226
In addition to the introduction of the Republican primary election, but the state
Australian ballot, anti-vote buying laws does not contend that any of the plaintiffs
were a major cause of the .decline of vote were involved in vote buying. See Doc.
buying. See Allen Hicken, How Do Rules No. 29 at 3.
and Institutions Encourage Vote Buying?,
Plaintiff Leon Rideout, who represents
in Elections for Sale: The Causes and
District 7 in Coos Country in the New
Consequences of Vote Buying 47,.. 57
Hampshire House of Representatives, vot(Frederic C. Schaffer ed., 2007) (explaining
ed in Lancaster, New Hampshire where he
that the strength of anti-vote buying rules
was on the ballot. Prior to casting his
“has the most direct impact on the expectmarked ballot, he took photographs of it
ed .utility of vote buying.”). In the United
States, federal law makes it a crime to buy with his phone. The ballot reflected that
votes or engage in voter coercion. See 52 he voted for himself as well as other Recandidates, Hours after he cast
U.S.C. .§ 10307(b) (voter intimidation, publican
threats, and coercion prohibited); 52 his ballot, he posted the photograph, to
U.S.G. § 10307(c) (vote, buying in certain Twittqr with the text, “# COOS7 vote in
federal elections prohibited). New; Hamp- primary 2014# nhpolitics.” Doc. No. 18-1
shire law also prohibits vote buying and at 9. He also posted the photograph to his
voter coercion.
N.H.Rev.Stat. Ann. House of Representatives Facebook page.
§ 659:40, I (“No person shall directly or In a September 11, 2014 article in the
Nashua Telegraph, Rideout explained, “I
indirectly bribe any person not to register
I think
to vote or any voter not to vote or to vote did it to make a statement....
for or against any question submitted to [RSA 659:35,1 is] unconstitutional.... It’s
voters or to vote for or against any ticket really just an overreach of the government
or candidate for any office at any elec- trying to control something that, in my
tion.”); N.H.Rev.Stat. Ann. § 659:40, II opinion, doesn’t need to be regulated.”
(“No person shall use or threaten force, David Brooks, You Didn’t Take a Picture
violence, or any tactic of coercion or intimi- of Your Ballot Tuesday, Did You? (It’s
dation to knowingly induce or compel any Illegal), Nashua Telegraph, Sept. 11, 2014,
other person to vote or refrain from vot- http://www.nashuatelegraph.com/news/
ing, vote or refrain from voting for any 1046026-469/you-didnt-take-a-picture-ofparticular candidate or ballot measure, or your.html. After Rideout posted the image,
refrain from registering to vote.”); see Paul Brodeur, an investigator from the
also N.H.Rev.Stat. Ann. § 659:37 (voter Attorney General’s Office, called him and
interference prohibited); NH.Rev.Stat.- requested an interview, which was conAnn. § 659:39 (giving liquor to voter to
ducted on September 16, 2014. The Attorinfluence
an'
election- prohibited);
ney General’s Office threatened to proseN.H.Rev.Stat. Anri. § 659:40, III (voter
cute Rideout under RSA 659:35, I, but no
suppression prohibited).
complaint was served because the plaintiffs
entered into agreements with the state to
C. The Plaintiffs
toll the statute of limitations period. Doc.
The New-Hampshire Attorney General’s
No. 18-1 at 11.
Office is currently investigating four indiThe Attorney General’s Office is also
viduals for alleged violations of RSA
659:35, I, including the three plaintiffs in investigating Andrew Langlois, who voted
this case. Doc. No. 18-1 at 9. The allega- in Berlin, New Hampshire. Because Lantioris.concerning each of the plaintiffs arise glois did not approve of his Republican
from their votes in the September 9, 2014 choices for U.S. Senate, he wrote the name