ࡱ> @ ogbjbjFF ,z,,aW PPPL8,,,8d$$&_>(uH^^^^^^^$daRcX^666^^:::6^:6^::\lY^ ц&,8^"y^,^0&_7^"dD:XdDY^dY^ I!&:+|70iIII^^D ,:.,APPLICATION TO FILE AN AMICI CURIAE BRIEF TO THE HONORABLE PRESIDING JUSTICE, FOURTH DISTRICT COURT OF APPEAL, DIVISION TWO: Pursuant to California Rule of Court 13, subdivision (c), amici curiae Common Cause, California Voter Foundation, People For The American Way Foundation, Americas Families United, Center for Constitutional Rights, Computer Professionals for Social Responsibility, and Voters Unite! respectfully request permission to file the accompanying brief amici curiae in support of Petitioners and Appellants Linda Soubirous, Grace Slocum, Allen E. Hill, Russell Henson, and Verifiedvoting.org. As the individual statements of interest by each amicus explain, each of these nonpartisan, nonprofit membership organizations has long been active in efforts to secure and protect the right to vote. Amici thus have a strong interest in ensuring that Riverside County conducts elections in a manner that accurately records and counts each vote that is cast. The amici brief will assist the Court by identifying the specific statutory obligations to which Riverside County is subject in conducting elections using electronic voting machines as well as discussing the importance of recounts in light of the use of unproven, inherently flawed technology. Amicus Common Cause is a nonpartisan, nonprofit, citizens organization whose mission is to ensure open, accountable, and effective government at the federal, state, and local levels. Among Common Causes goals are to promote fair and honest elections and to strengthen public participation and public faith in institutions of self-government. Common Cause has more than 250,000 members and supporters nationwide, with active members and volunteers in every state, including thousands in California. Common Causes members are directly and adversely affected by voting systems that are insecure and unreliable. Amicus California Voter Foundation (CVF) is a nonprofit, nonpartisan public-interest organization headquartered in Davis, California that is dedicated to advancing the responsible use of technology to improve democracy. CVF has over ten years of experience working on issues where democracy and technology intersect, such as online voter education, Internet disclosure of money in politics, and electronic voting technology. CVFs president and board members have served on three task forces relating to democracy and technology topics under the leadership of two different California Secretaries of State: the Electronic Filing Task Force (1995); the Internet Voting Task Force (1999); and the Ad Hoc Touch Screen Task Force (2003). CVFs web site, , provides nonpartisan voter education resources to California voters each election. Amicus People For The American Way Foundation (People For) is a nonpartisan citizens organization established to promote and protect civil and constitutional rights, including the fundamental right to vote. Founded in 1980 by a group of religious, civic, and educational leaders devoted to our nations heritage of tolerance, pluralism, and liberty, People For has over 600,000 members and other supporters nationwide. People For is actively working with organizations across the country on the nonpartisan Election Protection Program, which is aimed at protecting the fundamental right to vote and have that vote be counted. One of People Fors primary missions is to promote the integrity and legitimacy of the electoral process and, to that end, it believes that electronic voting machines have the potential to provide accurate, secure, and accessible voting. In light of the problems in California and elsewhere with respect to such technology, however, it believes that true auditability must be demanded in order to prevent irreparable harm to California voters. Amicus Americas Families United is a nonprofit organization working to increase civic participation within underrepresented and low-income communities throughout the United States. Its Voter Protection Project is a nonpartisan initiative directed at insuring that all Americas voters have the opportunity to vote and that every vote cast is counted. Amicus Center for Constitutional Rights (CCR) is a non-profit legal and educational organization founded in 1966 and based in New York City. CCR is dedicated to the advancement and protection of voting rights and other rights guaranteed by the Constitution of the United States. CCR has long been active in protecting the right to vote and has litigated voting rights cases in Mississippi, Thornton v. City of Greenville, Browder v. Westbrook and In re Malone; in Tennessee, Muhammad v. City of Memphis and Cousins v. Hamilton County; and New York, Goosby v. Town Board of Hempstead and France v. Pataki. Amicus Computer Professionals for Social Responsibility is a public interest alliance of computer scientists and others concerned about the impact of computer technology, including electronic voting, on the public. Amicus Voters Unite! is a nonpartisan national grassroots network working for fair and accurate elections. Voters Unite!s Internet website is at . INTRODUCTION At issue in this case is the right to vote, one of the most precious and fundamental of our liberties. Since our earliest days, Americans have fought and died at home and abroad to secure and preserve this right for all of us. Both our state and our federal constitutions, as well as our state Elections Code, jealously guard this right against infringement by government action. As Appellants Appeal (Appeal) filed with this Court makes clear, Respondent County of Riverside has flagrantly disregarded both its constitutional and statutory obligations to protect the right to vote. It is of the utmost importance that this Court grant the requested relief to insure the Countys compliance with its electoral duties as mandated by law in upcoming elections, and thereby protect the integrity of the election and the rights of Riverside County voters. ARGUMENT This Court Should Grant Appellants Requested Relief To Preserve The Right To Vote as Required By Law Riverside County Has Specific Constitutional And Statutory Duties It Must Follow To Protect The Right To Vote Every vote counts if and only if every vote is counted, and counted accurately in a manner that can be verified later in a recount. The obligation of Riverside County to ensure the accuracy and verifiability of the methods it provides for casting and counting votes is not some untethered and toothless aspiration it can ignore on a whim; rather it is a constitutional and statutory duty of the highest and most solemn order. The United States Constitutions equal protection clause mandates that each voters vote must be counted as cast. Having once granted the right to vote on equal terms, the State may not, by later arbitrary and disparate treatment, value one persons vote over that of another. Bush v. Gore, 531 U.S. 98, 104-105 (2000) TA \l "Bush v. Gore, 531 U.S. 98 (2000)" \s "Bush v. Gore" \c 1 . Similarly, the California Constitution expressly guarantees that [a] voter who casts a vote in an election in accordance with the laws of this state shall have that vote counted. Cal. Const., art. II, 2.5 TA \l "Cal. Const., art. II, 2.5" \s "Cal. Const., art. II, 2.5" \c 3 . Accordingly, a qualified voter has a constitutional right to vote in elections without having his vote wrongfully denied, debased or diluted. Canales v. City of Alviso, 3 Cal.3d 118, 130 (1970) TA \l "Canales v. City of Alviso, 3 Cal.3d 118 (1970)" \s "Canales v. City of Alviso" \c 1 . To insure the accurate counting and inclusion of each citizens vote, California has an elaborate statutory scheme that closely dictates the actions local election officials must take before, during, and after an election. Among other purposes, California requires these measures in order to make possible accurate election recounts and contests that are capable of confirming as thoroughly as possible that each vote has been correctly counted and included in the total. This case requires the Court to apply the clear mandates of the election statutes pertaining to the electronic voting machines known as direct recording electronic (DRE) voting systems, and in particular to the Sequoia DRE voting systems used by Riverside County. It presents an issue of great importance that has not just statewide but national implications in light of the upcoming primaries and the ongoing national debate over the future of election technology. In particular, the Elections Code requires Riverside County to perform the following duties. Before The Election Before the election, Riverside County must test every DRE voting machine to insure it is working properly: Each machine shall be tested to ascertain whether it is operating properly. Elections Code 19321 TA \l "Elections Code 19321" \s "Elections Code 19321" \c 2 . Riverside County must perform this pre-election testing in the presence of political party representatives: At the specified time one representative of each of the political parties shall be afforded an opportunity to see that the machines are in proper condition for use in the election. Elections Code 19320 TA \l "Elections Code 19320" \s "Elections Code 19320" \c 2 . After the initial preparation, a precinct election board member or other duly authorized person shall inspect each machine and submit a written report stating whether the machine is arranged in all respects in good order for the election. Elections Code 19322 TA \l "Elections Code 19322" \s "Elections Code 19322" \c 2 . On Election Day The Sequoia DREs at issue here record the voters choices on an internal memory, a recording device from which the voting results are then transferred onto a removable memory card. The removable memory card is then physically transported to another computer for tallying and printout. Because the Sequoia DREs use a recording device to store the votes cast on each machine, they fall within the second paragraph of  TA \l "Elections Code 19370" \s "Elections Code 19370" \c 2 section 19370 of the Elections Code. Section 19370 TA \s "Elections Code 19370"  requires that, after the polls close on Election Day, each precinct board must, for each individual machine [that] is provided with a recording device, operate the mechanism to produce the statement of return of votes cast record in a minimum of three copies. In addition, [o]ne copy of the statement of return of votes cast for each machine shall be posted upon the outside wall of the precinct for all to see. Elections Code 19370 TA \s "Elections Code 19370"  (emphasis added). The requirement that the vote totals for each machine be individually printed at the close of the polls is also required independently by  TA \l "Elections Code 19234" \s "Elections Code 19234" \c 2 section 19234 of the Elections Code. Section 19234 provides that [a]ny voting system purchased using bond funds [as were Riverside Countys Sequoia DREs] that does not require a voter to directly mark on the ballot [as Riverside Countys Sequoia DREs do not] must produce, at the time the voter votes his or her ballot or at the time the polls are closed, a paper version or representation of the voted ballot or of all the ballots cast on a unit of the voting system. In addition, to posting the paper printout of the votes cast on each machine, election officials must use them to conduct a public manual tally of one percent of the precincts as part of the official canvass of votes: The paper version [of the voted ballot or of all the ballots cast on a unit of the voting system] shall not be provided to the voter but shall be retained by elections officials for use during the 1 percent manual recount or other recount or contest. Elections Code 19234 TA \s "Elections Code 19234" . During the official canvass of every election in which a voting system is used, the official conducting the election shall conduct a public manual tally of the ballots tabulated by those devices cast in 1 percent of the precincts chosen at random by the elections official. Elections Code 15360 TA \l "Elections Code 15360" \s "Elections Code 15360" \c 2 ; see also id. at 335.5 TA \l "Elections Code 335.5" \s "335.5" \c 2 , 336.5 TA \l "Elections Code 336.5" \s "336.5" \c 2 . After Election Day California provides that those challenging the accuracy of an election are entitled to review not just the ballots as cast by the voters (nonexistent in the case of the electronic voting machines at issue here) but any and all relevant material, Elections Code 15630 TA \l "Elections Code 15630" \s "Elections Code 15630" \c 2 , a category that includes the Countys pre-election DRE voting machine testing records, its redundantly stored electronic vote data, its records of the custody of voting machines and electronically stored voting data, and the audit logs of DRE voting machines and any other records of DRE voting machine operations during polling. Riverside County Has Refused And Is Refusing To Comply With Its Constitutional And Statutory Duties Riverside County makes no secret of the fact that it refuses to perform the plain and mandatory duties set forth above that are required when it uses DREs to conduct an election. It has affirmed its defiance of its statutory duties in its pleadings in the trial court below and by its conduct in previous elections. The Electronic Voting Machines At Issue Here Have A History of Malfunctioning DRE voting systems like the Sequoia DRE voting system used by Riverside County have been aggressively marketed and sold to California counties and other jurisdictions across the nation as a way to replace discredited punch card voting machines and other voting systems. While these machines show promise in eliminating some of the problems created by punch cards, serious other problems have arisen in connection with the DRE voting systems used in California elections as well as elections nationwide. Across the country, election officials and voters alike have discovered that DREs introduce a broad range of problems and subject elections to substantial risk of error through machine malfunctions, mistakes or negligence in the operation of these machines by electoral officials, or intentional mischief by malicious persons. The history of problems with these new technologies supports a rigorous application of the stringent requirements of existing California electoral law to DRE voting systems. Examples of Sequoia DRE voting system malfunctions include the following: Snohomish County, Washington (November 2004) Voters in at least four polling precincts in Snohomish County said that they encountered problems with the Sequioia electronic voting machines. When they touched the screen to vote for a candidate, an indicator showed they had selected the opposing candidate. In some instances, it took at least four attempts before the indicator showed the correct candidate. New Orleans Parish, Louisiana (November 2004) In Louisiana, state election officials received about 200 complaints of problems with machines, including two confirmed reports of Sequoia AVC Advantage machines in New Orleans Parish that were not working, according to Scott Madere, press secretary for the Louisiana Secretary of State. Sacramento, California (August 2004) During a demonstration for state senate staffers, Sequoias paper-trail-enabled electronic voting system failed to accurately record votes to its internal memory, an error that was only discovered by comparing the electronic data to the paper trail. Morris County, New Jersey (June 2004) The Sequoia vote tabulating computer could not read the voting results data recording the votes cast on individual machines off of the removable memory cards that are used to transport the voting results data from individual DRE machines to the vote tabulating computer. San Bernardino County, California (March 2004) In San Bernardino County, officials waited three hours for their new Sequoia vote tabulating computer to process the results from individual Sequoia DRE voting machines before resorting to shutting down the computer and starting over. Bernalillo County, New Mexico (November 2002) Insufficient memory capacity for the Sequoia software used to tabulate the votes caused about 25% of the votes not to be counted in the initial tally. Although about 48,000 people voted on 212 DREs, the initial tally given to the commissioners indicated that no racenot even for governorshowed a total of more than about 36,000 votes. Apparently, the software program used to report all of the votes had a capacity of only 64 kilobytes of data at a time. If any more data than that was fed to the reporting program in one chunk, it was simply not tallied. Hillsborough County, Florida (April 2002) The voting results data recording the votes cast on individual machines could not be read off of the removable memory cards that are used to transport the voting results data from individual Sequoia DRE machines to the vote-tabulating computer. Palm Beach County, Florida (March 2002) In a voting precinct using Sequoia AVC Edge voting machines, Councilman Al Paglia lost by 4 votes on a one-race ballot, but 78 ballots registered as blank. Voters also reported erratic behavior of the touch screens. Riverside County, California (November 2000) During the 2000 presidential election, a Sequoia vote tabulating computer began dropping votes cast on Sequoia DRE voting machines from the official vote tally. A Meaningful Recount Must Include an Examination of Voting Technology The California legislature has enacted a series of straightforward requirements that codifies common-sense, fundamental principles of transparency in government and democracy; put simply, if a local government elects to use technology to administer elections, that technology must be open to scrutiny in the event of a proper election challenge. Appellants seek nothing more than a meaningful recount as permitted under state law. For almost one hundred and fifty years, California has required election officials to preserve hand-cast paper ballots after an election in order to protect for the electorate the ability to investigate the veracity of the voting process and to verify results. For almost a century, recognizing that new voting technology presents significant risks to the integrity and openness of the election process, California has mandated that the public be given the opportunity to investigate the inner workings of voting machines both before and after elections. Today, with electronic voting machines representing the most opaque voting process to date, it should not the case that the electorate must take the word of voting officials that their votes were tabulated and recorded properly. A wide range of sources have recognized the pivotal role that auditability plays in ensuring the veracity of elections and in ensuring the proper performance of voting technology. In the groundbreaking July 2003 Johns Hopkins electronic voting machine study headed by Tadayoshi Kohno, Adam Stubblefield, Aviel Ruben, and Dan Wallach, researchers noted in detail the errors and manipulation that can occur outside the view of the kinds of meager review procedures offered by Respondents in this case: The most fundamental problem with such a voting system is that the entire election hinges on the correctness, robustness, and security of the software within the voting terminal. Should that code have security-relevant flaws, they might be exploitable either by unscrupulous voters or by malevolent insiders. Such insiders include election officials, the developers of the voting system, and the developers of the embedded operating system on which the voting system runs. If any party introduces flaws into the voting system software or takes advantage of pre-existing flaws, then the results of the election cannot be assured to accurately reflect the votes legally cast by the voters. In 2003, on behalf of the State of Maryland, RABA Technology Innovative Solution Cell (RiSC) performed a thorough review of Diebold touch-screen electronic voting systems and identified the auditability of election technology as a critical component of preventing and discovering foul play. In addition, California Secretary of State Kevin Shelleys 2004 DRE directive to state election officials implicitly identified auditability as a significant factor in the administration of accurate and trusted elections, whether it be with electronic voting machines or otherwise. As these and other authorities have demonstrated and continue to demonstrate, the ability to challenge close or suspect elections depends on the ability to review accurate and meaningful information about the voting technology in use. The Countys position that such detailed information is insignificant to a meaningful recount amounts to a cry of trust us instead that is categorically at odds with state law and is in any event contrary to the real-world experience of DRE voters across the country. CONCLUSION The ability to verify the integrity of voting technology is essential to conducting fair and open elections. Californias recount laws have and continue to perform that function, requiring that voting technology be open to review in order to confirm the results of elections. The solution is not, as Respondents have suggested, to assume that a cursory examination of the technology is sufficient to verify its accuracy. The solution is to open up the process and allow candidates and the public to verify DRE performance themselves as required by state law. For all of these reasons, Amici respectfully request that this honorable Court grant the relief prayed for by Appellant. Respectfully submitted, ______________________ Counsel for Amici CERTIFICATE OF COMPLIANCE Pursuant to California Rule of Court 14(c), I certify that this brief contains _____ words. _______________________ Richard R. Wiebe  King5 News, Scattered Reports of Voters Being Blocked and Machine Malfunctions, November 2, 2004, at http://www.king5.com/topstories/stories/NW_110204ELBelectronicvotingproblemsLJ.1aac5fda.html.  Paul Roberts, E-voting Problems Reported As Election Gets Under Way, IDG News Service, November 2, 2004, at http://www.itworld.com/Tech/2987/041102evoteprobs/.  Kim Zetter, Wrong Time For An E-vote Glitch, Wired News, August 12, 2004, at http://www.wired.com/news/evote/0,2645,64569,00.html.  Montville and Chatham Mayors Ousted, New Jersey Star-Ledger, June 9, 2004.  Elise Ackerman, Election Officials Report Some E-Voting Glitches, San Jose Mercury News, March 4, 2004 at http://www.mercurynews.com/mld/mercurynews/news/special_packages/election2004/8103056.htm.  Frank Zoretich, Election Results Certified After Software Blamed, Albuquerque Tribune, November 19, 2002, at http://www.abqtrib.com/archives/news02/111902_news_vote.shtml.  Officials Still Searching For Election Glitch, St. Petersburg Times, April 6, 2002, at http://www.sptimes.com/2002/04/06/Hillsborough/Officials_still_searc.shtml  Wyatt Olson, Out of Touch: You press the screen. The machine tells you that your vote has been counted. But how can you be sure? New Times, April 24, 2003, at http://www.newtimesbpb.com/issues/2003-04-24/feature.html/1/index.html  Elise Ackerman, Electronic Votings Hidden Perils, San Jose Mercury News February 1, 2004, at http://www.mercurynews.com/mld/mercurynews/news/special_packages/election2004/7849090.htm.  Tadayoshi Kohno et. al., Analysis of an Electronic Voting System (July 23, 2003) at pg.2, http://avirubin.com/vote.pdf.  Dr. Michael A. Wertheimer et. al., Trusted Agent Report: Diebold AccuVote-TS Voting System (Jan. 20, 2004), http://www.raba.com/press/TA_Report_AccuVote.pdf.  State of California Standards for Accessible Voter Verified Paper Audit Trail Systems in Direct Recording Electronic (DRE) Voting Systems, (June 15, 2004), http://www.ss.ca.gov/elections/ks_dre_papers/avvpat_standards_6_15_04.pdf. #*+  b}WX}~%> ')=BN^y~QRz{| ######$$$$1%2%%%%%&&X& h\A6 h\Ajh\AUjh\AU h\A6jh\AUjh\AU h\A>*h\A h\ACJ h\A;CJE+~ [ n [&7( *i**+-d.u.12F5P9-a_kgngX&Y&i****P+Q+++,,--. .a.b.d.t.00Z0[00000111 2j2k222)3*3k3l35767V7W7888888889999L9M9P9c9q:r:::<c<==AA*BWBCCCCEEE7E0F1F2FWFjh\A0JU h\A5 h\A h\A6 h\ACJh\Ajh\AUSP9c9<d<==?A*BWBCCE7E2FXFhGGHHJ KL+LM3MMN0$d00dWFXFfGgGhGGHHHHJJJ KLLL*LMMM3MMMMMMNWWXXYY[[`_a_b_o____%`&`'`6`k```````aaLaMaNaOataaaaaaaabbabbbsbbbȻ h\A:h\AB*ph h\A6h\A5OJQJh\A56CJ h\ACJ h\A5jh\A0JUh\A h\A0J5JNuORTW[[^{^}^~^^^^^^^8_P_a_&``Maaab^gd\A^ ^`$`a$`0bbbbccc>c@cVcdchcccc*B*ph,X@, Emphasis6B^@B Normal (Web)dd[$\$&O!& term15FV@1F FollowedHyperlink >*B* ph6OA6 pmterms31 56ph6OQ6 pmterms21 56ph4@b4 Header  !4 @r4 Footer  !.)@. 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