CONNECTICUT PASSES DISCRIMINATORY FUNDING BILL

On December 7, Connecticut Bill 2103 was signed into law. It provides public funding for candidates for state office who raise a large amount of private contributions. Unfortunately, unlike similar laws in Maine, Vermont, and Arizona, members of parties that polled 10% in the last election are treated substantially better than other candidates.

To qualify for funding, all candidates must privately raise at least $250,000 if running for Governor, $75,000 if running for another statewide race, $15,000 for State Senate, or $7,500 for State House. The bill sets a minimum number of contributors, and says that amounts over $100 don’t count, and that no one is a "contributor" unless he or she gives at least $5. For legislative races, "contributors" must live nearby.

Unfortunately, the law also says that candidates who are not members of parties that polled 10% in the last election must not only raise the private contributions, but must submit petitions. For equal funding, they must submit petitions signed by 20% of the last vote cast for their office. If they are nominees of parties that polled 10% but under 15%, they can get one-third of the amount that their major party opponents received; if their party polled between 15% and 20% in the last election, they get two-thirds of the full funding amount.

Is the Law Constitutional?

In 1976, the U.S. Supreme Court ruled 7-2 that the government can discriminate when it awards public funds to presidential nominees. Buckley v Valeo. The law said that presidential nominees of parties that had polled 5% in the last election could get general election funding before the election, but no other presidential candidates could receive such funding before the election. However, an unfunded candidate who got 5% could receive some funding after the election.

The rationale for permitting this discrimination was that in presidential elections, only the two major parties had come close to winning, for many decades. The Court said, "Since the Presidential elections of 1856 and 1860, when the Whigs were replaced as a major party by the Republicans, no third party has posed a credible threat to the two major parties in Presidential elections." A footnote in the decision says, "In 1912 Theodore Roosevelt ran as the candidate of the Progressive Party, which had split off from the Republican Party, and he received more votes than William H. Taft, the Republican candidate. But this third-party ‘threat’ was short-lived; in 1916 the Progressives came back into the Republican Party. With the exception of 1912, the major-party candidates have outpolled all others in every Presidential election since 1856."

Connecticut is Different

Fortunately, the historical record for state office in Connecticut is very different than the history of U.S. presidential elections.

A Connecticut Party elected the Governor and Lieutenant Governor of Connecticut in 1990. In addition, that party performed very well in state legislative elections in 1992 and 1994, and some of its nominees outpolled major party nominees.

In November 1994, one nominee of A Connecticut Party outpolled one of his major party opponents, although not the other one. In the State Senate race in District 19, Kenneth Przybysz, nominee of A Connecticut Party, polled 11,240 votes. His Republican opponent only received 5,482 votes, but his Democratic opponent won with 13,405. Przybysz did well because he was the incumbent; he had been elected in 1992 as a Democrat, but in 1994 he lost the Democratic nomination, but won the A Connecticut Party nomination.

In November 1992, two nominees of A Connecticut Party outpolled one major party opponent, but not the other. In the 2^nd State Senate district, A Connecticut nominee Frank Barrows outpolled his Republican opponent 5,540 to 4,419, but he lost to the Democrat, who polled 15,805. In the 66^th State House race, A Connecticut nominee Sandra Carpenter outpolled her Democratic opponent 2,717 to 2,643, but she lost to the Republican, who polled 6,060.

In 1934 and 1938, Socialist Party nominees were elected to both houses of the state legislature. In 1954, two independent candidates were elected to the State House. They were Samuel Lawrence in East Windsor, and Abraham Shermer in Seymour.

Because the historical record in Connecticut does not match the record in U.S. presidential elections, the U.S. Supreme Court’s Buckley decision does not necessarily apply.

A closer analogy for any Connecticut lawsuit is Greenberg v Bolger, 497 F.Supp. 756 (1980). In that case, a U.S. District Court ruled unconstitutional a law that gave cheaper postal rates to political parties that had polled 25% for president in the last election. The cheaper rates were not available to other parties.

Another case is Socialist Workers Party v Rockefeller, 314 F.Supp. 984 (1970). A 3-judge U.S. District Court ruled that if the government gives a free list of the registered voters to qualified parties, it must give it to the unqualified parties as well. The U.S. Supreme Court summarily affirmed this decision (400 U.S. 806), so it applies nationwide.

Also helpful are decisions from New York, New Jersey, Colorado, and Oklahoma, that say if voters are permitted to register as members of qualified parties, they must be allowed to register as members of unqualified parties.

On November 30, the 6^th circuit upheld Ohio’s petition deadline for independent candidates (for office other than president) of March 1. Lawrence v Blackwell, 04-4022. The case had been brought by a Socialist Equality Party candidate for Congress, David Lawrence. He filed a declaration of candidacy on March 1, but did not submit his 2,000-signature petition until June, because his party is small and couldn’t get that many signatures any sooner, partly due to winter weather.

The 6^th circuit opinion is short, and says that since the Democrats and Republicans held their primary on March 2, the state is treating all candidates equally and the deadline is constitutional. However, the two Supreme Court opinions on early deadlines do not use this analysis.

Anderson v Celebrezze struck down Ohio’s March 20 deadline for independent presidential candidates. It says, "If the State’s filing deadline were later in the year, a newly emergent independent candidate could serve as the focal point for a grouping of Ohio voters who decide, after mid-March, that they are dissatisfied with the choices within the two major parties."

Also, "Several important third-party candidacies in American history were launched after the two major parties staked out their positions and selected their nominees."

And, "The Ohio filing deadline challenged in this case does more than burden the associational rights of independent voters and candidates. It places a significant state-imposed restriction on a nationwide electoral process."

Finally, Anderson v Celebrezze says, "The early deadline for filing as an independent may actually impair the State’s interest in preserving party harmony. As Professor Alex Bickel perceptively observed, ‘The characteristic American third party consists of a group of people who have tried to exert influence within one of the major parties, have failed, and alter decide to work on the outside.

‘States in which there is an early qualifying date tend to force such groups to create minor parties without first attempting to influence the course taken by a major one. For a dissident group is put to the choice of foregoing major-party primary and other prenomination activity by organizing separately early on in an election year, or losing all opportunity for action as a third party later."

Anyone who can read can see that the U.S. Supreme Court based Anderson v Celebrezze on the First Amendment and its protection for free, fluid and competitive elections. No U.S. Supreme Court decision has ever said that all types of nomination must be simultaneous. The idea is absurd on its face. For example, in 2004, the Democrats held their national convention in July, and the Republicans held theirs in September. Under the 6^th circuit’s theory, the two would need to be simultaneous.

Also, most southern states still use run-off primaries. It is common for one major party to need a run-off primary in a year in which the other major party does not need one. In all those instances, the two major parties are not making their final nomination simultaneously.

Furthermore, if the 6^th circuit were right, one would expect all states to set independent petition deadlines (for office other than president) on the day of the major party primary, or the day before. But only nine states follow this policy (Alabama, Alaska, Kansas, New Jersey, New Mexico, Ohio, South Dakota, Virginia, West Virginia).

The 6^th circuit opinion does not even mention Mandel v Bradley, the other U.S. Supreme Court deadline decision. That case, from 1977, says an early petition is likely to be unconstitutional if the record shows that few independent candidates ever qualify. The Ohio plaintiffs showed that in years when the Ohio deadline is in March, very few candidates qualify to run for Congress.

In 2004, only one independent candidate for the House qualified (out of 18 districts), and no Senate independent qualified.

In 2000, only three independents for House qualified (out of 19 districts), and none did so for Senate.

In 1996, not a single independent qualified for any House race, and no Senate seat was up.

Plainly, under the analysis of Mandel v Bradley, the 6^th circuit should have struck the deadline. All of the evidence about the paucity of independent candidates was in the record, but the 6^th circuit didn’t mention that evidence. Nor did the 6^th circuit mention any of the historical evidence that was in the record, about the formation of new parties in the middle of election years. The record also contained evidence that Ohio had a September deadline from 1891 (when government-printed ballots began in Ohio) until 1951. And the record showed that the independent elected to Congress from Ohio in 1950, Frazier Reams, did not enter the race until after the primary.

Lawrence asked for a rehearing, but it was denied on December 16. He may appeal to the Supreme Court. The attorney who has been handling the case will not appeal unless he is paid an additional $10,000, plus printing filing fees, so Lawrence hopes to find a pro bono attorney.

On December 1, the U.S. Postal Service revoked an old regulation that forbade petitioning on all post office sidewalks. A new regulation was issued, banning petitioning on sidewalks that lead from parking lots to the building, but permits it on sidewalks that are parallel to streets.

The Initiative and Referendum Institute, which brought the original case against the old postal regulation in 2000, has returned to the U.S. District Court (per the Appeal Court’s instructions) to contest whether the new restriction is constitutional. The U.S. District Court had upheld the old regulation on the grounds that many postal patrons don’t like being asked to sign petitions. Of course, that is not an appropriate justification for restrictions on free speech.

On December 12, the U.S. Supreme Court said it will hear four cases on whether the Texas legislature violated the Constitution in 2003, when it re-drew the boundaries of some U.S. House districts. Briefs for the voters and groups who objected to the legislature’s action are due January 10, and one has already been filed. The state’s brief is due February 1. Rebuttal briefs are due February 22, and the hearing is March 1 at 1 p.m. Two hours have been allotted. A two-hour hearing is unusual; almost all oral arguments in the U.S. Supreme Court last one hour.

The cases are League of United Latin American Citizens v Perry, Travis County v Perry, Jackson v Perry, and GI Forum of Texas v Perry.

Briefs and other documents relating to the case can be viewed at Jenner.com, the web page of the law firm Jenner and Block. As new documents come in, they will be posted.

The initiative to make it substantially easier for a party to remain on the ballot in Massachusetts, and to legalize fusion, has qualified for the November 2006 ballot.

On December 15, Rep. Paul Froehlich introduced HB 4250. It would lower the number of signatures for an independent candidate for the legislature from 10% of the last vote cast, to 5%. Illinois is the only state that requires an independent candidate for anything to submit a petition signed by more than 5% of the electorate.

On March 7, Burlington, Vermont, will use Instant-Runoff Voting to elect its mayor. This will be the first partisan election in the United States to use IRV since 1975, when Ann Arbor, Michigan used it.

On December 10, former U.S. Senator Eugene McCarthy died. Newspapers carried long obituaries, but none discussed his 1976 independent candidacy for the presidency. Yet McCarthy felt that what he did in 1976 was just as important as his far better known 1968 campaign.

In 1974, the U.S. Supreme Court said in Storer v Brown that states must have ballot access procedures for both new parties and independent candidates. At the time, 14 states had no provision for an independent presidential candidate. McCarthy sued 12 of those states, and won all his cases. He polled less than 1% of the vote in 1976, but his lawsuits paved the way for John Anderson in 1980 and Ross Perot in 1992. If McCarthy hadn’t won his lawsuits, they would have been forced to file similar lawsuits themselves, or else they would have had to create a new party (Ross Perot did create a party in 1995, but he was an independent candidate in 1992).

The only two states without a procedure that McCarthy didn’t sue were Alaska and Arkansas. Alaska didn’t create a procedure until 2005, and Arkansas still hasn’t done so.

Connecticut: on December 20, a federal court ruled that the Constitution does not require states to let people register to vote on election day. ACORN v Bysiewicz, 3:04-cv-1624. The legislature will probably pass a same-day registration bill anyway; such a bill passed in 2005 but was vetoed by former Governor John Rowland.

Illinois: on December 21, a state court ruled that an election law deadline for candidates for judge to file for re-election probably violates the State Constitution. The statute says they must file in December of the year before the election, but the State Constitution says the deadline is in May of election years. The state court issued an injunction putting the candidates on the ballot. O’Brien v Bellows, 05-coel-0036, Cook County.

Louisiana: the old lawsuit over the timing of the state’s congressional elections has been revived. Love v Foster, 95-788-B. On November 28, the state asked U.S. District Court Judge Frank Polozola to permit the state to restore a September date for U.S. House elections, since a law passed this year says such elections are "deemed" to be in November.

Michigan: on December 1, the 6^th circuit heard Nader v Land, 04-2428. The issue is whether the Secretary of State had a duty to decide which set of Reform Party state officers was the legitimate set. One faction wanted to put Nader on the ballot; the other wanted no presidential candidate. The Secretary of State refused to decide which were the legal officers.

Pennsylvania: on March 1, the State Supreme Court will hear In re Nader, over whether Nader must pay $85,000 to the attorneys who challenged his petition and had him removed from the ballot last year.

Utah: on January 25, a hearing will be held in the case in which a company union (backed by the employer, a coal mine) is suing the newspaper of the Socialist Workers Party for slander. IAUWU v UMWA, 2:04-cv-901, U.S. District Court.

The chart below shows the number of signatures needed for a Democrat or Republican to get on the ballot of all presidential primary ballots, for each election back to 1960.

The December 1, 2005 B.A.N. had a chart, showing the number of signatures needed for a new party or independent presidential candidate to get on the ballot in all states. The contrast between the requirements is extreme. Although the government supposedly has an interest in keeping primary ballots uncluttered, somehow the presidential primary system works well without mandatory petitions in most states. The number of signatures John Kerry needed to run for president in 2004, in all Democratic primaries, was only 4% of the number needed for the November ballots.

This chart shows how many signatures were required for a Republican or a Democrat to get his or her name on a presidential primary ballot, in each state, for the last 45 years. Dashes indicate that the state didn’t hold a presidential primary in a particular year. The states that have never held a presidential primary in the last 45 years are not listed above. If the number of signatures differed for a Republican and a Democrat, the Democratic requirement is shown. The chart assumes that the candidate has qualified for matching funds, or is discussed in the news media.

State	1960	1964	1968	1972	1976	1980	1984	1988	1992	1996	2000	2004
Al	- -	- -	- -	- -	- -	500	500	500	500	500	500	500
Az	- -	- -	- -	- -	- -	- -	- -	- -	- -	0	0	0
Ar	- -	- -	- -	- -	0	0	- -	0	0	0	0	0
Ca	15701	15186	13746	14694	0	0	0	0	0	0	0	0
Co	- -	- -	- -	- -	- -	- -	- -	0	0	0	0	0
Ct	- -	- -	- -	- -	- -	0	0	0	0	0	0	0
De	- -	- -	- -	- -	- -	- -	- -	- -	- -	0	0	0
DC	100	100	100	100	1,000	1,000	1,000	1,000	1,000	1,000	1,000	0
Fl	0	0	0	0	0	0	0	0	0	0	0	0
Ga	- -	- -	- -	- -	0	0	0	0	0	0	0	0
Id	- -	- -	- -	- -	0	0	0	0	0	0	0	0
Il	3,000	3,000	3,000	3,000	3,000	3,000	3,000	3,000	3,000	3,000	3,000	3,000
In	5,500	5,500	5,500	5,500	5,500	5,500	5,000	5,000	5,000	5,000	5,000	4,500
Ks	- -	- -	- -	- -	- -	0	- -	- -	0	- -	0	- -
Ky	- -	- -	- -	- -	0	0	- -	0	0	0	0	0
La	- -	- -	- -	- -	- -	0	0	0	0	0	0	0
Me	- -	- -	- -	- -	- -	- -	- -	- -	- -	0	0	- -
Md	0	0	- -	0	0	0	0	0	0	0	0	0
Ma	2,500	2,500	2,500	0	0	0	0	0	0	0	0	0
Mi	- -	- -	- -	0	0	0	- -	- -	0	0	0	- -
Ms	- -	- -	- -	- -	- -	0	- -	0	0	0	0	0
Mo	- -	- -	- -	- -	- -	- -	- -	0	- -	- -	0	0
Mt	- -	- -	- -	- -	2,000	2,000	2,000	2,000	1,000	2,000	0	0
Ne	300	300	0	0	0	0	0	0	0	0	0	0
Nv	- -	- -	- -	- -	0	0	- -	- -	- -	0	- -	- -
NH	100	100	100	1,000	1,000	1,000	0	0	0	0	0	0
NJ	1,000	1,000	1,000	1,000	1,000	1,000	1,000	1,000	1,000	1,000	1,000	1,000
NM	- -	- -	- -	0	- -	0	0	0	0	0	0	0
NY	- -	- -	- -	- -	- -	10,000	10,000	10,000	10,000	10,000	10,000	5,000
NC	- -	- -	- -	0	0	0	0	0	0	0	0	0
ND	- -	- -	- -	- -	- -	- -	0	0	0	0	0	- -
Oh	1,000	1,000	1,000	1,000	1,000	1,000	1,000	1,000	0	0	0	0
Ok	- -	- -	- -	- -	- -	- -	- -	0	0	0	0	0
Or	0	0	0	0	0	0	0	0	0	0	0	0
Pa	1,000	1,000	1,000	1,000	1,000	1,000	1,000	2,000	2,000	2,000	2,000	2,000
RI	- -	- -	- -	500	0	0	0	0	0	1,000	1,000	1,000
SC	- -	- -	- -	- -	- -	0	- -	0	0	0	0	0
SD	1,328	1,125	966	1,317	1,492	0	0	0	0	0	0	0
Tn	- -	- -	- -	0	0	0	0	0	0	0	0	0
Tx	- -	- -	- -	- -	- -	0	0	0	0	0	0	0
Ut	- -	- -	- -	- -	- -	- -	- -	- -	- -	- -	0	0
Vt	- -	- -	- -	- -	1,000	1,000	1,000	1,000	- -	1,000	1,000	1,000
Va	- -	- -	- -	- -	- -	- -	- -	0	- -	- -	10,000	10,000
Wa	- -	- -	- -	- -	- -	- -	- -	- -	0	0	0	0
WV	0	0	0	0	0	0	0	0	0	0	0	0
Wi	2,000	2,000	2,000	2,000	0	0	0	0	0	0	0	0
Tot	33529	32811	30,912	31,111	17992	27,000	25,500	26,500	23,500	26,500	34,500	28,000

STATE	REQUIREMENTS		SIGNATURES COLLECTED
	FULL PARTY	CAND	LIB'T	GREEN	CONSTI	NAT LAW	REFORM	Deadline
Alabama	41,012	41,012	1,200	0	0	0	0	in court
Alaska	(reg) 9,258	#3,128	already on	in court	0	0	0	Aug. 22
Ariz.	26,835	est. #20,000	already on	*3,700	0	0	0	June 14
Arkansas	10,000	10,000	1,000	*3,800	0	0	0	May 1
Calif.	(reg) 77,389	165,573	already on	already on	already on	already on	34,561	Aug. 11
Colorado	(reg) 1,000	#1,000	already on	already on	already on	534	337	July 10
Connecticut	no procedure	#7,500	already on	0	already on	0	0	Aug. 11
Delaware	est. (reg) 280	est. 5,600	already on	already on	already on	257	211	July 15
D.C.	no procedure	est. #3,800	can't start	already on	can't start	can't start	can't start	Aug. 30
Florida	be organized	pay fee	already on	already on	already on	already on	already on	July 18
Georgia	42,676	#42,676	already on	0	0	0	0	July 11
Hawaii	648	25	already on	already on	0	already on	0	July 25
Idaho	11,968	5,984	already on	0	already on	already on	0	Aug. 31
Illinois	no procedure	#25,000	can't start	can't start	can't start	can't start	can't start	June 26
Indiana	no procedure	#29,553	already on	*6,000	0	0	0	June 30
Iowa	no procedure	#1,500	0	0	0	0	0	Aug. 18
Kansas	16,477	5,000	already on	0	0	0	already on	July 31
Kentucky	no procedure	#2,400	0	0	0	0	0	Aug. 8
La.	(reg) 1,000	pay fee	already on	already on	47	20	already on	Sep. 7
Maine	24,798	#4,000	0	already on	0	0	0	May 25
Maryland	10,000	est. 29,400	already on	already on	already on	0	0	Aug. 7
Mass.	est. (reg) 41,000	#10,000	23,900	9,509	56	44	1,168	Aug. 1
Michigan	31,731	31,731	already on	already on	already on	already on	0	July 20
Minnesota	141,420	#2,000	0	0	0	0	0	July 18
Mississippi	be organized	1,000	already on	already on	already on	already on	already on	April 7
Missouri	10,000	10,000	already on	0	0	0	0	July 31
Montana	5,000	#5,000	already on	*1,000	*2,000	0	0	May 30
Nebraska	4,735	2,500	300	*4,300	0	0	0	Aug. 29
Nevada	7,915	7,915	already on	0	already on	0	0	July 7
New Hamp.	20,299	#3,000	*1,500	0	0	0	0	Aug. 9
New Jersey	no procedure	#800	0	0	0	0	0	June 6
New Mex.	3,782	14,079	finished	already on	already on	0	0	July 11
New York	no procedure	#15,000	can't start	can't start	can't start	can't start	can't start	Aug. 22
No. Car.	69,734	law is void	in court	0	0	0	0	June 30
No. Dakota	7,000	1,000	0	0	0	0	0	Sep. 8
Ohio	56,280	5,000	in court	*200	0	0	0	May 1
Oklahoma	73,188	pay fee	in court	0	0	0	0	June 21
Oregon	18,381	18,356	already on	already on	already on	0	0	Aug. 29
Penn.	no procedure	#66,827	can't start	can't start	can't start	can't start	can't start	Aug. 1
Rhode Isl.	21,815	#1,000	*0	*0	*0	*0	*0	July 20
So. Caro.	10,000	10,000	already on	already on	already on	0	already on	July 15
So. Dakota	8,364	#3,346	already on	0	already on	0	0	June 6
Tennessee	41,314	25	0	0	0	0	0	April 6
Texas	45,253	45,253	already on	can't start	can't start	can't start	can't start	May 11
Utah	2,000	#1,000	already on	already on	already on	0	0	Mar. 17
Vermont	be organized	#1,000	already on	already on	0	0	0	Sep. 21
Virginia	no procedure	#10,000	*0	*0	*0	*0	*0	June 13
Washington	no procedure	in court	can’t start	can't start	can't start	can't start	can't start	July 7
West Va.	no procedure	#8,724	0	0	0	0	0	May 8
Wisconsin	10,000	#2,000	already on	already on	already on	0	0	July 11
Wyoming	4,774	4,774	already on	0	0	0	0	Aug. 28
TOTAL STATES ON			27	17	16	6	5	`

3 states (Ky., La., N.C.) have no statewide race, so chart shows U.S. House.
*change since the Nov. 1 chart.
#partisan label is permitted (other than "indp.").
"Deadline" means procedure with latest deadline.
**The Labor Party has 4,000 in South Carolina.

New Jersey and Virginia held elections for the lower houses of their state legislatures on November 8, 2005. Here are the statewide legislative totals for each minor party that ran legislative candidates. New Jersey elects two assemblymembers from each district. When a minor party ran two candidates in the same district, only the candidate who received the higher vote was added into the state total (otherwise some voters would have been counted twice).

The Virginia Green totals are those received by the Independent Green Party of Virginia, which is not affiliated with the national Green Party. The affiliated Green Party in Virginia did not have any legislative candidates in 2005.

Party	New Jersey	Virginia
Libertarian	3,673	11,307
Green	8,546	1,665
Constitution	1,535	4,961
Socialist	1,416	- -
Socialist Workers	513	- -
Conservative	787	- -

The chart below shows the percentage of the vote that each party received, in each state, in those legislative districts in which it ran candidates.

Party	New Jersey	Virginia
Libertarian	1.41%	13.42%
Green	4.40%	1.69%
Constitution	2.57%	21.64%
Socialist	1.21%	- -
Soc. Workers	1.50%	- -
Conservative	1.58%	- -

CALIFORNIA CONGRESS ELECTION

On December 4, California held a special congressional election in the 48^th district. Jim Gilchrist, Constitution (American Independent) Party nominee, polled 25.1% of the vote. This was the best showing nationally for a minor party, in a U.S. House race in which voters could also vote for a Republican or a Democrat, since 1994. In 1994, A Connecticut Party polled 26.3% for U.S. House in Connecticut’s First District. Results for the other party nominees in the California race are: Republican 44.7%; Democratic 28.0%; Green 1.3%; Libertarian .9%.

California conducts special partisan elections by using a blanket primary. In this race, the blanket primary was in October 2005. At that blanket primary (in which all voters received the same ballot and the ballot listed candidates of all parties), Gilchrist only placed third, behind two Republicans. Under blanket primary rules, the top vote-getter from each party advanced, so the blanket primary did not injure Gilchrist.

But under the "top-two" system now being promoted in Oregon, Gilchrist would have been barred from the run-off ballot.

A Rasmussen Poll, taken on December 8 asked about the U.S. Senate race in Connecticut. The results are: 54% for incumbent Democrat Joseph Lieberman, 37% for potential independent candidate Lowell Weicker, 7% "other," and 7% "undecided." No Republican was named, since no one knows who the Republican nominee will be.

Maine now has 4 state representatives who aren’t Republicans or Democrats. Besides the one elected Green, and the two elected independents, Representative Joanne Twomey recently changed her registration from "Democratic" to "Independent."

---

SUBSCRIBING TO BAN WITH PAYPAL

If you use Paypal, you can subscribe to B.A.N., or renew, with Paypal. If you use a credit card in connection with Paypal, use richardwinger@yahoo.com. If you don’t use a credit card in conjunction with Paypal, use sub@richardwinger.com.