F.3d 1162, 1165 (6th Cir. 1995) (stating in dicta that Section 241 requires an overt act). Section 241 reaches conduct affecting the integrity of the federal election process as a whole, and does not require fraudulent action with respect to any particular voter. United States v. Nathan, 238 F.2d 401, 407 (7th Cir. 1956). On the other hand, Section 241 does not reach schemes to corrupt the balloting process through voter bribery, United States v. Bathgate, 246 U.S. 220 (1918), even schemes that involve poll officers to ensure that the bribed voters mark their ballots as they were paid to do, United States v. McLean, 808 F.2d 1044, 1048–49 (4th Cir. 1987) (noting, however, that Section 241 may apply when vote-buying occurs in conjunction with other corrupt practices, such as ballot-box stuffing). Section 241 prohibits only conspiracies to interfere with rights flowing directly from the Constitution or federal statutes. This element has led to considerable judicial speculation over the extent to which the Constitution protects the right to vote for candidates running for non-federal offices. Oregon v. Mitchell, 400 U.S. 112 (1970); Reynolds v. Sims, 377 U.S. 533 (1964); Blitz v. United States, 153 U.S. 308 (1894); In re Coy, 127 U.S. 731 (1888); Ex parte Siebold, 100 U.S. 371 (1880); see also Duncan v. Poythress, 657 F.2d 691, 699–706 (5th Cir. 1981). While dicta in Reynolds casts the parameters of the federally protected right to vote in extremely broad terms, in a ballot fraud case ten years later, the Supreme Court specifically refused to decide whether the federally secured franchise extended to non-federal contests. Anderson v. United States, 417 U.S. 211 (1974). The use of Section 241 in election fraud cases generally falls into two types: “public schemes” and “private schemes.” A public scheme is one that involves the necessary participation of a public official acting under the color of law. In election fraud cases, this public official is usually an election officer using his office to dilute valid ballots with invalid ballots, or to otherwise corrupt an honest vote tally in derogation of the Equal Protection and Due Process 36