It will not be long before Americans are voting on iPads or similar tablets. The current generation of voting equipment, purchased after the “hanging chad” debacle of 2000, is fast ending its expected lifespan. Election administrators want to replace single-purpose voting machines, which are warehoused for all but a few days each year, with multipurpose devices, which local governments can devote to nonelectoral uses generally, but can reconfigure with a voting-specific “app” for Election Day.
Anticipating this development, we should envision a new kind of sample ballot that voters can view on their own tablets: one that looks exactly like what they will see on Election Day except that when the voter touches each candidate’s name, a video pops up with a message from that candidate. As all candidates seeking the same office would receive equal time for their messages, this “speaking ballot” would function like a debate between competing candidates. You can call it the “speech-and-debate ballot,” if you prefer.
Perhaps for some offices, like that of U.S. Senator, touching the title of the office could open a moderated debate between the candidates for that office. The ballot would house not merely separate videos prepared by each candidate’s campaign, but a genuine debate where the candidates share the same stage and must respond to questions from the moderator and points made by each other. Think of it as a twenty-first century variation on the famous Lincoln-Douglas debates. To sustain the attention of a contemporary audience, these debates could not be hours in length. But some conscientious voters would be willing to watch a half-hour debate in a competitive election for an important office—U.S. Senator, governor, and the like—especially if that debate were moderated by a media celebrity, like Jon Stewart, and if the video archive of that debate were housed on a sample ballot easily accessible at the voter’s convenience on the voter’s own smartphone or tablet computer.
Even without moderated debates, these speaking ballots could reduce the relative influence of privately financed campaign ads. Consider the most rudimentary form of a speaking ballot: Each candidate may provide a thirty-second campaign message linked to his or her name on the ballot. This would merely be side-by-side dueling campaign ads like those placed on network or cable television. Even so, this speaking ballot would be a significant step in the direction towards equality of campaign discourse compared to the traditional world of privately financed TV ads. Precisely because the two ads would sit right next to each other on the sample ballot, voters could quickly and directly compare the most essential messages that each campaign wishes to convey. Each message would have equal opportunity to influence these voters based solely on the merits of its contents, unaffected by any inequality in private wealth between the campaigns.
To be sure, as long as current campaign finance jurisprudence prevails, the equal-opportunity messages linked to the speaking ballot would not be the only campaign-related speech that might influence a voter. Each campaign still could purchase traditional TV time with privately financed funds. Additionally, separate supporters of a candidate could engage in so-called “independent expenditures” to purchase their own ads to promote that candidate’s campaign. In a world of vastly unequal private wealth, it is easy to envision some candidates promoted by a flood of TV ads paid for by superrich supporters, while other candidates receive only a trickle of TV promotion funded by supporters with precious little cash to spare for political campaigns. Thus, a great inequality in the opportunity to persuade voters on the relative merits of competing candidates would still obtain with respect to campaign ads funded by private wealth.
Nonetheless, adoption of the speaking ballot would be a major step in the direction of electoral equality. This essay will explain why and sketch out some preliminary thoughts on how best to implement the idea.
EQUAL ACCESS AND THE SPEAKING BALLOT
In a world with the speaking ballot, there is reason to be less concerned by the inequality of privately financed campaign discourse. For one thing, it is possible that the power of traditional TV advertising may diminish with the growth of Internet TV. The purpose of a traditional TV ad is to pay for access to eyeballs. But those eyeballs may not be there if viewers are watching TV over the Internet at a time of their own choosing, which might be after the election is over. (Not everyone has yet finished the second season of House of Cards or even gotten around to starting Orange Is the New Black). Moreover, even if there are certain forms of time-sensitive programming, like sports or news, the price of Internet ads may be significantly lower than the price of traditional TV ads. A cash-poor political campaign might be able to purchase enough space on a sports or news website for a link back to its own campaign website, whereas the campaign could not have afforded a thirty-second spot on cable.
But even if Internet ads become as expensive as traditional TV ads (at least for prime spots on premium sports or news websites), or even if traditional TV ads continue to predominate as the best use of campaign cash, there is good reason to think that a speaking ballot would diminish the relative influence of the privately financed campaign ads. When a speaking ballot is so easily accessible, many voters will choose to get their information directly from the candidates’ messages on the speaking ballot, and they will discount the privately financed campaign ads on the Internet or TV. The now-longstanding tradition of presidential debates illustrates this point. Because voters tune into the presidential debates to watch the head-to-head competition between the candidates, privately financed TV ads have much less influence in presidential elections than in down-ballot races that lack equivalent debates. The presidential debates are truly do-or-die moments for the candidates; the debates have immense influence because of the head-to-head competition. Campaign ads rarely have the same influence in a presidential election, the “Swift Boat” ad of 2004 being a prominent exception because its allegations were not effectively countered (not because of the amount of funds spent to disseminate that ad).
The speaking ballot has the potential to play an equivalent role for down-ballot races as the presidential debates do for the top-of-the-ticket contest. Insofar as voters come to expect that the speaking ballot is where to find the head-to-head competition between the candidates, they will turn to the speaking ballot in order to make their judgment about the relative merits of the competing candidates. If the speaking ballot contains a link to a moderated debate between the candidates, this will be even more the case. But even if the speaking ballot contains only side-by-side campaign messages, that contrast will be more influential than the stray privately funded ad that interrupts whatever the viewer was intending to watch.
The speaking ballot will not eliminate the influence of privately financed ads completely. That would be possible only by a revolution in campaign finance jurisprudence. But that revolution is unlikely to occur, and there are reasons to believe that it would be undesirable compared to a world in which privately financed campaign messages supplemented the existence of the speaking ballot.
Consider what it would take to eliminate privately financed campaign ads entirely. It would not be enough to overrule Citizens United and McCutcheon, the Roberts Court’s two recent, much-vilified decisions. Eliminating these two precedents would still leave the 1976 foundational precedent of Buckley v. Valeo, which entitles billionaires like Sheldon Adelson or George Soros to spend their wealth on campaign advocacy. And it is pointless to overrule Buckley as long as the Press Clause of the First Amendment guarantees that newspapers and other media outlets may devote their resources to circulating campaign endorsements. Given Forbes Magazine, Bloomberg News, and Huffington Post, it would be easy to add Adelson Times and Soros Journal.
A more promising strategy for pursuing the goal of greater equality of resources for the dissemination of campaign messages is to adjust the relative balance of power, in terms of influence over the electorate as the target audience, between the domain of campaign discourse governed by the norm of equal access, on the one hand, and the domain of campaign discourse governed by the norm of financial freedom, on the other. Although these two domains have both existed since time immemorial, the technological innovations of cyberspace make it possible to increase the relative power of the equality-governed domain compared to the wealth-governed domain.
Equal access as a governing norm in the context of campaign discourse is by no means dead after Citizens United and McCutcheon. Sean McCutcheon was not entitled to purchase additional minutes of oral argument at the Supreme Court so that his attorney might have a better chance of being more persuasive. Oral argument at the Supreme Court is governed by a strictly enforced norm of equal time for opposing sides, usually thirty minutes each per case. Chief Justice Rehnquist was well-known for cutting off an advocate midsentence when the red light came on at the end of thirty minutes. If Chief Justice Roberts is slightly more lenient with the red light than his predecessor, it is emphatically not because private wealth paid him to be a bit more permissive. That would be entirely inappropriate in the context of equal time for each side in an oral argument, and the author of McCutcheon does not disagree. The point is that private wealth has absolutely no role to play in the allocation of oral argument time at the Court, which instead is governed entirely by the norm of equal access.
The same point, of course, applies to the presidential debates. The candidates negotiate exactly how many minutes, or even seconds, are permitted for opening statements, rebuttals, and the like. No candidate is permitted to purchase extra time in the debate, and no one thinks that causes a First Amendment problem. Buckley, Citizens United, and McCutcheon simply do not apply in the context of these debates, which are also governed by the norm of equal access.
To use another example, consider the ballot itself. Each candidate’s name and party affiliation is displayed in similar font. No candidate is entitled to pay for more space on the ballot or a bigger font size, as if placement on the ballot were an old-fashioned newspaper ad. Being displayed more prominently on the ballot than one’s opponent would be a real advantage for a candidate, and one with ample financial resources would love to use them to purchase this advantage. But private wealth has no role to play in determining how a candidate’s identity appears on the ballot. The ballot itself, in this sense, is entirely off-limits to private wealth and is governed by the norm of equal access.
Underlying all three of these examples is the basic First Amendment idea of the public forum. We need not delve into the details of the public forum doctrine. It suffices to say that equal access prevails when a public forum exists and the doctrine thus applies. Consequently, for anyone interested in increasing the role that equality plays in the realm of campaign discourse, the strategy should be to figure out how more campaign discourse might occur within the context of a public forum, rather than in domains of communication governed by the freedom to spend private wealth as one wishes.
The speaking ballot is one such strategy, but there may be others that build on the new Internet-based technologies. What if the system of presidential debates was expanded significantly to encompass all other major elective offices, like U.S. Senator, governor, and maybe even U.S. House and state legislative seats? Even without a speaking ballot, these debates could all be housed on a new website operated by the government, www.elections.gov. Care would be needed in setting up the organizational structure that picks the moderators for all these debates. But the successful Commission on Presidential Debates serves as a model.
Indeed, even if the government itself does not provide technologically innovative public forums for campaign discourse, the evolving structure of the Internet indicates that it might be possible for a civic-minded private entity to replicate the idea of a domain governed by the norm of equal access. Suppose, for example, that Google TV, or Apple TV, as a public service created a web-based platform where all candidates could upload their messages free of charge. Maybe Google TV, or Apple TV, would hire someone like Jon Stewart to interview candidates or moderate debates, all governed by strict fidelity to the norm of equal time and access in order to be consistent with this public service mission. If done well, this website could build an audience for its content, and candidates or their supporters could not use their own private wealth to purchase extra access to this special civic-function website.
We could even imagine Google TV, or Apple TV, as the sponsor of this civic-function website embedding links to this specific site elsewhere on its vast array of websites. Imagine in the future watching a sporting event on Google TV and, instead of (or in addition to) seeing on the screen a link to one candidate’s campaign video—this link purchased as an Internet ad with private funds—the viewer sees a link to www.elections.org, the website that Google TV operates as a public service. Clicking on that link would thus take the viewer to a domain of campaign discourse governed entirely by the norm of equal access. Maybe it would even be possible for Google TV to require that any privately funded campaign ad purchased on any Google website also contain a tagline of this type: “For more information about the upcoming election, visit www.elections.org.” In such a scenario, the balance of power between campaign ads funded by private wealth and campaign messages governed by equal access would shift significantly toward the equality-governed domain. In that scenario, the private wealth of candidates and their supporters certainly would play much less of a role in disseminating campaign advocacy than it has in recent decades.
While we should explore such other ideas about new types of equal-access forums for campaign discourse, the speaking ballot is especially promising for several reasons. First, there is a natural reluctance to rely on the private sector to exercise exclusive responsibility for limiting the role of private wealth in campaign discourse. Even if Google TV, or Apple TV, were to undertake the kind of public service described above, what if down the road this private-sector firm decided to abandon the civic-minded endeavor, or was overtaken by a firm not similarly civic-minded? Would we trust Amazon TV to be scrupulous in adhering strictly to the norm of equal access? How much do, or should, we really trust either Google or Apple to play this public-service role, since ultimately they are for-profit enterprises? In the end, it is better if the government can step up to the responsibility of providing needed public forums governed by the equal-access norm, because the government by definition is the public sector. Relying on the private sector to fulfill the public sector’s obligations is inevitably a second-best solution, one to adopt in the interim until the government can get its act together. Pragmatism requires employing such second-best solutions as necessary, but idealism requires not losing sight of the vision of a robust government-operated domain for campaign discourse.
Second, the ballot is already a domain that is well-understood and well-accepted as the government’s responsibility and thus a public forum to which the norm of equal access applies. The speaking ballot is simply a natural extension of this preexisting idea, updated to take advantage of twenty-first century technology. Taxpayers are increasingly hostile to public financing for political campaigns. The speaking ballot, however, can be seen as a form of in-kind public financing that does not require the outlay of tax dollars to pay for campaign advertising. An electorate that already accepts the government’s role in preparing the ballot would be much more amenable to the idea of that ballot, in electronic form, linking to campaign messages provided by each candidate on strictly equal terms. Just as the ballot currently gives each candidate equal opportunity to provide party affiliation, the speaking ballot would be more informative for voters insofar as it gives each candidate equal opportunity to provide a link to a video message of specified length. Voters would welcome this additional information as part of a technologically updated ballot.
Implementing the speaking ballot would require thinking through some details. For example, what is the right length of video message to permit each candidate? One minute each? More? Or only thirty seconds? Perhaps specified length should vary from office to office, with more important “up-ballot” races receiving more allotted time?
Should candidates be permitted to submit whatever videos they want, as long as each video complies with the allotted length? Or should candidates be required to use a specified government-provided studio, with the opportunity only to film the candidates themselves each speaking directly into the camera—no extra images, background music, or slick production, in other words? Obviously, if candidates can submit whatever videos they want (consistent with the time limit), then inequality of available campaign resources could affect the quality of videos. Candidates with more money might be able to hire superior video producers. That would be a reason to limit them to the government-provided studio with the strict format of simple candidate-only speaking. But I am inclined to take a one-step-at-a-time approach, recognizing that permitting candidates to use their own resources to produce their videos still eliminates the use of private wealth to pay the advertising expense of placing the video in a prominent location where viewers readily will see it.
In whatever precise form it takes, the speaking ballot would be a major transformation in the conduct of elections in this country. It would be a change as significant as the adoption of the so-called “Australian ballot” a century ago. Indeed, the speaking ballot is an extension of the Australian ballot’s core concept of having the government, rather than private parties, print ballots. Previously, political parties used their own funds to supply ballots, which came in various shapes and sizes—to the detriment of ballot secrecy and democratic integrity. Once the government began preparing a uniform ballot for all candidates, no candidate’s name could appear in a more eye-catching color or font. The speaking ballot would simply extend this idea to the dissemination of a candidate’s main campaign message. Rather than requiring candidates to rely on private funds for this task, the speaking ballot would make this essential electoral endeavor a public function.
Precisely because these campaign messages governed by the equal-access norm would be linked to the ballot itself, they would play a special role in shifting the balance of power from the private-wealth domain to the equal-access domain, regardless of whatever other equality-oriented reforms might be pursued. At the moment when voters decide to look at their ballot, they would have instant access to each candidate’s main message, provided on strictly equal terms. Some voters would not bother to click on these links, and some voters will vote a straight party-line ticket regardless of whatever candidates might say in these instantly available messages. But the goal of equality in resources for campaign discourse does not apply to voters who are entirely unpersuadable. Private wealth would not affect these indelibly straight-party voters either. Instead, the issue concerns the voters who are open to persuasion, and the speaking ballot gives each candidate, regardless of campaign funds, equal access to these persuadable voters precisely at the moment that they are examining their ballot. In this way, the speaking ballot is a particularly powerful tool for increasing the role that the equal-access norm plays in campaign discourse.
Finally, perhaps the most persuasive reason to focus on the speaking ballot as a method of equalization is that the technological transformation of the ballot is already occurring; the speaking ballot is but a small step further. Los Angeles County, the nation’s largest jurisdiction responsible for running elections, is already pursuing the development of tablet-based voting technology on which voters can view, and even cast, their ballots at home. We are not yet at the stage where voters will be able to transmit these e-ballots over the Internet after filling them out. Instead, what L.A. County is contemplating is that voters, after completing their e-ballots at home, stop by a polling location and swipe their e-ballot to a reader that prints a paper copy of the voter’s choices. This swipe of the e-ballot would be much like swiping one’s smartphone to pay for a latte at Starbucks, or swiping one’s electronic boarding pass at TSA security at the airport. The printed copy of the ballot (produced by a machine that in the field is called a “ballot marking device”) would then, after the voter’s review for accuracy, be fed into a separate ballot-reading and vote-tabulating machine. This system of two different readers, separated by the paper copy of the voter’s choices, eliminates the risk that the tablet-based software could be hacked.
If L.A. County’s anticipated system becomes pervasive, as many believe, we can expect to see voters filling out their e-ballots at home on their tablets, even if they do not submit those ballots by email. We certainly can expect voters examining sample versions of their e-ballots at home, even if they are required to go to a polling place to cast their actual ballot. Even if some counties do not adopt L.A. County’s model but instead require voters to use the county’s own tablets stationed at polling places, these voters will have the opportunity to examine exact replicas of their e-ballots on their own tablets before going to the polling places. Moreover, Washington State already operates online “video voter guides”; it would take but a bit of website formatting to convert these video voter guides into sample e-ballots.
STATUS QUO OR INCREMENTAL CHANGE?: A REPLY TO PROFESSOR MANHEIM
I am delighted that Professor Manheim has vigorously and expertly engaged with the speaking ballot proposal.  I read her to be, on balance, supportive of moving forward with the proposal, depending on very important design details. My basic response is that I concur, and that we should work together to implement the proposal in a way that addresses the appropriately cautionary points that Professor Manheim raises.
I do want to ask one key question, however: Is the risk that something could go wrong with the implementation of the speaking ballot such that we are better off not trying to implement it in the first place? I emphatically do not think so.
I accept the basic proposition that some experiments in how to design the institutions of democracy would not be a good idea. For precisely the kind of reason that Professor Manheim raises—can we trust the regulators?—the concern is that some government official would horribly abuse their discretion. However, the relevant question is whether the speaking ballot, all things considered, would be an incremental improvement when compared to the status quo. The speaking ballot should not be compared to democratic perfection, or an electoral system free of all risk of partisan abuses. Like Professor Manheim, I worry greatly about partisan Secretaries of State and other election officials manipulating the administration of the electoral system to their own partisan ends. Elsewhere, I have advocated institutional reforms designed to minimize such partisan abuse to the extent humanly feasible. But the difficulty of minimizing partisan administration of elections is not a reason to abandon the speaking ballot, just like it was not a reason to abandon the original form of the Australian ballot.
Simply put, consider two alternative choices: (a) the world as it is today, with Citizens United and McCutcheon and the vast inequalities of resources available for campaign messages; and (b) the exact same world, except for the addition of the speaking ballot, even recognizing that it may not be implemented perfectly despite best efforts. I maintain that (b) is definitely better than (a). Or, at least, given that in our federalist system states are permitted to serve as “laboratories of democracy,” an enterprising state should begin to test the idea of a speaking ballot in practice. After all, that is what happened with the Australian ballot: Some states were early adopters, and then the idea swept the nation after being proved successful.
Moreover, the very process of moving to the speaking ballot may “nudge” (to use Professor Manheim’s useful term) the administration of elections to become somewhat less partisan. Insofar as the speaking ballot is perceived as more powerful than the original Australian ballot, there would be an insistence that the government body charged with administering the speaking ballot be structured to be scrupulously fair to all candidates. It would need to be designed to model the successful Commission on Presidential Debates. But just as parties tolerate the power of this Commission because it is not a “Government Veracity Bureau” with power to regulate all campaign discourse, so too could the parties come to trust a well-designed body with authority to administer the speaking ballot.
Would that authority be perfect? No. Would its existence be better than the current situation? Yes.
In one format or another, the era of sample e-ballots, available to voters at home on their own tablets, has arrived. We might as well take advantage of these e-ballots by converting them to speaking ballots by permitting candidates to link to a campaign video of specified length. Even better would be to let voters mark this sample ballot after they have had a chance to view this head-to-head comparison of the candidates’ competing campaign messages. With this simple step, we can transform the existing version of the Australian ballot into a new twenty-first century version that provides a much greater role for equal access as the governing norm of campaign discourse.
Copyright © 2014 by Edward B. Foley, Director, Election Law @ Moritz, and Charles W. Ebersold and Florence Whitcomb Ebersold Chair in Constitutional Law, The Ohio State University Moritz College of Law. I would like to thank the Brennan Center for inviting me to the conference that prompted this essay. I would like to thank Lori Augino, David Becker, Richard Briffault, Yasmin Dawood, John Fortier, Sam Issacharoff, Deborah Hellman, Steve Huefner, Johanna Kalb, Chisun Lee, Dean Logan, Michael Malbin, Robert Post, Wendy Weiser, and especially Lisa Manheim, for conversations relating to this essay.
 The report of the Presidential Commission on Election Administration, often known colloquially as the Bauer-Ginsberg Commission, sounds the alarm on the deteriorating reliability of the nation’s current stock of voting equipment and discusses the desire to replace it with “off the shelf” equipment:
"This lack of up-to-date standards has impeded the inevitable and much-needed transition of the voting process to off-the-shelf technology, such as tablets and laptop computers. Jurisdictions that use electronic voting machines usually deploy machines for a few days a year and then lock them up in storage for the rest. For cash-strapped jurisdictions that wish to keep pace with evolving technology, the purchase of hundreds of expensive, specialized pieces of hardware good for only one purpose—elections—no longer makes sense."
Robert F. Bauer et al., The American Voting Experience: Report and Recommendations of the Presidential Commission on Election Administration 12 (Jan. 2014), available at https://www.supportthevoter.gov/files/2014/01/Amer-Voting-Exper-final-dr....
 See, e.g., Dan Hopkins, Political Ads: Not as Powerful as You (or Politicians) Think, Wash. Post Wonkblog (Jan. 20, 2013), http://www.washingtonpost.com/blogs/wonkblog/wp/2013/01/20/political-ads... (analyzing recent relevant social science research and finding that presidential candidates get “surprisingly little” as a result of their campaign advertising).
 In a survey of voters in the 2002 election, 67% responded that they were influenced by the debates, while only 32% responded that they were influenced by campaign ads. Most Say Presidential Debates Influence Their Vote, Pew Research Ctr. (Sept. 11, 2012), http://www.pewresearch.org/daily-number/most-say-presidential-debates-in.... Beyond that, just consider the consequences of these “gaffes” in a presidential debate: “Gerald Ford’s faulty knowledge of Eastern Europe, George H.W. Bush’s looking at his watch and Al Gore’s audible sighing.” John Wihbey, Presidential Debates and Their Effects: Research Roundup, Shorenstein Ctr. on Media, Politics, & Pub. Policy (Oct. 16, 2012), http://journalistsresource.org/studies/politics/elections/presidential-d....
 Citizens United v. FEC, 558 U.S. 310 (2010); McCutcheon v. FEC, 134 S. Ct. 1434 (2014).
 See Buckley v. Valeo, 424 U.S. 1 (1976) (striking down federal limitations on independent campaign expenditures).
 See U.S. Const. amend. I (“Congress shall make no law . . . abridging the freedom of . . . the press . . . .”).
 See Solicitors General Panel on the Legacy of the Rehnquist Court, 74 Geo. Wash. L. Rev. 1171, 1177 (2006) (describing the experiences of various Solicitors General with Chief Justice Rehnquist, including cutting off speakers at the expiration of time).
 For the basics of the public forum doctrine, see Daniel A. Farber, The First Amendment 167–73 (3d ed. 2010). A public forum, as the term implies, is a space where all members of the public can go to express their political views. Hyde Park’s Speakers’ Corner is often cited as a quintessential example.
 For a history of the Commission’s role in presidential debates, concluding that the Commission “has operated honorably and free from scandal,” see Alan Schroeder, Presidential Debates: Fifty Years of High-Risk TV 300 (2d ed. 2008).
 Dean Logan, who runs elections for L.A. County, told Governing magazine:
"We want to build a ballot-marking process that has flexibility and is adaptable to the electorate we serve, for those voters who vote by mail, for those voters who might want to go to a vote center, or vote early or at neighborhood polling places. We want to give them a ballot to mark that is both intuitive and accessible. But then we want that to produce a uniform paper-based, human-readable ballot that is tabulated on an entirely different system that has no physical relationship to the device where the ballot was marked."
J.B. Wogan, L.A. County Designs a Whole New Voting System, Governing (July 7, 2014), http://www.governing.com/topics/politics/gov-why-los-angeles-county-want....
 For more information about the L.A. process and plans, see Katy Owens Hubler, Voting: What’s Next?, State Legislatures Mag. (Aug. 1, 2014), http://www.ncsl.org/research/elections-and-campaigns/what-s-next-6354209...Reimagining the L.A. County Voting Experience, Los Angeles County Voting Systems Assessment Project, https://www.lavote.net/Voter/VSAP/index.html (last visited Sept. 10, 2014).
 David Becker, who directs Pew’s Election Initiatives, sums it up: “I hear from a lot of folks in the field . . . [that] a tablet device, a printer, probably an optical scanner to read the paper ballot that gets printed . . . is going to be the wave of the future.” Rebecca Shabad, Problem at the Polls: Tech Stuck in the Past, Hill (May 7, 2014), http://thehill.com/blogs/ballot-box/205401-problem-at-the-polls-tech-rem....
 See 2012 Voters’ Video Guide – General Election, TVW.com, http://www.tvw.org/2012-video-voters-guide-general-election (last visited Sept. 10, 2014) (showing video voter guides sponsored by Washington’s Secretary of State).
 See Edward B. Foley, The Separation of Electoral Powers, 74 Mont. L. Rev. 139, 140 (2013) (proposing the idea and a possible working of the separation of electoral powers).
 Roy G. Saltman, The History and Politics of Voting Technology: In Quest of Integrity and Public Confidence 96–102 (2006).