• Ordering, keeping, or having under one’s authority or control any troops or armed persons at any polling place in any election, federal or non-federal. The actor must be an active civilian or military officer or employee of the United States Government (18 U.S.C. § 592). 3. Conduct that Does Not Constitute Federal Election Fraud Various types of conduct that may adversely affect the election of a federal candidate may not constitute a federal election crime, despite what in many instances might be their reprehensible character. For example, a federal election crime does not normally involve irregularities relating to: (1) distributing inaccurate campaign literature, (2) campaigning too close to the polls, (3) engaging in activities to influence an opponent’s withdrawal from an election, or (4) failing to comply with state-mandated voting procedures through the negligence of election officials. Also, “facilitation benefits,” e.g., things of value given to voters to make it easier for them to cast a ballot that are not intended to stimulate or reward the voting act itself, such as a ride to the polls or a stamp to mail an absentee ballot, do not ordinarily involve federal crimes. been deprived either of any money or property or the choice in how to spend the money”), and United States v. George, No. 86–CR–123, 1987 WL 48848, at *2 (W.D. Ky. Oct. 20, 1987) (similar), with United States v. Schermerhorn, 713 F. Supp. 88, 92 (S.D.N.Y. 1989) (scheme to conceal that state senate candidate was being financed by organized crime in violation of state campaign financing laws held actionable under the salary theory), United States v. Webb, 689 F. Supp. 703 (W.D. Ky. 1988) (scheme to fraudulently elect sheriff by procuring false absentee ballots held actionable under the salary theory), and United States v. Ingber, Cr. No. 86-1402 (2d Cir. Feb. 4, 1987) (unpublished), quoted in Ingber v. Enzor, 664 F. Supp. 814, 815– 16 (S.D.N.Y. 1987) (habeas opinion). 26