“because an absentee voter must first apply for an absentee ballot as a ‘prerequisite to voting.”’ Id. at 589 (quoting t h e d e f i n i t i o n o f “ v o t e ” i n 52 U.S.C. § 10310(c)(1)). The court also held that by using the names of real registered voters on the applications, the defendants “[gave] false information as to [their] name[s]” within the meaning of Section 10307(c). 18 Id. Finally, the court held that one of the defendants, whose role was limited to completing absentee ballot applications for ballots that others used to fraudulently vote, was liable under 18 U.S.C. § 2 as an aider and abettor. Id. at 589–90. Subsequently, in United States v. Smith, the Eleventh Circuit held that each forgery of a voter’s name on a ballot document or on an application for a ballot constituted a separate offense under the “false information as to name” clause of Section 10307(c). 231 F.3d 800, 815 (11th Cir. 2000). Section 10307(c)’s false information clause is particularly useful when the evidence shows that a voter’s signature (name) was forged on an election-related document, for example: (1) when signatures on poll lists are forged by election officials who are stuffing a ballot box, (2) when a voter’s signature on an application for an absentee ballot is forged, or (3) when bogus voter registration documents are fabricated in order to get names on voter registries. Some, but not all, states permit a practice commonly known as “bounty-hunting,” that is, paying people to collect voter registrations on a per-registration basis. Where it is allowed, it is not unusual to find that this method of remuneration provides a motive for the unscrupulous to forge voter registrations and to enhance the piecework payments they can receive. While this situation usually does not result in fraudulent votes actually being cast, it does cause voter registration offices to become overloaded with the task of processing large numbers of bogus registrations immediately prior to an The Eighth Circuit observed that “[b]ecause only registered voters are eligible to apply for and vote absentee ballots, the use of real registered voters’ names was essential to the scheme to obtain and fraudulently vote absentee ballots . . . .” Id. 18 42

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