(a) The basis for federal jurisdiction 16 Congress added Section 10307(c) (originally codified as 42 U.S.C. § 1973i(c)) to the 1965 Voting Rights Act to ensure the integrity of the balloting process in the context of an expanded franchise. In so doing, Congress intended that Section 10307(c) have a broad reach. In fact, the original version of Section 10307(c) would have applied to all elections. However, constitutional concerns were raised during congressional debate on the bill, and the provision’s scope was narrowed to elections that included a federal contest. Section 10307(c) rests on Congress’s power to regulate federal elections and on the Necessary and Proper Clause. U.S. C ONST . art. I, § 4; art. I, § 8, cl. 18; United States v. Slone, 411 F.3d 643, 648– 49 (6th Cir. 2005). Section 10307(c) has been held to protect two distinct aspects of a federal election: the actual results of the election, and the integrity of the process of electing federal officials. United States v. Cole, 41 F.3d 303, 307 (7th Cir. 1994). In Cole, the Seventh Circuit held that federal jurisdiction is satisfied so long as a single federal candidate is on the ballot – even if the federal candidate is unopposed – because fraud in a mixed election automatically has an impact on the integrity of the federal election process. See also Slone, 411 F.3d at 648–49; McCranie, 169 F.3d at 727 (jurisdiction under Section 10307(c) satisfied by the name of unopposed federal candidate on ballot); United States v. Douglas, No. 309-014, 2010 WL 737330, at *4 (S.D. Ga. Mar. 2, 2010). Section 10307(c) is particularly useful for two reasons: (1) it eliminates the unresolved issue of the scope of the constitutional right to vote in matters not involving racial discrimination, and (2) it eliminates the need to prove that a given pattern of corrupt conduct had an actual impact on a federal election. It is sufficient under The discussion here concerning federal jurisdiction under Section 10307(c) applies equally to its companion statute, 52 U.S.C. § 10307(e), which addresses multiple-voting with a federal jurisdictional predicate phrased precisely the same way. 16 39