House and Senate candidates on ballot); United States v. Daugherty, 952 F.2d 969, 970 (8th Cir. 1991) (payments to vote for several local candidates); United States v. Odom, 858 F.2d 664, 665–66 (11th Cir. 1988) (payments to vote for state representative); United States v. Campbell, 845 F.2d 782, 784 (8th Cir. 1988); (payments to benefit a candidate for county judge); Garcia, 719 F.2d at 100 (food stamps to vote for candidate for county judge); Malmay, 671 F.2d at 870 (payments to vote for school board member); Carmichael, 685 F.2d at 905 (payments for sheriff). (d) Conspiracy to cause illegal voting The second clause of Section 10307(c) criminalizes conspiracies to encourage “illegal voting.” 20 The phrase “illegal voting” is not defined in the statute. On its face it encompasses unlawful conduct in connection with voting. It has potential application to those who undertake to cause others to register or vote in conscious derogation of state or federal laws. Cianciulli, 482 F.Supp. at 616 (noting that this clause would prohibit “vot[ing] illegally in an improper election district”). For example, all states require voters to be United States citizens, and most states disenfranchise people who have been convicted of certain crimes, who are mentally incompetent, or who possess other disabilities that may warrant restriction of the right to vote. This provision requires that the voters participate in the conspiracy. 21 The conspiracy provision of Section 10307(c) applies only to the statute’s “illegal voting” clause. Olinger, 759 F.2d at 1298–1300. Conspiracies arising under the other clauses of Section 10307(c) (i.e., those involving vote- buying or fraudulent registration) should be charged under the general federal conspiracy statute, 18 U.S.C. § 371. 20 Violations of this provision are felonies. False statements involving any fact that is material to registering or voting under state law may also be prosecuted under 52 U.S.C. § 20511, as will be discussed in Part D.7 of this chapter. 21 45