. The Law now requires each ‘regis­tra­tion agent’ to sign a sworn form detail­ing severe felony penal­ties that result from false regis­tra­tion. While we train our volun­teers to ensure no one falls afoul of these laws, intro­du­cing a student to civic parti­cip­a­tion and volun­teer­ism via a list of felony penal­ties, in turn signed under felony penalty of perjury, is intim­id­at­ing and scary for many students. The nature of the required form will lead to fewer students who are will­ing to parti­cip­ate in and volun­teer in RTV’s voter regis­tra­tion activ­ity, partic­u­larly on a spon­tan­eous basis.” Like­wise, Ms. Smith affirms that “[T]here is no ques­tion that we will have to drastic­ally cut back, or perhaps discon­tinue, our regis­tra­tion efforts in Flor­ida. We have already suspen­ded our Demo­cracy Class program and our in-person voter regis­tra­tion work in the state of Flor­ida since the Law’s passage.”  The cessa­tion of RTV’s Demo­cracy Class in Flor­ida is partic­u­larly signi­fic­ant because RTV has “had to turn down requests from indi­vidu­als and teach­ers in Flor­ida to collab­or­ate on voter regis­tra­tion activ­ity due to the Law’s burden­some new require­ments.”  This is because HB 1355 will prevent RTV from incor­por­at­ing voter regis­tra­tion into Demo­cracy Class. “Without the voter regis­tra­tion compon­ent,” Ms. Smith explains, “Demo­cracy Class will be signi­fic­antly less effect­ive in advan­cing RTV’s mission of getting young people involved in the polit­ical process.”

See Exhibit E for Ms. Smith’s full affi­davit detail­ing HB 1355’s impacts on RTV’s voter regis­tra­tion activ­ity.

  • Brad Ashwell, Advoc­ate for Flor­ida PIRG, explains how HB 1355 simil­arly impacts his organ­iz­a­tion’s abil­ity to engage in voter regis­tra­tion: “FL PIRG will have to require every person assist­ing with voter regis­tra­tion to sign sworn state­ments threat­en­ing crim­inal prosec­u­tion for false regis­tra­tions before they can engage in regis­tra­tion activ­it­ies. From my exper­i­ence work­ing with students and other young people, I believe the intim­id­at­ing regis­tra­tion agent form will signi­fic­antly burden FL PIRG’s abil­ity to recruit volun­teers. Some students will hesit­ate to join our volun­teer efforts, partic­u­larly those drawn in spon­tan­eously, if they must first sign a form list­ing multiple felony penal­ties. Moreover, certain school admin­is­trat­ors will not want their students to parti­cip­ate in voter regis­tra­tion drives for fear of fines or repu­ta­tional damage to the school.” Further­more, Mr. Ashwell explains, “The Law’s require­ment that forms be submit­ted within 48 hours of collec­tion will be extremely diffi­cult to comply with in many circum­stances. The 48-hour turn­around time is partic­u­larly troub­ling as it relates to FL PIRG’s frequent voter regis­tra­tion work during the even­ing. Night­time events are extremely effect­ive on campus, after classes are over and when students have more time to complete voter regis­tra­tion applic­a­tions. But under the law, conduct­ing voter regis­tra­tion efforts after 5:00 p.m. becomes more complic­ated because of the 48-hour require­ment.” 

See Exhibit F for Mr. Ashwell’s full affi­davit detail­ing HB 1355’s impacts on the FL PIRG’s voter regis­tra­tion activ­ity.

Though it has been in effect for only a short time, the oner­ous burdens of HB 1355 are already clear. Multiple groups, whose char­it­able missions revolve around protect­ing and expand­ing the fran­chise, have ceased or signi­fic­antly curtailed their regis­tra­tion activ­it­ies through­out the State out of fear that they will be unable to comply with HB 1355’s require­ments and thus be subject to fines, crip­pling civil and crim­inal penal­ties, and devast­at­ing repu­ta­tional harm. HB 1355’s severe restric­tions effect­ively preclude these groups from advan­cing a shared belief in the import­ance of parti­cip­at­ory demo­cracy and wide­spread voter regis­tra­tion.

Policy Recom­mend­a­tions

Rather than making it more diffi­cult for Flor­idi­ans to vote, the State should be work­ing to encour­age wide­spread parti­cip­a­tion and increase voter regis­tra­tion rates. Respons­ib­il­ity for voter regis­tra­tion must be trans­ferred from the citizens to the govern­ment, and Flor­ida must upgrade its regis­tra­tion process. Flor­id­a’s anti­quated, paper-based regis­tra­tion system is expens­ive, inef­fi­cient and prone to errors which can disen­fran­chise voters.

Current voter regis­tra­tion require­ments place the onus of regis­ter­ing on the voter, and block the proper func­tion­ing of an inclus­ive demo­cratic system. Our coun­try’s tradi­tional voter regis­tra­tion system was not designed for a mobile soci­ety where one in six Amer­ic­ans moves every year. Of the 57 million citizens who were not registered to vote in 2000, one in three was a former voter who had moved but failed to register. Unsur­pris­ingly, regis­tra­tion prob­lems alone kept up to 3 million eligible Amer­ic­ans from voting in 2008.   

Four key compon­ents are neces­sary for Flor­ida to modern­ize its voter regis­tra­tion system: auto­matic regis­tra­tion, perman­ent regis­tra­tion, online regis­tra­tion, and Elec­tion Day regis­tra­tion.

  • Auto­matic Regis­tra­tion: Flor­ida should auto­mat­ic­ally register eligible citizens to vote using avail­able data­bases main­tained by motor vehicle author­it­ies and other state agen­cies, as well as federal data­bases such as the Select­ive Service.
  • Perman­ent Regis­tra­tion: When voters move within a state, they should stay on the voter rolls. HB 1355 has taken Flor­ida a step back­wards in time: it elim­in­ated Flor­id­a’s long­stand­ing and success­ful prac­tice of permit­ting movers to make any in-state address change at the polls. Voters should remain perman­ently registered unless they move from the state.   
  • Online Regis­tra­tion: Flor­ida should make this conveni­ent form of regis­tra­tion avail­able. Stud­ies show that online regis­tra­tion is more secure and cost-effect­ive than paper. While Flor­ida offers its voter regis­tra­tion form online to complete and print, it should take the next step and develop a system that permits voters to submit and update their voter regis­tra­tion online.
  • Elec­tion Day Correc­tion: Flor­ida should allow eligible citizens to register and correct their regis­tra­tion on Elec­tion Day. This has already been imple­men­ted in many states, and tech­no­lo­gical advances ensure that it can be done securely. It serves as a fail-safe meas­ure to prevent voters from being disen­fran­chised by regis­tra­tion errors.

There is simply no reason to make people navig­ate a cumber­some, 19th-century model of voter regis­tra­tion when there are more effi­cient, cost-effect­ive, and reli­able meth­ods avail­able.  In a modern­ized voter regis­tra­tion system, inform­a­tion contained in exist­ing data­bases—such as those held by state depart­ments of motor vehicles, public assist­ance agen­cies, state tax author­it­ies or, for example, the federal Select­ive Service list—­would be sorted and sent to elec­tion offi­cials. After checks to verify citizen­ship and avoid duplic­ate regis­tra­tion, these citizens would be auto­mat­ic­ally registered to vote. Altern­at­ively, citizens could register through a secure online system. On Elec­tion Day, any eligible voter whose name did not appear on the voter rolls or whose name appeared with inac­cur­ate inform­a­tion could correct her regis­tra­tion and vote a regu­lar ballot, rather than being turned away or forced to vote provi­sion­ally. States that have imple­men­ted these reforms have enjoyed increased regis­tra­tion rates, cost savings, and fewer regis­tra­tion errors. Flor­ida has already adop­ted reforms in the wake of the federal “motor voter” law, and there­fore already has many of the tools needed to fully imple­ment these reforms. Voter regis­tra­tion modern­iz­a­tion would help remove a need­less obstacle that prevents millions from voting. Flor­id­a’s lead­ers should follow this approach instead of making regis­tra­tion even more diffi­cult.

By imple­ment­ing common-sense reforms, Flor­ida can ensure that more citizens are registered to vote while redu­cing burdens on elec­tion offi­cials. These steps would not only boost Flor­id­a’s dismal voter regis­tra­tion rates, they would save the State money in the long run. Flor­ida should over­turn the Law’s unreas­on­able restric­tions on community-based voter regis­tra­tion and instead adopt common-sense reforms to modern­ize voter regis­tra­tion.

[1] Our co-coun­sel in Flor­ida v. United States are the Lawyers’ Commit­tee for Civil Rights Under Law and the law firm Bryan Cave, LLP.

[2] Under the federal Voting Rights Act, changes to Flor­id­a’s elec­tion laws must be “precleared” by the United States Depart­ment of Justice or through a lawsuit in the D.C. federal court.  Flor­ida is currently seek­ing preclear­ance by a D.C. federal court in the case Flor­ida v. United States.

[3] Our co-coun­sel in LWVF v. Brown­ing are law firm Paul, Weiss, Rifkind, Whar­ton & Garrison LLP, the ACLU of Flor­ida, and law firm Coffey Burl­ing­ton.

[4] Data obtained by creat­ing custom tables with the Current Popu­la­tion Survey (CPS) Table Creator for 2004 and 2010, respect­ively. U.S. Census Bureau, Current Popu­la­tion Surveys (Nov. 2004; Nov. 2010). The rate of new voter regis­tra­tions in Flor­ida from 2006 to 2010 simil­arly mirrors the over­all decline in registered voters. From Janu­ary through Octo­ber 2006, there were 479,611 new and valid voter regis­tra­tions in Flor­ida, compared to 363,545 in the same period in 2010, a 24.2% decline. See Flor­ida Divi­sion of Elec­tions, Voter Regis­tra­tion Stat­ist­ics, http://elec­; Voter Regis­tra­tion Year To Date Report, Octo­ber 2006: http://elec­­tra­tion/archives/2006/Octo­ber/YTDTotal.pdf; Voter Regis­tra­tion Year To Date Report, Octo­ber 2010: http://elec­­tra­tion/archives/2010/Octo­ber/YTDTotal.pdf.

[5] U.S. Census Bureau, Current Popu­la­tion Survey (Nov. 2010).

[6] Attached as Exhibit A is a letter by the Bren­nan Center and the Lawyers’ Commit­tee for Civil Rights Under Law further detail­ing these racial impacts, which was submit­ted to the Justice Depart­ment in oppos­i­tion to the preclear­ance of the Law, on behalf of the National Coun­cil of La Raza and the League of Women Voters of Flor­ida.

[7] Fla. Stat. §§ 97.021(37), 97.0575; Fla. Admin. Code Ann. R. 1S-2.042.

[8] Fla. Stat. § 97.0575(3)(a).

[9] Id. §§ 97.0575(4), 104.41.

[10] Each of these affi­davits, which are quoted in part in this state­ment, are appen­ded in their entirety as exhib­its B-F.