225 For the most part, the Australian ballot “printed and distributed at public expense”; (2) ballots contain the names of all is credited with delivering “a blow against nominated candidates; (3) ballots are dis- clientelism,” Stokes, supra, at 241, and tributed “only by ... election officers at ending “direct bribery and intimidation.” the polling place”; and (4) “detailed provi- Fredman, supra, at 129; see Burson, 504 sions” are made for physical arrangements U.S. at 204, 112 S.Ct. 1846' (“The success to ensure secrecy when casting a vote. Id. achieved through thesé reforms was immeat 46. In 1888, Louisville, Kentucky be- diately ' noticed and widely praised.”). came the first American city to adopt the Nevertheless, although thé Australian balAustralian ballot, and in November 1889, lot drastically reduced incentives to resort Massachusetts was the first to use it state- to vote buying, it did not eradicate the wide. Id. at 31, 36-39; Lepore, supra. phenomenon entirely. For example, in New Hampshire has used the Australian Adams County, Ohio, vote buying was able ballot since 1891. Legislative History at to persist due to the “relative smallness” of 000062. the area. See Fabrice Lehoucq, When drastically Does a Market for Votes Emerge?, in The Australian ballot changed the utility of bribing voters be- Elections for Sale: The Causes and Consecause party workers could no longer moni- quences of Vote Buying 33, 38 (Frederic C. tor how voters voted. See Fredman, su- Schaffer ed., 2007). There, in 1910, the pra, at 47. Professor L.E. Fredman used “price of a vote oscillated between a drink the differences between the 1888 and 1892 of whisky and US$25, with the average presidential elections to highlight the ef- price being US$8 per vote....” Id. (citing fect. See id. at 83. Both elections fea- Genevieve B. Gist, Progressive Reform in tured Republican Benjamin Harrison a Rural Community: The Adams County against Democrat Grover Cleveland, but in Vote-Fraud Case, 48 Miss. Valley Historithe interim, 38 states had adopted the cal Rev. 60, 62-63 (1961), http://www.jstor. Australian ballot. Id. In 1888, the treasurorg/stable/1902404). Similarly, due to ruer of the Republican National Committee ral populations with high poverty rates, instructed local officials: “Divide the floa- “vote buying remained endemic well into ters in blocks of five, .and put a trusted the twentieth century” in many southern man, with necessary funds, in charge of states.' Stokes, supra, at 229. these five, and make them responsible that Although “isolated. and anachronistic,” none get away.” Id. at 22. Although the continue to be some reports of vote there memorandum exposed the extent of brib■in the twenty-first century. buying election, ery during that Benjamin Harrison was elected. In the 1892 election, by Stokes, supra, at 231. For example, there contrast, “[tjhere seemed to be more factu- have been recent prosecutions for violaal argument and fewer noisy processions, tions of federal vote-buying statutes in and the day itself was generally quiet and Kentucky, North Carolina, and Illinois. orderly.” Id. at 83; see also Stokes, su- See United States v. Thomas, 510 F.3d pra, at 228 (“Historians also note the ris- 714, 717 (7th Cir.2007); United States v. ing importance of party platforms in the Shatley, 448 F.3d 264, 265 (4th Cir.2006); United States v. Johnson, No. 5:11-cr-143, late nineteenth century, another sign that 2012 WL 3610254, at *1 (E.D.Ky. Aug. 21, vote buying was yielding to electoral strat2012); Stokes, supra, at 231. None of egies that, in [Theodore] Hoppen’s phrase, cases, however, involved the use of a ‘depended upon words.’”) (quoting Theo- these dore K. Hoppen, The Mid-Victorian Gen- digital or photographic image of a marked eration: me-1886 (2000)). ballot.