20511(2)), and persons who are not United States citizens (currently all states) (52 U.S.C. §§ 10307(c), 20511(2); 18 U.S.C. §§ 1015(f), 611). • Knowingly making a false claim of United States citizenship to register to vote or to vote in any election (18 U.S.C. § 1015(f)), or falsely and willfully claiming U.S. citizenship for, inter alia, registering or voting in any election (18 U.S.C. § 911). • Providing false information concerning a person’s name, address, or period of residence in a voting district to establish that person’s eligibility to register or to vote in a federal election (52 U.S.C. §§ 10307(c), 20511(2)). • Causing the production of voter registrations that qualify alleged voters to vote for federal candidates, or the production of ballots in federal elections, that the actor knows are materially defective under applicable state law (52 U.S.C. § 20511(2)). • Using the mails or interstate wire facilities to obtain the salary and emoluments of an elected official through any of the activities mentioned above (18 U.S.C. §§ 1341, 1343). Depending on the Circuit, this “salary theory” of mail and wire fraud has potential as a prosecutive theory that would extend federal criminal jurisdiction to election fraud schemes, including those that occurred in non-federal elections. 10 10 Compare United States v. Ratcliff, 488 F.3d 639, 647 (5th Cir. 2007) (candidate lied to election ethics board about illegal campaign loans), United States v. Turner, 459 F.3d 775, 784–90 (6th Cir. 2006) (defendant fraudulently concealed illegal contributions and bribed voters to vote for candidate), Westchester Cnty. Indep. Party v. Astorino, No. 13–CV–7737(KMK), 2015 WL 5883718, at *11–12 (S.D.N.Y. Oct. 8, 2015) (holding that “a person who has committed election fraud in order to obtain the normal salary given to the person holding that elected office has not committed money or property fraud, because the victim the government – has not 25