4. Voting More than Once: 52 U.S.C. § 10307(e) Section 10307(e), enacted as part of the 1975 amendments to the Voting Rights Act of 1965, makes it a crime to vote “more than once” in any election in which a federal candidate is on the ballot. Violations are punishable by imprisonment for up to five years. The federal jurisdictional basis for this statute is identical to that for 52 U.S.C. § 10307(c), which is discussed in detail above. Section 10307(e) is most useful as a statutory weapon against frauds that do not involve the participation of voters in the balloting acts attributed to them. Examples of such frauds are schemes to cast ballots in the names of voters who were deceased or absent, Olinger, 759 F.2d at 1297; schemes to exploit the infirmities of the mentally handicapped by casting ballots in their names, United States v. Odom, 736 F.2d 1 0 4 , 106 (4th Cir. 1984); and schemes to cast absentee ballots in the names of voters who did not participate in and consent to the marking of their ballots, Smith, 231 F.3d at 804–05. Most cases prosecuted under the multiple-voting statute have involved defendants who physically marked ballots outside the presence of the voters in whose names they were cast – in other words, without the voters’ participation or knowledge. The statute may also be applied successfully to schemes when the voters are present but do not participate in any way, or otherwise consent to the defendant’s assistance, in the voting process. However, when the scheme involves “assisting” voters who are present and who also marginally participate in the process, such as by signing a ballot document, prosecuting the case under Section 10307(e) might present difficulties. For instance, in United States v. Salisbury, 983 F.2d 1369, 1372 (6th Cir. 1993), the defendant got voters to sign their absentee ballot forms, and then instructed them how to mark their ballots, generally without allowing them to choose the candidates – and even in some cases without disclosing the identity of 46