include any effort to derogate any right that flows from the Constitution
or from federal law.
Section 241 has been an important statutory tool in election
crime prosecutions. Originally held to apply only to schemes to
corrupt elections for federal office, it has been successfully applied to
non-federal elections as well, provided that state action was a necessary
feature of the fraud. This state action requirement can be met not only
by the participation of poll officials and notaries public, but by
activities of persons who clothe themselves with the appearance of
state authority, e.g., with uniforms, credentials, and badges. Williams
v. United States, 341 U.S. 97 (1951).
Section 241 embraces conspiracies to:
• stuff a ballot box with forged ballots, United States v.
Saylor, 322 U.S. 385 (1944); United States v. Mosley, 238
U.S. 383 (1915);
• prevent the official count of ballots in primary elections,
United States v. Classic, 313 U.S. 299 (1941);
• destroy voter registration applications, United States v.
Haynes, Nos. 91-5979, 91-6076, 1992 WL 296782, at *1
(6th Cir. Oct. 15, 1992);
• destroy ballots, United States v. Townsley, 843 F.2d 1070,
1073–75 (8th Cir. 1988);
• exploit the infirmities of elderly or handicapped people by
casting absentee ballots in their names, United States v.
Morado, 454 F.2d 167, 171 (5th Cir. 1972);
34