States” – including the right to vote. The statute, which is discussed in detail above, has potential application in two forms of voter intimidation: a conspiracy to prevent persons whom the subjects knew were qualified voters from entering or getting to the polls to vote in an election when a federal candidate is on the ballot, and a conspiracy to misuse state authority to prevent qualified voters from voting for any candidate in any election. Section 241 has been successfully used to prosecute intimidation in connection with political activities. Wilkins v. United States, 376 F.2d 552 (5th Cir. 1967) (en banc). Wilkins involved both violence and clear racial animus, and arose out of the shooting of a participant in the 1965 Selma-to-Montgomery voting rights march. Id. at 557–59. The marchers had intended to present the Governor of Alabama with a petition for redress of grievances, including denial of their right to vote. Id. at 555. The Fifth Circuit held that those marching to protest denial of their voting rights were exercising “an attribute of national citizenship, guaranteed by the United States,” and that shooting one of the marchers therefore violated Section 241. Id. at 561. Section 242 makes it a misdemeanor for any person to act “under color of any law, statute, ordinance, regulation, or custom,” to willfully deprive any person in a state, territory, or district of a right guaranteed by the Constitution or federal law. For all practical purposes, this statute embodies the substantive offense for a Section 241 conspiracy, and it therefore can apply to voter intimidation. It is the Criminal Division’s position that Sections 241 and 242 may be used to prosecute schemes to intimidate voters in federal elections through threats of physical or economic duress, or to prevent otherwise lawfully qualified voters from getting to the polls in elections when a federal candidate is on the ballot. Examples of the latter include intentionally jamming telephone lines to disrupt a political party’s get-out-the-vote or ride-to-the-polls efforts, and schemes to vandalize motor vehicles that a political faction or party intended to use to get voters to the polls. 54