WISCONSIN LEGISLATIVE COUNCIL
ACT MEMO
2011 Wisconsin Act 23
[2011 Assembly Bill 7]
Changes to Election Laws
2011 Wisconsin Act 23 makes changes to election laws relating to requiring certain
identification in order to vote at a polling place or obtain an absentee ballot; absentee voting; late voter
registration; proof of residence; a requirement for electors to provide a signature when voting in person
at an election; the duration and location of residency for voting purposes; voting a straight party ticket;
issuance of operator’s licenses and identification cards by the Department of Transportation (DOT);
voter registration information; the statewide voter registration list; voter registration activities; granting
rule-making authority; and providing a penalty.
PROOF OF IDENTIFICATION
Under current law, an elector voting at a polling place or by absentee ballot is not required to
present identification other than, if applicable, proof of residence.
Act 23 requires that an elector present proof of identification to vote at a polling place or by
absentee ballot.
“Proof of Identification” Defined
Under Act 23, “proof of identification” means identification that contains the name of the
individual to whom the document was issued, which name conforms to the individual’s voter
registration form, if the individual is required to register to vote, and that contains a photograph of the
individual. “Identification” means any of the following documents issued to an individual:
•
One of the following documents that is unexpired or, if expired, has expired after the date of
the most recent general election: (1) an operator’s license issued by DOT; (2) an
identification card issued by DOT; (3) an identification card issued by a U.S. uniformed
service; or (4) a U.S. passport.
This memo provides a brief description of the Act. For more detailed information,
consult the text of the law and related legislative documents at the Legislature’s Web site at: http://www.legis.state.wi.us/.
___________________________
One East Main Street, Suite 401 • P.O. Box 2536 • Madison, WI 53701-2536
(608) 266-1304 • Fax: (608) 266-3830 • Email: leg.council@legis.state.wi.us
http://www.legis.state.wi.us/lc
-2•
A certificate of U.S. naturalization that was issued not earlier than two years before the date
of an election at which it is presented.
•
An unexpired driving receipt issued by DOT.
•
An unexpired identification card receipt issued by DOT.
•
An identification card issued by a federally recognized Indian tribe in this state.
•
An unexpired identification card issued by an accredited university or college in this state
that contains the date of issuance and signature of the individual to whom it is issued and that
contains an expiration date indicating that the card expires no later than two years after the
date of issuance, if the individual establishes that he or she is enrolled as a student at the
university or college on the date that the card is presented.
Voting at Polling Place
Act 23 requires that an elector present proof of identification when voting at a polling place. The
election official must verify that the name on the proof of identification presented by the elector
conforms to the name on the poll list or separate list and must verify that any photograph appearing on
that document reasonably resembles the elector.
Voting by Absentee Ballot
Act 23 provides that if an elector applies for an absentee ballot in person at the clerk’s office, the
clerk may not issue the elector an absentee ballot unless the elector presents proof of identification. The
clerk must verify that the name on the proof of identification presented by the elector conforms to the
name on the elector’s application and must verify that any photograph appearing on that document
reasonably resembles the elector. The clerk must then enter his or her initials on the certificate envelope
indicating that the absentee elector presented proof of identification to the clerk.
In addition, Act 23 provides that if an elector applies for an absentee ballot in a manner other
than in person at the clerk’s office, the elector must enclose a copy of his or her proof of identification or
any authorized substitute document with his or her application. The municipal clerk must verify that the
name on the proof of identification conforms to the name on the application. The clerk may not issue an
absentee ballot to an elector who is required to enclose a copy of proof of identification or an authorized
substitute document with his or her application unless the copy is enclosed and the proof is verified by
the clerk. However, if an elector applies for an absentee ballot in an electronic manner and the elector
has not enclosed a copy of his or her proof of identification with his or her application, the elector must
enclose a copy of the proof of identification with the absentee ballot.
Lastly, Act 23 provides that when an agent applies for an absentee ballot for a hospitalized
elector, the agent must present proof of identification to the clerk on behalf of the elector. The clerk
must verify that the name on the proof of identification presented by the agent conforms to the name on
the elector’s application. The clerk must then enter his or her initials on the carrier envelope indicating
that the agent presented proof of identification to the clerk.
-3Absentee Ballot Certificate
Act 23 requires that an absentee ballot envelope certificate include a space for the municipal
clerk or deputy clerk to enter his or her initials indicating that if an absentee elector voted in person, the
elector presented proof of identification to the clerk and the clerk verified the proof of identification
presented. The certificate must also include a space for the municipal clerk or deputy clerk to enter his
or her initials indicating that the elector is exempt from providing proof of identification.
Exceptions to Identification Requirement
Act 23 creates the following exceptions to the requirement that electors present proof of
identification when voting:
•
A military elector, as defined in s. 6.34 (1) (a), Stats., who votes by absentee ballot is not
required to provide a copy of proof of identification.
•
An overseas elector, as defined in s. 6.34 (1) (b), Stats., who votes by absentee ballot is not
required to provide a copy of proof of identification.
•
An elector who has a confidential listing, as a result of domestic abuse, sexual assault, or
stalking, may present his or her confidential identification card, or give his or her name and
confidential identification serial number, in lieu of presenting proof of identification.
•
An elector who receives a citation or notice of intent to revoke or suspend an operator’s
license from a law enforcement officer in any jurisdiction that is dated within 60 days of the
date of an election, and is required to surrender his or her operator’s license or driving receipt
issued to the elector at the time the citation or notice is issued, may present an original copy
of the citation or notice in lieu of an operator’s license or driving receipt, or, if voting by
mail, may enclose a copy of the citation or notice in lieu of a copy of an operator’s license or
driving receipt.
•
An absentee elector who has received an absentee ballot from the municipal clerk by mail for
a previous election and has provided a copy of proof of identification with that ballot, and
has not changed his or her name or address since providing that proof of identification, is not
required to provide a copy of proof of identification.
•
An absentee elector who is indefinitely confined because of age, physical illness, or
infirmity, or who is disabled for an indefinite period, and who has applied for and qualified to
receive absentee ballots automatically may, in lieu of providing a copy of proof of
identification, submit with his or her absentee ballot a statement signed by the same
individual who witnesses voting of the ballot that contains the name and address of the
elector and verifies that the name and address are correct.
•
An absentee elector who resides in a nursing home, qualified retirement home, qualified
community-based residential facility (CBRF), qualified residential care apartment complex,
or qualified adult family home where special voting deputies are sent may, in lieu of
providing a copy of proof of identification, submit with his or her absentee ballot a statement
signed by the special voting deputies that contains the name and address of the elector and
verifies that the name and address are correct. The deputies must enclose the statement in the
certificate envelope.
-4•
An absentee elector who resides in a qualified retirement home, qualified CBRF, residential
care apartment complex, or adult family home where special voting deputies are not sent
may, in lieu of providing a copy of proof of identification, submit with his or her absentee
ballot a statement signed by the same individual who witnesses voting of the ballot and that
contains the certification of an authorized representative of the complex, facility, or home
that the elector resides in the complex, facility, or home and the complex, facility, or home is
certified or registered as required by law, that contains the name and address of the elector,
and that verifies that the name and address are correct.
Electors Not Providing Identification
Act 23 provides that if an elector does not present proof of identification, if the name appearing
on the document presented does not conform to the name on the poll list or separate list, or if any
photograph appearing on the document does not reasonably resemble the elector, the elector may not be
permitted to vote, except that an elector who does not present proof of identification must be offered the
opportunity to vote by provisional ballot.
In addition, Act 23 provides that if an absentee elector is required to provide a copy of proof of
identification and no copy of the proof of identification is enclosed or the name on the document cannot
be verified by the election officials, the officials must treat the ballot as a provisional ballot.
Lastly, Act 23 specifies that if an elector is required to provide proof of identification or a copy
thereof and fails to do so, and the elector votes by provisional ballot, the elector bears the burden of
correcting the omission by providing the proof of identification or copy thereof at the polling place
before the closing hour or at the office of the municipal clerk or board of election commissioners no
later than 4 p.m. on the Friday after the election.
Public Information Campaign
Act 23 requires that the Government Accountability Board (GAB) conduct a public information
campaign in conjunction with the first regularly scheduled primary and election at which the voter
identification requirements of the Act initially apply for the purpose of informing prospective voters of
the new voter identification requirements. The Act also requires GAB to engage in outreach to identify
and contact groups of electors who may need assistance in obtaining or renewing a document that
constitutes proof of identification for voting and provide assistance in obtaining or renewing that
document.
Instructions
Act 23 requires that a municipal clerk or board of election commissioners post instructions
regarding the proof of identification requirement.
Operator’s Licenses and Identification Cards
Under current law, certain provisions of the federal REAL ID Act will be incorporated into state
law when DOT provides notice that it will implement the federal REAL ID Act. These provisions
include requirements that DOT follow certain procedures in processing applications for operator’s
licenses and state identification cards and that each operator’s license and identification card contain a
photograph.
-5Act 23 allows DOT, upon the implementation of the federal REAL ID Act in this state, to
process applications for operator’s licenses and identification cards that are not compliant with the
federal REAL ID Act if the licenses and cards are marked to indicate that they are not REAL ID
compliant. DOT must process the applications for REAL ID noncompliant operator’s licenses and
identification cards using DOT practices and procedures that are in effect immediately prior to
implementation of the federal REAL ID Act.
Current law allows DOT to issue an operator’s license, but not an identification card, that does
not contain a photograph of the licenseholder based on the religious beliefs of the licenseholder.
However, after implementation of the federal REAL ID Act, all REAL ID compliant operator’s licenses
and identification cards must contain a photograph.
Under Act 23, until implementation of the federal REAL ID Act, the religious belief photograph
exemption for operator’s licenses continues, and the Act creates a religious belief photograph exemption
for identification cards. After implementation of the federal REAL ID Act, the Act creates a religious
belief photograph exemption for REAL ID noncompliant operator’s licenses and identification cards.
Specifically, the exemption provides that an application for an operator’s license or identification card
may be processed, and the license or card issued or renewed, without a photograph being taken of the
applicant if the applicant provides to DOT an affidavit that states that the applicant has a sincerely held
religious belief against being photographed; identifies the religion to which the applicant belongs or the
tenets of which the applicant adheres to; and states that the tenets of the religion prohibit the applicant
from being photographed.
Lastly, Act 23 allows an elector to obtain a free identification card from DOT if the applicant is
eligible to obtain an identification card and if the elector is a U.S. citizen who will be at least 18 years of
age on the date of the next election and the elector requests that the card be provided without charge for
purposes of voting.
SIGNATURE REQUIREMENT
Current law does not require that an elector sign the poll list, supplemental list, or other separate
list when voting.
Act 23 requires that an elector enter his or her signature on the poll list, supplemental list, or
other separate list when voting in person at an election, unless exempt by reason of the elector’s physical
disability. Each registration list prepared for use as a poll list at a polling place or for purposes of
canvassing absentee ballots must contain a space for the elector’s signature, or, if another person signed
the elector’s registration form for the elector by reason of the elector’s physical disability, the word
“exempt.” GAB must, by rule, prescribe the space and location for entry of each elector’s signature on
the poll list, which must provide for entry of the signature without changing the orientation of the poll
list from the orientation used by the election officials.
In addition, Act 23 provides that if an elector previously signed his or her registration form or is
exempt from a registration requirement and is unable, due to physical disability, to enter his or her
signature at the election, the officials must waive the signature requirement if the officials determine that
the elector is unable, due to physical disability, to enter his or her signature. In such case, the officials
must enter the words “exempt by order of inspectors” next to the name and address of the elector on the
poll, supplemental, or separate list. If both officials do not waive the signature requirement and the
elector wishes to vote, the official or officials who do not waive the requirement must require the elector
to vote by ballot and must challenge the elector’s ballot. The challenged elector may then provide
-6evidence of his or her physical disability to the board of canvassers charged with initially canvassing the
returns prior to the completion of the initial canvass.
RESIDENCY
Under current law, an individual must be a resident of an election district or ward for 10 days
before an election to be eligible to vote in the election. An individual who moves within this state later
than 10 days before an election must vote at his or her previous ward or election district if the individual
is otherwise qualified.
Act 23 increases the residency requirement from 10 days before an election to 28 consecutive
days before an election. The Act also provides that an individual who moves within this state later than
28 days before an election must vote at his or her previous ward or election district if the individual is
otherwise qualified.
Current law provides that an individual who was or who is an eligible elector, except that he or
she has been a resident of this state for less than 10 days prior to the date of the presidential election, is
entitled to vote for the president and vice president but for no other offices.
Act 23 applies this provision to an individual who has been a resident of this state for less than
28 consecutive days prior to the date of the presidential election.
REGISTRATION
Corroboration
Under current law, an elector who registers to vote after the third Wednesday preceding an
election generally must provide proof of residence or, if the elector cannot provide proof of residence,
another elector of the municipality may corroborate the information contained in the elector’s
registration form.
Act 23 eliminates the use of corroboration as an alternative to providing proof of residence when
registering to vote.
Late Registration Deadline
Under current law, an elector of a municipality who has not previously filed a registration form
or whose name does not appear on the registration list of the municipality may register after the close of
registration (the third Wednesday preceding an election) but not later than 5 p.m. or the close of
business, whichever is later, on the day before an election at the office of the municipal clerk.
Act 23 provides that this provision applies until the Friday before an election, rather than the day
before an election. [The Act continues to allow an elector to register at a polling place on Election Day.]
Special Registration Deputies
Under current law, an elector of this state may apply to GAB to be appointed as a special
registration deputy for the purpose of registering electors of any municipality prior to the close of
registration. In addition, an elector of this state may apply to any municipal clerk or board of election
commissioners to be appointed as a special registration deputy for the purpose of registering electors of
-7the municipality prior to the close of registration. The municipal clerk, board of election commissioners,
or GAB may revoke an appointment made by the clerk, board of election commissioners, or GAB for
cause at any time.
Act 23 repeals the provisions regarding appointment, and revocation of appointments, of special
registration deputies by GAB. In addition, the appointment of each individual who serves as a special
registration deputy on the effective date of the Act solely as the result of action of GAB is revoked.
Registration Forms
Under current law, registration forms must be designed to obtain from each elector certain
information, including the elector’s residence location and the number of the elector’s valid operator’s
license issued by DOT.
Act 23 requires that registration forms also be designed to obtain the location of the elector’s
previous residence immediately before moving to the current residence location. Further, the Act
requires that registration forms be designed to obtain the number of an elector’s current and valid
operator’s license. The Act also requires that the form contain a statement that falsifying information on
the form is a Class I felony.
Proof of Residence for College Students
Under current law, proof of residence includes a university, college, or technical college fee or
identification card that contains a photograph of the cardholder if the card contains a current and
complete name and residential address of an individual. A card that does not contain this information is
considered proof of residence if the university, college, or technical college that issued the card provides
a certified and current list of students who reside in housing sponsored by the university, college, or
technical college to the municipal clerk prior to the election showing the current address of the students
and if the municipal clerk, special registration deputy, or inspector verifies that the student presenting
the card is included on the list.
Act 23, instead, provides that proof of residence includes either of the following documents:
•
An identification card issued by a university, college, or technical college that contains a
photograph of the cardholder, together with a fee payment receipt issued to the cardholder by
the university, college, or technical college dated no earlier than nine months before the date
of the election at which the receipt is presented.
•
An identification card issued by a university, college, or technical college that contains a
photograph of the cardholder if the university, college, or technical college that issued the
card provides a certified and current list of students who reside in housing sponsored by the
university, college, or technical college and who are U.S. citizens to the municipal clerk prior
to the election showing the current address of the students and if the municipal clerk, special
registration deputy, or inspector verifies that the student presenting the card is included on
the list.
Further, Act 23 provides that an identification card issued by a university, college, or technical
college that is used as proof of residence is not required to contain the current and complete residential
address of the cardholder.
-8Out-of-State Driver’s Licenses
Under current law, if an elector registers to vote and presents a driver’s license issued by another
state, the election official must record on a separate list the name and address of the elector, the name of
the state, and the license number and expiration date of the license. A municipal clerk must compile
and, no later than seven days after each general election, transmit to GAB the lists of electors registering
to vote who presented valid drivers’ licenses issued by other states. Further, after each general election,
GAB must contact the chief election official of each state from which an elector who voted in that
election presented a valid driver’s license. GAB must inquire whether the holder of the driver’s license
voted in that election in that state.
Act 23 repeals these provisions.
Official Registration List
Current law provides that the official registration list is open to public inspection, except that
access to certain information is restricted and may be viewed only by an employee of GAB, county
clerk, deputy county clerk, executive director of a county board of election commissioners, deputy
designated by the executive director, municipal clerk, deputy municipal clerk, executive director of a
city board of election commissioners, or deputy designated by the executive director.
Act 23 provides that GAB or any municipal clerk or board of election commissioners may
transfer any information in the registration list to which access is restricted to a law enforcement agency,
to be used for law enforcement purposes. Further, the Act provides that GAB may transfer any
information in the registration list to which access is restricted to a subunit of the state government of
another state to be used for official purposes.
Under current law, a municipal clerk may update any entries in the registration list that change
on the date of an election in the municipality within 30 days after that date.
Act 23 provides that the municipal clerk may update any entries in the registration list that
change on the date of an election, other than a general election, within 30 days after the date of that
election and may update any entries that change on the date of a general election within 45 days after the
date of that election. In addition, the Act provides that GAB legal counsel may, upon request of a
municipal clerk, permit the clerk to update entries that change on the date of a general election within 60
days after that election.
ABSENTEE VOTING
Absentee Ballot Application
Under current law, if an elector makes an application for an absentee ballot in person, the
application must be made no later than 5 p.m. on the day preceding the election.
Act 23 provides that the application must be made no earlier than the opening of business on the
third Monday preceding the election and no later than 5 p.m. or the close of business, whichever is later,
on the Friday preceding the election.
In addition, current law provides that any registered elector who is hospitalized may apply for
and obtain an absentee ballot by agent. The agent may apply for and obtain a ballot for the hospitalized
-9elector by presenting a form prescribed by GAB and containing the required information supplied by the
hospitalized elector and signed by that elector.
Act 23 provides that if a hospitalized elector is unable to sign the GAB form due to physical
disability, the elector may authorize another elector to sign on his or her behalf. Any elector signing an
application on another elector’s behalf must attest to a statement that the application is made on request
and by authorization of the named elector, who is unable to sign the application due to physical
disability. The agent must present this statement along with all other information required under current
law.
Electronic Transmission
Under current law, a municipal clerk may, if the clerk is reliably informed by an absent elector
of a facsimile transmission number or electronic mail address where the elector can receive an absentee
ballot, transmit a facsimile or electronic copy of the absent elector’s ballot to that elector in lieu of
mailing if, in the judgment of the clerk, the time required to send the ballot through the mail may not be
sufficient to enable return of the ballot by the return deadline.
Act 23 provides that a municipal clerk must, if the clerk is reliably informed by an absent elector
of a facsimile transmission number or electronic mail address where the elector can receive an absentee
ballot, transmit a facsimile or electronic copy of the absent elector’s ballot to that elector in lieu of
mailing.
Automatic Absentee Ballots
Current law provides that an elector may, by written application, require that an absentee ballot
be sent to the elector automatically for every election that is held within the same calendar year in which
the application is filed.
Act 23 provides that the municipal clerk must discontinue mailing or transmitting absentee
ballots to an elector if the elector fails to return any absentee ballot mailed or transmitted to the elector.
In addition, an elector who fails to cast an absentee ballot but who remains qualified to receive absentee
ballots may receive absentee ballots for subsequent elections by notifying the municipal clerk that the
elector wishes to continue receiving absentee ballots for subsequent elections.
Uniform Instructions
Current law requires that GAB prescribe uniform instructions to absentee voters. The
instructions must include information concerning the procedure for correcting errors in marking a ballot
and obtaining a replacement for a spoiled ballot.
Act 23 also requires that the instructions include information concerning whether proof of
identification is required to be presented or enclosed.
RESIDENTIAL CARE APARTMENT COMPLEXES AND ADULT FAMILY HOMES
Current law contains procedures that may be adopted for absentee voting by occupants of
nursing homes, qualified CBRFs, and qualified retirement homes and includes procedures relating to the
appointment of special voting deputies to visit the home or facility to supervise absentee voting by
occupants of the home or facility.
- 10 Act 23 also applies the procedures to absentee voting by occupants of qualified residential care
apartment complexes and qualified adult family homes. Specifically, the Act provides that the
municipal clerk or board of election commissioners of any municipality where a residential care
apartment complex or adult family home is located may adopt the procedures for absentee voting in any
such complex or home located in the municipality if the clerk or board finds that there are a significant
number of the occupants of the complex or home who lack adequate transportation to the appropriate
polling place, who may need assistance in voting, who are aged 60 or over, or who are indefinitely
confined.
Under current law, no person may engage in electioneering within 100 feet of an entrance to or
within a nursing home, qualified CBRF, or qualified retirement home while special voting deputies are
present at the home or facility. In addition, current law provides that no election official may obtain an
absentee ballot for voting in a nursing home, qualified CBRF, or qualified retirement home and fail to
return the ballot to the issuing officer.
Act 23 also applies the prohibition against electioneering to qualified residential care apartment
complexes and qualified adult family homes and applies the prohibition against failing to return a ballot
to voting in qualified residential care apartment complexes and qualified adult family homes.
STRAIGHT PARTY TICKET
Under current law, at a general election, an elector may vote a straight party ticket, which allows
an elector to vote for all candidates nominated by one political party.
Act 23 eliminates the authority for any elector, other than an overseas or military elector, to vote
a straight party ticket. Under federal law, an overseas or military elector may vote a straight party ticket
on a write-in absentee ballot for national offices.
CHALLENGING VOTERS
Under current law, each inspector must challenge for cause any person offering to vote whom
the inspector knows or suspects is not a qualified elector.
Act 23 also requires that an inspector challenge for cause any person offering to vote who does
not adhere to any voting requirement under ch. 6, Stats.
ELECTION MATERIAL
Current law provides that poll lists created at a nonpartisan primary or election may be
destroyed two years after the primary or election at which they were created and poll lists created at a
partisan primary or election may be destroyed four years after the primary or election at which they were
created.
Act 23 provides that poll lists created for any election may be destroyed 22 months after the
election at which they were created.
- 11 -
INITIAL APPLICABILITY
Durational Residency
Act 23 provides that the 28 consecutive day residency requirement first applies to elections
occurring on the effective date of the Act.
Signature Requirement
Act 23 provides that the requirement that an elector sign a poll list first applies to elections
occurring on the effective date of the Act.
Absentee Ballot Applications
Act 23 provides that in-person applications for absentee ballots must be made no earlier than the
opening of business on the third Monday preceding the election and no later than 5 p.m. or the close of
business, whichever is later, on the Friday preceding the election. This time period first applies to
requests for absentee ballots made for voting in elections held on the effective date of the Act.
Voter Registration Forms
Act 23 provides that the additional information required on registration forms first applies with
respect to registration of electors on the effective date of the Act.
Late Registration Deadline
Act 23 provides that a qualified elector of a municipality who has not previously filed a
registration form or whose name does not appear on the registration list of the municipality may register
after the close of registration but no later than 5 p.m. or the close of business, whichever is later, on the
Friday before an election. This deadline first applies with respect to late registration for elections held
on the effective date of the Act.
Proof of Residence for College Students
Act 23 provides that proof of residence includes a university, college, or technical college
identification card presented as proof of residence, together with a fee payment receipt dated no earlier
than nine months before the date of the election, or includes an identification card if the university,
college, or technical college provides a certified and current list of students who reside in housing
sponsored by the university, college, or technical college and who are U.S. citizens prior to the election
and the student is included on the list. These proof of residence provisions first apply with respect to
elections held on the effective date of the Act.
Straight Party Ticket
Act 23 provides that the elimination of straight party ticket voting first applies with respect to
voting at the 2012 General Election.
- 12 Proof of Identification
Act 23 provides that no elector who votes by absentee ballot at an election held prior to the 2012
Spring Primary is required to provide proof of identification. Further, an elector who votes at a polling
place at an election held prior to the date of the 2012 Spring Primary must be requested by the election
officials to present proof of identification. However, if the elector does not present proof of
identification, and the elector is otherwise qualified, the elector’s ballot must be counted without the
necessity of presenting proof of identification and without the necessity of casting a provisional ballot.
If any elector who votes at a polling place at an election held prior to the 2012 Spring Primary
does not provide proof of identification and would be required to provide proof of identification but for
this provision, the election official who provides that elector with a ballot must also provide to the
elector written information prescribed by GAB. The GAB information must briefly describe the voter
identification requirement created by the Act and inform the elector that he or she will be required to
comply with that requirement when voting at future elections beginning with the 2012 Spring Primary
unless an exemption applies.
Effective date: The Act generally takes effect on June 10, 2011, except for provisions relating to
voting identification assistance and REAL ID.
Prepared by:
JKR:KBO:jal:ksm
Jessica Karls-Ruplinger, Senior Staff Attorney; and
Katie Bender-Olson, Staff Attorney
June 6, 2011