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Harvard Law Professor Nicholas Stephanopoulos, a leading authority on gerrymandering and election law, explores the pivotal role that legal professionals play in safeguarding our democratic processes. Professor Stephanopoulos shares his insights on the current state of election law, the impact of recent Supreme Court decisions, and the ongoing challenges in campaign finance. By the end of the episode, you’ll understand why every election is crucial and how the legal community can uphold the integrity of our democracy.
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What is ABA Law Student Podcast?
Presented by the American Bar Association’s Law Student Division, the ABA Law Student Podcast covers issues that affect law students, law schools, and recent grads. From finals and graduation to the bar exam and finding a job, this show is your trusted resource for the next big step.
Todd Berger (00:01):
It's October, 2024. While we know you're 100% focused on your legal education as you should be, it wouldn't be surprising if you were sparing just a little attention to the upcoming elections these days. It's hard not to. And while every American should take an interest in our electoral process, lawyers should remember that their role can go much further than just filling out a ballot. Voting is the foundation upon which our democratic system is built and legal professionals play a key role in its effective execution. Today we're going to dive into the world of election law, learn more about how our electoral system is doing and how you can get involved. This is the a, a Law Student podcast. Hey, Manny, great to have you here today. We'll get started shortly. First, we wanted to let our listeners know that unfortunately, Shay is not with us this week. Shay is busy otherwise doing law student and work related things, and she'll be back on our next episode. But great to have you here today, Manny, and talking about a really important topic this time of year. So what do you got for us?
Manny Fernandez (01:19):
Yeah, really happy to be here. Shay will be missed. I'm super excited about this interview because it's so topical. We have an election coming up and I had the amazing chance to speak with Professor Nicholas Stephanopoulos, professor of law at Harvard, and probably the preeminent authority. I mentioned this in the interview, gerrymandering election law. He's with us today specifically to talk about election law and how it relates to us as law students. So very excited for this one.
Todd Berger (01:53):
As a law student, what exactly is your interest in election law? What made you want to reach out to the professor and cover this topic as a part of the podcast?
Manny Fernandez (02:01):
So I got to say at one point in the interview, professor Stephanopoulos mentions being a politics junkie and where I'm not really a politics junkie. I do often see the intersection between the law and politics, and really this election keeps being touted as a big one. And it seems like every year it's a big one. Every election that comes up is the biggest election. And so I really thought it would be useful for our listeners to hear from an expert in this field. And for me at least, I thought it would be super helpful to be a little bit more versed in the topic of election law because as law students, at least me personally, I get asked all the time by my friends and family who are not in law school, the nexus between the law and current events. So really it's something that to me is super important to know about.
(03:00):
Even though many of our listeners might not end up litigating cases in front of the Supreme Court or anything like that, I think it's super useful to be well-versed in this topic. And this is not exactly a topic that oftentimes many of us take in law school, but nonetheless, it's still important to know about because it really, like the professor mentioned, affects all of us. If you're concerned about democracy, then you certainly should be concerned about election law. And as future lawyers, as custodians of the law, we almost have a responsibility to make sure that we're educated on this.
Todd Berger (03:36):
Absolutely, and I'll tell you what doesn't suck this podcast. So let's get into it.
Manny Fernandez (03:45):
So Professor Stephanopoulos, you are probably the preeminent authority on gerrymandering, and you have certainly a ton of expertise on just the broader field of election law. Can you tell us a little about why the field of election law is important and why young lawyers or law students in particular should care about it?
Nicholas Stephanopoulos (04:05):
Yeah, so I think of election law as being so pivotal because it's the law that structures are electoral and our democratic process. And so our democratic process is of interest to almost everybody. What kind of representation do we have? What kinds of policies are adopted by governments at different levels? What kind of political participation do we have? Some of those are political or policy issues that law can't directly affect, but to a large degree, participation and representation and policy are all things that election law can shape to some extent. What voting laws we have can influence whether voting is easy or hard, and who votes what laws and parameters and restrictions we have on redistricting shapes, what our legislatures look like and partisan and also in racial and ethnic terms. And then who is in legislatures who's elected to executive branch offices that largely determines the laws that we live under. So for anybody who cares about the state of American democracy, the state of American governance election law is the legal field that most directly touches on those topics.
Manny Fernandez (05:34):
Can I ask what brought you, I guess, on a more personal level, specifically to dedicating so much of your scholarship to this subject? What was going on, I guess, in the world when you first decided that this was something you wanted to pretty much devote your academic career to?
Nicholas Stephanopoulos (05:50):
Yeah, so I guess I was a bit of a politics junkie before law school, and that continued in law school and still continues now. So I've always been interested in the political side of American governance. And so election law is relayed in all kinds of ways to politics, to polls, to campaigns for office. So that was one interest that I had. I was also an undergrad government major, so I thought a lot about political and governance topics as an undergrad. When I was in law school, a really interesting partisan gerrymandering case was argued in front of and then decided by the US Supreme Court. That was VV Jubilee back in 2004. And in that case, that was the court's first confrontation with partisan gerrymandering in more than 15 years. So there was a lot of interest to see what the court would say about gerrymandering.
(06:53):
The court also splintered in a really fascinating way. Four justices wanted to make partisan gerrymandering completely noticable. Four other dissenting justices offered three separate standards for what constitutes an unlawful partisan gerrymander. And in the middle, justice Kennedy said that he was open in the future to adopting a manageable gerrymandering standard, but he wasn't convinced by any of the proposals he had seen so far. And so I followed VI very closely. I wrote a paper when I was in law school on partisan gerrymandering. I eventually went to work for the law firm that argued Vith and worked quite closely with the lawyer who argued vi. And so I think not only my background as a politics junkie, I also had this fascinating Supreme Court case unfolding when I was in law school. And I guess that was enough to kind of push me into a focus on election law
Manny Fernandez (07:51):
That also confirms a lot about what I know about Justice Kennedy always in the middle on everything. So interestingly enough, when it comes to partisan gerrymandering, you've brought up a lot of the issues that this topic has revolved around on the federal level. There's been a lot of things that have happened on the federal level that have prevented partisan gerrymandering from going away completely. Can I ask if you have a proposed solution without federal intervention?
Nicholas Stephanopoulos (08:22):
Yeah, there are a range of different ways that we can curb or eliminate partisan gerrymandering. A federal judicial solution is now off the table thanks to the Supreme Court's decision in rau common cause a few years back, a federal legislative solution to partisan gerrymandering is very much still on the table. So there was a bill, there were several bills in Congress in 20 21, 20 22 that would've directly tackled gerrymandering, at least at the congressional level. One of those bills would've required states to use independent commissions to draw congressional district lines. That's the approach that quite a few states already use, and that basically every foreign country uses to prevent self-interested politicians from drawing district lines. And then one of the congressional bills actually the one that got the furthest in the process and came within two votes of prompting Democrats to get rid of the filibuster for democracy issues. The final bill had a different strategy. It would've adopted a quantitative partisan bias ceiling, and it would've said politicians can keep drawing district lines, but we have this formula that we'll use to calculate the partisan bias of any map that they come up with and that bias can't exceed a certain number. And so that would've been a different federal legislative strategy leaving the power to redistrict in politicians' hands, but capping how much bias they could insert into district maps.
Manny Fernandez (10:07):
So that's very interesting. But it seems almost like you're Solomon splitting the baby there. It's like you're allowing some degree of bias. Can you speak a little bit more about that, what that would entail?
Nicholas Stephanopoulos (10:19):
Yeah. My preference as a reformer in this area is the structural root.
(10:24):
I think that when it comes to drawing lines that directly affect the fates of their own careers and their party, you just can't trust politicians with this activity. And that's why Britain, Australia, Canada, all the other countries that use single member districts have taken politicians out of the line drying process. But of course, there's a lot of opposition to that more dramatic move among sitting members of Congress, including sitting democratic members of Congress. And so the formula-based approach was a way to hopefully curb a lot of the abuses of gerrymandering without needing the structural reform. And it definitely, we would've left some partisan bias in the system. It would've been a second best solution, but it would've dramatically reduced the partisan bias of district plans around the country. And so that would've been a great leap forward, even if it didn't completely eliminate the bias that we get from gerrymandering.
Manny Fernandez (11:30):
That being said, do you think structural reform would ever be possible, or is it just pie in the sky if it comes down to politicians making these decisions and politicians are self-interested in many ways? Again, could this just be, is it in any way feasible or is that just blind hope?
Nicholas Stephanopoulos (11:50):
Yeah, at the state level, it's often possible just circumvent politicians. And so a bunch of states have gotten their independent commissions through voter initiatives that many sitting politicians opposed, but voters approved in a statewide vote at the federal level in normal times. I would agree with your pessimism. That's why we haven't seen Congress mandate commissions over the last two centuries plus. But we're kind of a unique moment where serious redistricting reform is now really part of the Democratic party platform and is also a relatively salient issue nationwide in a way that it wasn't historically. And so I now tend to think that if there's ever a substantial democratic majority on Capitol Hill, I think 95% plus of Democratic politicians I think would vote for aggressive structural redistricting reform. That's a new development. And so I think that today this kind of reform is more conceivable than it basically any point in the past.
Manny Fernandez (13:00):
I also want to address the elephant in the room a little bit, which is the fact that as of recording this, we're just a few weeks away from a major election in our country. And I do want to keep the conversation as apolitical as possible, but I wanted to ask you personally what kind of unique insights you might be able to offer us that are especially relevant to this upcoming election?
Nicholas Stephanopoulos (13:22):
A couple of observations. One is that this is a much more normal election than the last presidential election, which is really encouraging from the perspective of administering the election in a predictable sound way. So 2020 was held in the middle of the pandemic states were changing their election laws left and right. There's a huge amount of litigation over states electoral policies. None of that is happening right now. This election is coming at a time of relative stability in terms of election laws. That's a good thing. Another pretty interesting development since we were just discussing the partisan bias of the US House as a whole is that at the moment, the US house is pretty fair, pretty undistorted in aggregate. There are lots of individual biased maps at the state level, but they basically all canceled out in 2020 and 2022. And the best estimates now are that the overall level of bias in the house should be quite low by historical standards in 2024. And so that's also really encouraging. It means that whichever party wins, the majority of the US House vote nationwide is very likely to win a narrow majority of the US house. And so I think the whole electoral ecosystem is therefore in a somewhat healthier place than it was in 2020, let's say.
Todd Berger (15:00):
We'll be right back. So many great first part of our discussion with Professor Stephanopoulos. Really important stuff, interesting stuff about the current state of election law for our listeners, what's your big takeaway from what you talked about?
Manny Fernandez (15:21):
So my big takeaway I think was not just Professor Stephanopoulos did a great job of laying down, I guess the framework of the current state of our nation's election law landscape, but also his insight on reform was interesting to me. He laid out a lot of different options for reforming things like partisan gerrymandering, which have been a longstanding problem in our country. But it's almost like this, so many things in the law, it's almost like this a Boris the snake eating its own tail. This is a problem that depends on politicians who have self-interest in not reforming this problem. So it was a really interesting topic to me. He also compared the United States to other nations when it comes to a specific topic, how our legal landscape is a little bit behind other commonwealth countries. It's tough to kind of see where this ends, where the line ends, where it begins, and if reform like this is really going to be feasible in the United States, probably on a more local level, maybe not on a major national level, but who knows.
(16:32):
He also mentioned that our country and our system has sort of the guardrails have held up and we've sort of returned to status quo ever since Covid. While that may be true, I think as a law student and surrounded by other people my age, everyone, if you have your hand on the pulse of what's currently going on in our nation, everyone is watching the news and everyone is actually concerned about the legitimacy of our democracy and our electoral system. So even though again, maybe the guardrails have held up and it seems like we're going back to status quo, at least compared to Covid times, there is still a perception of shakiness in our electoral system, which definitely needs to be addressed, I think. And I think that's where we come in as legal professionals to, I guess assure everybody that the legal system is strong, our democracy can be strong. So I don't know, at least that was, I think my major takeaway.
Todd Berger (17:37):
Yeah, I thought that was actually really interesting was he talked about something that I found a little surprising, which was that this election is more normal than the last or more stable than the last, which I can understand in the sense Covid played a role in sort of well how that past election was conducted. But when you think about what that means that this is more normal than the last, what does that say about our current understanding of normal?
Manny Fernandez (18:05):
Yeah, it changes. It's a whole new normal, and it certainly, I 100% understand what the professor means, but it certainly doesn't feel that way on a visceral level. Again, from a very sterile legal standpoint, it looks like our system is putting itself back together. We're back to normal. But it doesn't feel that way, does it? And when I talk to people, at least people who are both in our profession, and even more so people who don't really understand the law, they don't feel like we're in a normal state. I mean, it seems almost like maybe the goalposts have shifted in our legal environment. And yeah, it's certainly of great relevance to law students who are in the midst of learning the ins and outs of things like constitutional law. One of my professors mentioned that law one stuff almost never changes the structures of government. Well, now we're kind of in this inflection point where a lot of the law one stuff is changing and we don't really even know as law students if by the time we graduate, it'll still be good law. And it has a lot to do with the current state of our democracy.
Todd Berger (19:20):
When you walk around your law school and you're just one law student, and even within your own law school, I'm sure you have your own kind of network of people that you connect with and talk to. Do you think the sentiment is one of optimism about lawyers' role in the future of American elections? Or do you think students are just feeling really apprehensive, really pessimistic? How is everything that's going on in the country, in your view, really impacting lawsuits in particular? How's this all filtered through how law students think about their lives and their future?
Manny Fernandez (19:59):
Future? Yeah, there is this sense of futility sometimes where we're putting so much effort and so much time into learning about the strictures of our laws and of our constitution specifically. And then so much of it can be put into flux so quickly by sometimes a shifting supreme court sometimes by a legislature that is influenced through perverse incentives. So there is a bit of pessimism. I mean, buried underneath all of the concern about passing midterms and finals and making sure that you're taking good notes in class. There is a bit of a sense of pessimism, I would say.
Todd Berger (20:40):
Absolutely. So I sense that and that a little bit of anxiety from our students as well. And I think lawyers have a really unique role to play in what elections look like in ways that people who have other really important jobs, they're doing other really important things, but it's not as connected to the legitimacy and fate of our democracy. So on that uplifting note and with the promise that in this next segment there'll be no snakes eating themselves, let's hear the rest of your conversation with Professor Stephanopoulos.
Manny Fernandez (21:17):
What would you say are some of the most noteworthy recent developments in the field that I guess have stood out most to you as an expert? And can you tell us why?
Nicholas Stephanopoulos (21:26):
Yeah, I guess a couple summers ago we had the Supreme Court deciding two really important election law cases in a pretty good way. And so this adds to my sort of cautious optimism going into 2024 election. So first there was Alan v Milligan where the Supreme Court rejected a really audacious challenge by Alabama to the way that Voting Rights Act lawsuits have worked over the last 40 or so years. The court reaffirmed the existing Voting Rights Act, doctrinal framework. For the first time ever, the court required a state to draw an additional minority opportunity district where minority voters can elect their preferred candidates. So it was a very unexpected development to see John Roberts, who cut his teeth opposing the Voting Rights Act, writing an opinion confirming the traditional framework for applying the Voting Rights Act. The other case was more the Harper, which raised the question of whether there are certain state legislative choices about federal elections that can't be second guessed by courts or maybe by administrators or maybe the governor because of a couple provisions in the Constitution that refer to the state legislature as the regulator of federal elections.
(23:00):
And in War V Harper, the court largely, if not entirely rejected this independent state legislature with theory. The court allowed governors and administrators and courts to remain involved in regulating federal elections. And that's really good because the state level officials that I trust the least to regulate federal elections are state legislators. They're often elected through gerrymandering. They have deep partisan ties to presidential candidates and members of Congress. I do not trust them to impartially fairly regulate federal elections. And so from a small democratic perspective, it was a really good development to see the court rejecting the more aggressive disruptive versions of the independent state legislature theory.
Manny Fernandez (23:53):
What about in the realm of campaign finance law
Nicholas Stephanopoulos (23:56):
There? I think the field is largely a disaster in my view. Most other democracies permit significant regulation of money in politics because they realize that money in politics can cause all kinds of harms to the democratic system. It can breed corruption, it can make elected officials dependent on big funders as opposed to people themselves. I've written about how money and politics can cause misalignment between public policy and what people actually want public policy to be. So if you look at Canada, Australia, many other countries, they allow significant regulation of campaign funding to avoid those democratic harms. So here, I think the court went off the rails a while ago in Citizens United in particular, but also in quite a few other campaign finance decisions that have struck down all sorts of federal and state campaign finance limits. Putting the legal debate aside, the other, I think really interesting development in this area are one ever growing money in politics. So the amount of spending in elections has grown at much higher than the rate of the economy or the rate of inflation over the last 10 or 20 years. And also what had been a historic advantage for Republicans has now turned into either parity or an advantage for democratic candidates. And so it's interesting in partisan terms that the money flowing into the system is no longer consistently advantaging Republicans the way it did in the sixties, seventies, eighties, nineties, two thousands.
Manny Fernandez (25:43):
Would you say that this is a place where lawyers can step in and lawyers can play a really strong role in ensuring compliance and transparency, I guess, in our campaign finances? Is this an opportunity for a lot of the people who are listening to us today who might be interested in this field to maybe pursue a career path where they can truly make a difference?
Nicholas Stephanopoulos (26:06):
Yeah, there's a lot of work out there in the campaign finance compliance space. So both the federal government and state governments have all kind of rules about disclosure and reporting that candidates have to comply with. And so nobody can run for office without a campaign finance lawyer. And so there really is a lot of work out there for federal and state and local candidates.
Manny Fernandez (26:34):
There are a lot of still active live issues out there that a lot of young lawyers or future lawyers could potentially make a part of their practice in the future that will truly and can truly impact not just their own careers, but also democracy as a whole. In our country, sometimes we feel like something like an area like election law is kind of set in stone, but it's actually interesting to see that there are lots of live issues and lots of things that are still kind of up in the air and still there's room for change or improvement specifically in the areas like redistricting and election administration.
Nicholas Stephanopoulos (27:17):
This is one more area where there's a lot of need for labor and thought elections only work because hundreds of thousands of people, some volunteering their time, some getting paid for their time, all come together to run elections. This is a huge enterprise that requires a lot of effort from lawyers and non-lawyers across the country. There's never ending, I guess, litigation and policy debate over the voting process. And so I think regrettably, the parties have turned voting into ideological hotspot, and there are a lot of states enacting voting restrictions around the country. There are a lot of lawsuits over those voting restrictions. There's also a lot of activity on the other side making voting easier in some states that doesn't spawn as much litigation, although now we're actually seeing efforts by the Trump campaign to argue that certain voting expansions go beyond state or federal law in some way or improperly result at a higher risk of fraud. So we're seeing litigation even extending to voting expansions, which had been relatively legally non-controversial until recently. So I'm kind of disappointed by how much activity there is in this area. But I guess the bright side for lawyers is that there is a lot of activity, and so there are a lot of ways to get involved in the fights over voting policies.
Manny Fernandez (28:55):
Yeah, certainly. So before I let you go, I'm interested in learning a little bit more on the broader constitutional principles that election law touches. For the lawyer out there who's listening to this, who is maybe thinking, well, I just want to get into personal injury, the young law student who's figuring out what they want to do, and maybe they don't think they're going to be doing anything in the public sector. How does this field kind of touch on the rest of the law and specifically constitutional principles, but in any other way that you think it might affect people who might not be getting involved in election law at all?
Nicholas Stephanopoulos (29:34):
Yeah, great. So election law is tied to constitutional law in a number of ways, more so than is the case for most public law fields. So first of all, a lot of the Constitution covers the structures of election law, who needs to hold elections for different offices, how the selection of different elected officials is going to work, who's entitled to vote, and on what basis can the right to vote be denied or not be denied or abridged? And so there's a fair amount of constitutional infrastructure about voting and the electoral process itself. There are also provisions like the First Amendment, the 14th Amendment, the 15th amendment that limit the ability of state and local actors to burden voting or redistricting on certain grounds. And so we have one line of doctrine under the first and 14th amendment that bars unjustified burdens on voting itself. We have a couple of lines of doctrine under the equal protection clause that limit redistricting.
(30:49):
So you can't mal apportion district, you can't draw districts with race as the predominant motive. You can't deliberately dilute the vote of a minority group. Even partisan gerrymandering is technically non justiciable, but the court concedes that extreme partisan gerrymandering is unconstitutional. So even there, there's a constitutional hook. And so part of what I like about election law is that it's grounded in not just norms about democracy, not just statutes, but also a range of fundamental constitutional provisions. I sometimes think of election law as applied constitutional law. And so yeah, there's a clear constitutional dimension to many election law disputes.
Manny Fernandez (31:39):
That's a good way of putting it. Applied constitutional law. It's where the rubber meets the road. Really. You'll be right back after this.
Todd Berger (31:54):
So Manny, picking up on where your interview ends, there's some types of decisions that have come down that the professor talked about from the Supreme Court. There's also some failed legislative initiatives. There's a lot going on in this space that it seems like lawyers are involved in after talking to a professor. Is election law an area that you think you might want to practice?
Manny Fernandez (32:14):
I think if the opportunity presented itself, absolutely yes. But beyond that, like I mentioned a little bit earlier, even if it ended up being something that I never touched in my practice, we have I think, such an important responsibility as legal professionals to be well-versed in election law. We're in a way kind of like the Pretorian guard of our nation's democracy. So many, I mentioned at some point that so many of our listeners are going to disproportionately be the legislators that enact these laws or the judges that decide these laws or the lawyers who go to court and litigate these very important outcomes. I mean, it's no secret that the legal profession is the one that lends itself the most to policymaking. And so I think even if I personally end up never practicing election law, it's certainly a greater responsibility that we have to make sure that we know what's going on in the sphere of election law.
(33:23):
And truly, I mean, after this conversation with a professor, it seems like there's a lot of opportunity out there for work even beyond, again, even if you never end up arguing in front of the Supreme Court, there is a lot of work to be done from work done at prosecutor's offices. This is not stuff that is only done on a federal level or on a supreme Court level. It happens in localities. And oftentimes that is where a lot of the important questions come from. The professor mentioned the Allen v Milligan case where the Supreme Court struck down the Alabama partisan gerrymandering or the partisan redistricting. That all started at a very local level and started with attorneys, local attorneys in Alabama who really were affecting outcomes that touch the rest of the country. To his credit, the professor mentions there is a lot of work to be done, and there certainly is. And if you compare our nation to many other countries around the world, there are certainly changes that we can enact that would make our democracy a lot stronger in a lot of different realms. He mentioned that there's a lot of work to be done in campaign finance, for example, and who does that weight fall on? It falls on the legal professionals, the people listening to this podcast.
Todd Berger (34:45):
Yeah, absolutely. I think it's a really important point for students to recognize is that a very, very, very small percentage of lawyers will ever argue before the Supreme Court. So you might think, well, this election law stuff has nothing to do with me. Because I think a lot of our focus on what goes on in elections are the cases that get to the Supreme Court on these complex constitutional issues. And in reality, there's all different kinds of election related issues that happen all the time at the local level. So many places in the country on election day, there's a prosecutor who's assigned to deal with the things for election court judges who their dockets cleared for election related issues. And there's a lot of different lawyers who are involved in public interest side of things and good governments groups who are there to deal with things might come up on election day.
(35:38):
So if you're concerned about election law, if you're concerned about the integrity of our democracy, regardless of whatever your political affiliation is, don't think as a law student that this is fanciful stuff that five lawyers in America are going to deal with. These are things that, like you said, they happen every day at local levels, and there's really important ways in which you, as a practicing lawyer can get involved in making sure that our elections are fair. So there's definitely a space out there for law students and certainly young lawyers to be able to meaningfully contribute in this area.
Manny Fernandez (36:15):
Yeah, absolutely. And it does, again, it touches so many other fields of law, administrative law, and to put it in the professor's words, election law is applied constitutional law, and it's the stuff, it's the stuff that brought so many of us to law school. If you're concerned about our democracy, if you're concerned about our nation's integrity and the integrity of our republic, I guess to not put it in too lofty of terms, then this is it. This is the kind of law that you should be looking into. And really, it doesn't take a super fancy Supreme Court litigator. Sometimes. All it takes is somebody who has sat in that law school classroom for three or four years and comes out with the preparation necessary to enact real meaningful change, sometimes on a micro level, sometimes on a macro level. But it really is so necessary for all of us to be aware of the role that we have as legal professionals in preserving our nation's democracy.
(37:26):
And so it all comes down. It all really comes down to this, and again, we can be pessimistic about how our laws are in flux, and our constitutional law specifically seems to be changing, but I don't know, what do you guys think? Our listeners can weigh in on this and tell us, as law students, do you feel discouraged about what's happening? Or do you feel like this really is just an opportunity? Because it really is times like this when opportunity strikes, I guess, to be a good litigator to go out there. And actually, like I said before, an enact change.
Todd Berger (38:04):
Once again, thanks to Professor Nicholas Stephanopoulos, if you want to dig more into this subject. Professor Stephanopoulos is written extensively on election law, so you should check that out. And like Manny said, we want to hear more from you on today's topic. So share your thoughts with us on the a, a Law Student Division socials, or through a review on Apple. If you're looking for even more content curated just for you, head over to the a a Law Student Division website and become a member. And before we go, we'd like to thank our production partners at Marine Media and to thank the a, a law student division for making this show a reality. We'll be back next month with our next episode. See you then.