|This issue was originally printed on white paper.|
On February 14, the U.S. Senate added this amendment to S.565:
"It is the policy of the United States that any State may, in the administration of any voter registration or other election law, use the social security account numbers issued by the Commissioner of Social Security for the purpose of establishing the identification of individuals affected by such law, and may require any individual who is so affected to furnish to such State or any agency thereof having administrative responsibility for the law involved, the social security account number issued to such individual by the Commissioner of Social Security."
Currently, Hawaii is the only state which requires petition signers to include their Social Security number on a petition for ballot access. Other states are barred from requiring the numbers, due to the federal privacy act of 1974, which forbids states from requiring Social Security numbers for any purpose unless they had already been requiring it. Hawaii is the only state which required the numbers on petitions prior to 1975.
Delaware and Kentucky began requiring the number on ballot access petitions after 1974, but lawsuits by the Socialist Workers and Libertarian Parties forced both states to stop, because of the federal Privacy Act.
However, if the Senate version of S.565 becomes law, all states will be able to require Social Security numbers on petitions. S.565 is expected to pass. It would provide financial assistance to state and local governments, to enable them to buy better vote-counting machines.
The Social Security number amendment was sponsored by Senator John Kyl of Arizona. The only Senator who tried to stop it was Senator Chris Dodd of Arizona. The amendment was passed by voice vote.
Another consequence of the amendment is that states could provide that individuals without a social security number could not register to vote.
Please ask your U.S. Senators, and your member of the U.S. House, to oppose the Social Security number amendment. S.565 is still being debated. Even if it passes in its current form, the House has passed a different version, HR 3295, without the Social Security number provision. Therefore, a conference committee will be needed, and the Social Security number provision might fail to survive the Conference Committee.
Four bills which improve ballot access, or otherwise help minor parties, have made headway in the last month:
1. Connecticut: HB 5257 was introduced on February 14 by the House Government Administration and Elections Committee. It eliminates the requirement that petition circulators must be registered voters. Since the Committee itself introduced the bill, it is very likely that the bill will pass. Connecticut is in the 2nd circuit, and the 2nd circuit (in a case from New York) already ruled that states cannot require petitioners to be registered voters.
2. Kentucky: On January 29, HB 32 passed the House unanimously. It requires elections officials to keep a tally of voters who register into any party, whether that party is qualified or not. Currently, the state only keeps a tally of Republicans and Democrats; members of other parties are entered into the state's computerized list of voters as though they were independents. The bill is backed by the Secretary of State and contains other non-controversial provisions.
3. Michigan: HB 5237 (by Rep. Leon Drolet, a Republican) passed the House Local Government Committee on February 21. It makes it easier for a party to remain on the ballot. Currently, a party's status is determined by the vote for its candidate who is closest to the top of the ballot. The bill provides that a party's status is determined by the vote for its highest vote-getting statewide candidate. Since minor parties typically get more votes for lesser statewide office than they do for president or governor, this makes it easier for them to remain on the ballot.
4. Virginia: HB 1256 passed the House on February 12. It provides for partisan labels on the general election ballot for the candidates of all parties, not just candidates of qualified parties. Also, HB 599 passed the House on February 6. It provides for party labels for candidates for partisan county office (currently, county office candidates don't have a party label on the ballot, even though parties nominate such candidates).
On January 30, Senator Aran Garabedian, a Democrat, introduced S 2423, which provides that if a group submits a petition to become a qualified party, it then enjoys that status for 4 years.
Currently, after a group submits such a petition, it is only qualified for a single election year. If it fails to poll 5% in its first election, it goes off the ballot. However, under current law, if a new party does manage to poll 5%, it then retains its status for four years. Garabedian feels that the 4-year policy should apply for all types of political party.
The petition to create a new party requires signatures of 5% of the last vote cast. It has existed since 1994 and has never been used.
1. Alabama: HB 317, to lower the vote test for a party to stay on the ballot from 20% to 10%, has made no headway, but is still alive.
2. Georgia: HB 814 passed the House Governmental Affairs Committee on February 1. It lowers the statewide petition from approximately 40,000 signatures to a flat 15,000; lowers U.S. House petitions from 5% to 2%; lowers State Senate petitions to 3,000, and State House petitions to 1,000. It also says that if a party is qualified statewide, it is also automatically qualified for U.S. House. Unfortunately, it is stuck in the House Rules Committee, and the legislature adjourns in mid-March.
3. Indiana: HB 1344, to reduce statewide minor party petitions from approximately 36,000 signatures to approximately 9,000, has made no progress. However, HB 1101, which lowers the statewide petition for Democrats and Republicans from 5,000 signatures to 4,500, passed the House on February 5 by a vote of 95 to 1.
4. Iowa: SSB 3133, which would have let voters register as members of unqualified parties, never received a hearing in the State Government Committee, and is therefore dead.
5. Nebraska: LB 975, which would have let primary voters sign petitions for independent presidential candidates, lost in the Government & Veterans Committee on February 11.
6. New Hampshire: HB 1158, to reduce the vote test for a party from 4% to 3%, lost in the House Election Committee on February 12, 11-5.
7. Oklahoma: HB 2654, which would have lowered the petition and the vote test for parties, was killed by the House Rules Committee.
8. South Carolina: H 3273, to permit write-ins for president, has made no headway, although it is alive and recently gained a co-sponsor.
9. West Virginia: no ballot access reform bill was introduced this year, since legislative leaders said such bills will only be considered in odd-numbered years.
On February 14, the U.S. Senate voted down an amendment (to S.565) to permit ex-felons to vote in federal elections. The vote was 31-63. Voting in favor: Senators Akaka, Bingaman, Boxer, Cantwell, Cleland, Clinton, Corzine, Daschle, Dayton, DeWine, Durbin, Feingold, Hollings, Inouye, Jeffords, Kennedy, Kerry, Kohl, Leahy, Levin, Lieberman, Lincoln, Mikulski, Miller, Murray, Reed, Reid, Santorum, Sarbanes, Specter and Wellstone. Six senators did note vote: Bennett, Campbell, Domenici, Hatch, Smith (Ore.), Stevens. All others voted "no".
Under a 1970 U.S. Supreme Court precedent, Oregon v Mitchell, congress has the right to set voter qualifications in federal elections.
In State Legislatures
1. Alabama: On February 13, the Senate Elections Committee passed HB 40, to restore voting for ex-felons.
2. Hawaii: HB 2604, to let felons vote, was introduced on January 24.
3. Mississippi: currently, ex-felons can't vote if they committed a felony in Mississippi. Two bills, HB462 and HB808, were introduced to expand the restriction, to include felonies committed outside the state. They were both defeated in committee on February 5.
4. Washington: HB 2455 and SB 6519, to permit ex-felons to vote, failed to pass.
All IRV bills in Washington state failed to pass their house of origin by the deadline, and are thus dead.
Newly-introduced bills to authorize instant-runoff voting are:
1. Florida: S1812 (primaries only)
2. Hawaii: HB 2755, SB 2921 and SB 2546
3. Illinois: SB 1789 (primaries only)
4. New Mexico: SJR 21
On March 5, San Francisco, and nineteen Vermont towns, will vote on whether to implement IRV.
Bills have been introduced this year in two states to tinker with the electoral college. In Alabama, HB 82, by Representative Ken Guin, would provide that presidential candidates receive a number of presidential electors that are proportionate to that candidate's share of the popular vote in the state.
In California, SB 1438, by Senator Thomas Oller, would elect a single presidential elector from each congressional district. Oller, a Republican, hopes to persuade his party to do an initiative to implement this idea, if his bill fails to pass.
1. Alaska: most Democratic legislators are co-sponsoring HB 442 and SB 315, which would restore a single primary ballot for all parties, except for those parties which demand a closed primary ballot. Current law, passed last year, provides a separate primary ballot for each party and lets each party decide who may use it.
2. Arizona: SB 1251, which would have moved the state's presidential primary from late February to early February, was killed in Committee on February 11.
3. Hawaii: SB 3086 passed the Senate Judiciary Committee on February 14. It requires separate primary ballots for each party, rather than printing all party primary ballots on the same sheet of paper.
Florida State Senator Tom Rossin has introduced S2334, to add additional qualifications for legislators. Under this bill, no one running for the legislature, or for state executive or judicial posts, or for local government posts, could gain a place on the ballot unless he or she passes the eighth-grade-level Florida comprehensive assessment test. This is the same test that students must take.
Senator Rossin is the Democratic leader in the State Senate. His office did not return a phone call, asking why he introduced this bill.
In response to the Massachusetts Supreme Court decision of January, requiring the legislature to fund the public financing law for campaigns, the legislature passed S2263 on February 15. However, all it does is fund the only two particular candidates who already qualified to receive public funds. The Governor has said she will veto this bill, so the controversy will continue.
On February 13, U.S. District Court Judge Stephen Wilson issued a one-sentence order, requiring California to stop using punchcard ballots by 2004. Common Cause v Jones, 01-3470, Los Angeles. He hasn't yet issued an opinion explaining the basis for his order, but it will probably be based on Bush v Gore.
On January 30, U.S. District Court Judge Sam Sparks struck down the Texas law which requires each signature on a petition to list the signer's voter registration number. Fjetland v Weddington, A-02-CA45, Austin.
The law had already been declared void in three past lawsuits, one for minor parties, one for independent candidates, and one for initiatives. This case concerns petitions to get on a primary ballot.
The judge said, "The state might want to consider amending the election code instead of requiring judges to spend taxpayer dollars to reiterate the Pilcher holding ad nauseam."
On November 28, 2001, U.S. District Court Judge David Herndon struck down an Illinois county redistricting plan, because the districts deviate in population by 9%. Hulme v Madison County, 01-456, s.d. Old U.S. Supreme Court rulings permit local and state government districts to deviate in population as much as 10%. However, Judge Herndon said that computer mapping technology has improved so much since then, the old benchmark no longer applies. The county did not appeal.
1. Florida: on February 15, a federal judge in Miami ruled that a trial will be held in NAACP v Harris, 01-120. The state had argued that the lawsuit should be dismissed, because last year's legislature allegedly eliminated the problems. The trial will be in August. One issue is the state's method of removing ex-felons from the voter registration list.
2. Illinois: the U.S. Supreme Court will probably say on March 18 whether it will hear Tobin for Governor v Illinois Election Board, 01-998. The issue is whether state elections officials have immunity from being sued as individuals.
3. Montana: the State Supreme Court will rule soon on whether the legislative term limits law is valid. Cole v State of Montana ex rel Brown, 01-882.
3. Oregon: in January, the U.S. Supreme Court asked Oregon to submit a brief by February 15, explaining why the Court should not hear Decker v Bradbury, 01-732. Oregon asked for, and received, an extension of time until March 15. The issue is whether federal law bars voting over a 2-week period.
4. Texas (1): on October 16, 2001, a State Appeals Court struck down a law requiring anyone who distributes printed campaign material, to identify either himself or his agent on that literature. State v Doe, 61 SW 3d 99. The state is appealing.
Texas (2): on January 22, the State Supreme Court ruled that petition signatures are not invalid just because the signer's county was omitted. In re Kevin H. Bell, 02-0034.
5. Washington: the trial in Washington State Democratic Party v Munro has been postponed from March 11 to March 25. This is the combined Democratic-Republican lawsuit against the state's blanket primary.
6. federal law: on January 25, the 4th circuit ruled that not-for-profit corporations may make small campaign contributions to candidates for federal office. Beaumont v Federal Election Commission, 01-1348.
Lawsuits likely to be filed in the next month or so:
1. Kansas: the Natural Law Party will sue over a 100-year old law which requires all parties to have only one word in their name. The law also bans hyphenated party names.
2. North Carolina: Paul DeLaney, an independent candidate for U.S. Senate, plans to challenge the number of signatures he needs, 102,000 (approximately). The basis for the claim is that new parties only need half as many signatures.
3. Oklahoma: the Libertarian Party may file a lawsuit in state court, against the 61,712-signature requirement for party ballot access this year. The basis for the case will be the state Constitution, which says "Elections Shall be Free and Equal". Under current law, any adult citizen may run for congress, just by paying a filing fee, except for registered members of the Libertarian and Reform Parties. Even independents can run, just by paying a fee; but registered members of unqualified parties may not do so.
On February 6, the Center for Governmental Studies (University of Virginia) issued a 72-page "Report of the National Symposium on Presidential Selection". See it at http://www.goodpolitics.org/ Although it addresses election problems, it doesn't discuss the fact that voters in three states were not able to vote for candidates Ralph Nader, Howard Phillips, or John Hagelin. Nor does it mention presidential debates.
On February 12, the Democratic Party of South Carolina set its presidential primary for 2004 on February 3. The last time the party held a presidential primary, in 1992, it was in March. The Democratic national committee formerly forbade Democratic presidential primaries earlier than March (except for New Hampshire), but the national party rescinded this rule recently.
Although hundreds of different law journals have long been published in the United States, there has never before been one devoted exclusively to election law, until now. Election Law Journal published its first edition in January, 2002. It will be published four times per year, and costs $216 per year for print, or $199 for an on-line version. It is edited by Law Professors Daniel H. Lowenstein and Richard L. Hasen, and is published by Mary Ann Liebert, Inc., of Larchmont, N.Y. To subscribe, call 1-800-654-3237.
The first edition carries six original papers, two book reviews, a "forum" section, and selected recent Documents relating to election reform. The original papers are:
1. Unpacking Page v Bartels: a Fresh Redistricting Paradigm, by Sam Hirsch.
2. Internet Politics 2000: Overhyped, Then Underhyped, the Revolution Begins, by Trevor Potter and Daniel Manatt.
3. Initiatives and the New Single Subject Rule, by Daniel Lowenstein.
4. Neutralizing the Incompetent Voter: A Comment on Cook v Gralike, by James A. Gardner.
5. Voting Machines, Race, and Equal Protection, by Stephen Ansolabehere.
6. The Secretaries Speak: Sixteen Points to Improve American Elections, by Sharon Priest.
The books reviewed are Bradley A. Smith's Unfree Speech -- the Folly of Campaign Finance Reform, and Elisabeth R. Gerber's The Populist Paradox: Interest Group Influence and the Promise of Direct Legislation.
It would be inaccurate to say that the Journal has a point of view, since each author has his or her own point of view. However, the first issue has two selections with a stance that is favorable to the initiative process, and no pieces with an anti-initiative point of view. The next issue (April 2002) will have at least one selection that is favorable to ballot access for minor parties and independent candidates.
Spoiling for a Fight, Third Party Politics in America, by Micah L. Sifry. Published by Routledge, $27.50 plus shipping. http://www.routledge-ny.com/, (212)-216-7800. Published in February 2002. 365 pages, hard cover.
Spoiling for a Fight is a riveting history of some minor party activity during the period 1990-2001. Sifry is perhaps the only person who could have written this book. For years, he has been attending minor party national conventions, interviewing party leaders, being present at rallies, at the venues for presidential debates, and at hearings of the U.S. Supreme Court which affected minor parties. He was savvy enough to have interviewed Jesse Ventura a few weeks before Ventura was elected Governor of Minnesota.
Although several books about Ross Perot's candidacies have been published, Spoiling for a Fight seems to be the first book to chronicle a history of the Reform Party for the period 1996-2000. Sifry was an eye-witness at the party's annual conventions; he is also a gifted writer. The combination makes for a book which is so entertaining, one can hardly put it down. His chapter on the Jesse Ventura victory for Governor of Minnesota contains new material that most commentators have missed.
Sifry's history of the Green Party, especially during 2000, is equally well done. Although Sifry is sympathetic to Ralph Nader, he does not shy away from an analysis of how the Nader campaign could have been more effective.
Sifry also includes a history of the New Party's fight to win a U.S. Supreme Court decision that would have legalized "fusion" (the practice of two parties jointly nominating the same candidate). He also has a history of the Working Families Party of New York state, a party that thrives partly because it exists in a state that permits fusion. And he tells the story of the Supreme Court's unfortunate Arkansas Educational TV debate decision, letting public TV shut out non-major party candidates.
The book includes only three pages on the Libertarian Party, and no separate sections on any parties not already mentioned in this review. It is, therefore, not comprehensive nor encyclopedic.
United States Presidential Elections 1788-1860, The Official Results by County and State, by Michael J. Dubin. Published by McFarland & Co, (336)-246-4460. $75 plus $4 shipping. Published in January 2002. 225 pages, hard cover.
This is the first book to include county-by-county election returns for U.S. presidential elections earlier than 1836. It is the first book to include comprehensive state totals for presidential elections before 1824. For example, there has never before been any book which tells that, in the 1800 presidential election, Thomas Jefferson received 41,516 popular votes in the nation, whereas John Adams received 25,748.
Years of research were required to find this data. Dubin did a great deal of the research, and he was the beneficiary of earlier research done by Philip Lampi. Unfortunately, some of the election returns are still missing, and will probably never be found.
B.A.N. has been publishing the number of registered voters in each state, in even years, for a decade now. However, no data has ever been presented from Rhode Island or Utah, because state elections authorities in those states don't tabulate it.
B.A.N. has obtained Rhode Island data for the first time, by contacting each town. Current state totals are:
|indp. and other:||345,321|
The next issue will have Utah registration data by party.
|FULL PARTY||CAND.||LIB'T||GREEN||CONSTIT'N||REFORM||NAT LAW|
|Alabama||39,536||39,536||already on||0||0||0||0||July 1|
|Alaska||(reg) 6,606||#2,879||already on||already on||5||58||7||June 1|
|Arizona||20,427||est. #9,800||already on||2,500||0||*350||0||May 18|
|California||(reg) 86,212||157,073||already on||already on||already on||already on||already on||Aug 9|
|Colorado||(reg) 1,000||#1,000||already on||already on||already on||already on||already on||May 1|
|Connecticut||no procedure||#7,500||already on||0||already on||0||0||Aug 7|
|Delaware||est. (reg) 250||est. 5,000||already on||already on||already on||already on||already on||Aug 17|
|D.C.||no procedure||est. #3,500||can't start||already on||can't start||can't start||can't start||Aug 28|
|Florida||be organized||pay fee||already on||already on||already on||already on||already on||Sep 1|
|Georgia||38,600||#38,600||already on||*5,000||0||0||0||Aug 5|
|Hawaii||638||25||*finished||already on||0||0||already on||Apr 24|
|Idaho||10,033||5,017||already on||0||already on||already on||already on||Aug 31|
|Illinois||no procedure||#25,000||can't start||can't start||can't start||can't start||can't start||Jun 24|
|Indiana||no procedure||#30,717||already on||0||0||0||0||Jul 15|
|Iowa||no procedure||#1,500||*300||already on||0||0||0||Aug 16|
|Kansas||14,854||5,000||already on||0||already on||already on||0||June 1|
|Kentucky||no procedure||#5,000||0||0||0||0||0||Aug 6|
|Louisiana||est. (reg) 140,000||pay fee||1,016||393||17||2,408||23||July 1|
|Maine||21,051||#4,000||0||already on||0||0||0||May 25|
|Maryland||10,000||est. 26,000||*17,000||0||0||0||0||Aug 5|
|Massachusetts||est. (reg) 37,500||#10,000||already on||already on||17||2,594||73||July 30|
|Michigan||30,272||30,272||already on||already on||0||already on||0||July 18|
|Minnesota||104,550||#2,000||0||already on||0||0||0||June 1|
|Mississippi||be organized||#1,000||already on||*organizing||already on||already on||already on||March 1|
|Missouri||10,000||10,000||already on||0||0||0||0||July 29|
|Montana||5,000||#5,000||already on||already on||*4,000||already on||already on||Mar 14|
|Nebraska||5,453||2,500||already on||0||0||0||0||Aug 1|
|Nevada||5,867||5,867||0||already on||already on||already on||already on||July 7|
|New Hampshire||16,931||#3,000||*300||0||0||0||0||Aug 6|
|New Jersey||no procedure||#800||0||0||0||0||0||July 31|
|New Mexico||2,994||17,958||*5,000||already on||0||0||0||Apr 2|
|New York||no procedure||#15,000||can't start||already on||can't start||can't start||can't start||Aug 20|
|North Carolina||58,842||est. 102,000||already on||0||0||0||0||May 17|
|North Dakota||7,000||4,000||0||0||0||0||0||Apr 5|
|Ohio||45,753||5,000||in court||5,200||0||0||4,500||*May 6|
|Oklahoma||61,712||pay fee||0||0||0||0||0||May 31|
|Oregon||16,663||15,306||already on||already on||already on||0||already on||Aug 27|
|Pennsylvania||no procedure||20,900||can't start||can't start||can't start||can't start||can't start||Aug 1|
|Rhode Island||15,323||#1,000||0||already on||0||0||0||Jul 18|
|South Carolina||10,000||10,000||already on||0||already on||already on||already on||July 17|
|South Dakota||6,505||#2,602||already on||0||0||already on||0||April 2|
|Texas||37,381||37,381||already on||already on||can't start||can't start||can't start||May 28|
|Utah||2,000||#1,000||already on||*already on||0||0||already on||Mar 15|
|Vermont||be organized||#1,000||already on||0||already on||0||*0||*Sep 19|
|Virginia||no procedure||#10,000||*1,200||0||0||0||0||Jun 11|
|Washington||no procedure||#200||already on||can't start||can't start||can't start||can't start||Jul 6|
|West Virginia||no procedure||#11,864||0||0||0||0||0||May 13|
|Wisconsin||10,000||#2,000||already on||already on||already on||can't start||can't start||Jun 1|
|Wyoming||4,247||4,247||already on||0||0||0||0||Jun 1|
|TOTAL STATES ON||28||*21||13||12||*12|
"Deadline" is procedure with earliest petition deadline, except in the states where the earliest deadline has already passed. #Candidate procedure allows partisan label. Other nationally-organized parties on a statewide ballot are Socialist, Socialist Workers, Southern, and Workers World, in Florida. * -- means a change, compared to the Jan. 2002 BAN.
On January 29, Minnesota held special elections in two state senate districts:
1. 7th dist: Dem. 55.84%; Green 36.99%; Independence 6.88%. In November 2000 the results for the same office had been: Dem. 87.73%; Constitution 12.27%.
2. 67th dist: Democratic 51.32%; Republican 29.20%; Independence 17.72%; Green 1.76%. In November 2000 there had been only one candidate, a Democrat.
The Peace and Freedom Party of California, which was on the ballot between 1968 and 1998, is still trying to get back on the ballot. It needs 86,212 registered active members at any official state tally this year, or an unknown number of registrations next year, in order to appear on the 2004 ballot (it's too late for 2002). At the January 2002 tally, it had 69,197, which was an increase from the October 2001 tally of 66,946. The next tally will be released at the end of March 2002.
The Feb. 26 issue of USA Today newspaper has a full-page ad, written by the Libertarian Party, satirizing a U.S. government ad from last month which claims that people who use illegal drugs are helping fund terrorists. The Libertarian ad says that the war on drugs boosts the price of illegal drugs by as much as 17,000 percent - funneling huge profits to terrorists. This seems to be the first time a minor party has run a full-page in a nationally-circulated newspaper since the Natural Law Party's USA Today ad in 1996. See http://www.lp.org/issues/drugczarad.htmlfor brief information (and a link to the full-sized PDF file); see http://www.lp.org/lpnews/0203/drugad.htmlfor more details.
At the beginning of this year, there were two independents in the U.S. House, Bernie Sanders of Vermont and Virgil Goode of Virginia. Since then, Goode has announced he will run for re-election as a Republican. But James Traficant of Ohio, a Democrat, announced he will run for re-election as an independent.
On Presidents' Day, February 18, a joint press conference in Washington, D.C., by Ralph Nader, Pat Buchanan, and the Libertarian Party's political director Ron Crickenberger, criticized the Commission on Presidential Debates. All three men called for the creation of a truly non-partisan debates-sponsoring organization. Unfortunately, none of the three mentioned HCR 263, by Congressman Jesse Jackson, Jr. HCR 263 expresses the sense of Congress that the Commission on Presidential Debates ought to invite people into the debates if they are at 5% in polls, or if 50% of the public feels the candidate should be invited.
The Green Party has a national office now. It is at 1314 18th St., NW, Washington DC 20036, (202)-296-7755.
No party has qualified for the Tennessee ballot, by petition, since 1968. Signatures equal to 2.5% of the last vote cast for Governor are needed.
This year, the Constitution Party tried to qualify, and gathered 12,000 signatures by the mid-February deadline, less than half of the required 24,406. However, the party is free to keep custody of its signatures, and to get more, and use them to qualify for the 2004 ballot.
The Center for Voting and Democracy is seeking volunteers in each state who will monitor what type of vote-counting machines are purchased by local and state governments. The Center hopes that no jurisdiction will buy machines unless those machines can handle ranked-choice voting (in which the voter indicates a "1" next to his or her favorite candidate, and a "2" for the next-most favored candidate). Contact the Center at (301)-270-4616, or rr.AT.fairvote.org
The list of states with straight-ticket ballot devices in the last B.A.N. accidentally omitted Texas.