Another Update on States’ Consents to Refugees Resettlement 

President Trump on September 24, 2019, issued Executive Order 13888, entitled “Enhancing State and Local Involvement in Refugee Resettlement” that required state and local governments to submit to the Department of State written consents for resettlement of refugees as a precondition for such resettlements.[1]

The deadline for providing those consents, however, has been confusing in the primary and secondary sources. But it now appears that the key date is January 21, 2020, which is the deadline for local refugee resettlement agencies to submit applications for funding of those efforts by the State Department’s Bureau of Population Refugees and Migrations (PRM) and that such funding applicants must submit to PRM such “consent letters from state and local officials on a rolling basis both before and after submission of their proposals.”  (Emphasis added.)  Thus, there is no explicit deadline for submitting the consents.[2]

List of Consenting State & Local Governments

PRM now is publishing on its website a list of state and local governments that have submitted letters of consent, copies of most of which are hyperlinked to the list.[3] However, there is no “as of” date for the PRM’s list which will be updated from time to time. In any event, here is the latest PRM list consolidated with lists from other sources identifying 34 states (15 Republican governors and 19 Democrat Governors)  that have consented.[4]

State PRM Other




PRM Other


Arizona (Rep. Gov.)   X    X Phoenix (City), Tucson (City)

Maricopa (County), Pima (County)

Arkansas (Rep. Gov.)    X
Colorado (Dem. Gov.)   X
Connecticut (Dem. Gov.)   X    X New Haven (City)   X
Delaware (Dem. Gov.)   X    X
Illinois (Dem. Gov.)   X    X DuPage County, Chicago (City)   X     X
Indiana (Rep. Gov.)    X
Iowa (Rep. Gov.)   X
Kansas (Dem. Gov.)   X     X
Louisiana (Dem. Gov.)     X
Maine (Dem. Gov.)   X
Massachusetts (Rep. Gov.)   X     X Easthampton (City)   X
Holyoke (City)   X
Northampton (City)   X
Salem (City)   X
West Springfield (City)   X
Michigan (Dem. Gov.)   X     X
Minnesota (Dem. Gov.)   X     X Minneapolis (City)    X
Montana (Dem. Gov.)   X     X
Nebraska (Rep. Gov.)     X
New Hampshire (Rep. Gov.)   X
New Jersey (Dem. Gov.)   X    X
New Mexico (Dem. Gov.)   X    X
North Carolina (Dem. Gov.)   X    X Durham County    X
North Dakota (Rep. Gov.)   X     X Burleigh County    X
Ohio (Rep. Gov.)     X
Oklahoma (Rep. Gov.)
Oregon (Dem. Giov.)   X    X
Pennsylvania (Dem. Gov.)   X     X
Rhode Island (Dem. Gov.)   X
South Dakota (Rep. Gov.)    X
Tennessee (Rep. Gov.)    X
Texas (Rep. Gov.)   X[i] Bexar County   X
Utah (Rep. Gov.)   X    X
Vermont (Rep. Gov.)    X
Virginia (Dem. Gov.)   X    X Alexandria (City)   X
Richmond (City)   X
Roanoke (City)   X
Washington (Dem. Gov.)   X    X
West Virginia (Rep. Gov.)    X
Wisconsin (Dem. Gov.)    X

Finally no state so far has affirmatively rejected such resettlements although there is no requirement to do so. Rejection is implicit if there is no affirmative consent.


Many of the current letters of consent contain inspiring words about welcoming refugees that will be discussed in a subsequent post while another post will cover religious justifications for welcoming refugees.

Now we wait to learn what the other 16 states (11 Republican (Alabama, Alaska, Florida, Georgia, Idaho, Maryland, Mississippi, Missouri, South Carolina, Texas and Wyoming) and 5 Democrat (California, Hawaii, Kentucky, Nevada and New York ) will do.

It should be noted, however, that the official website of New York’s Democrat Governor Andrew Cuomo on September 17, issued a statement criticizing the Trump Administration’s new lower cap on refugee admissions and saying, “We believe that our diversity is our greatest strength, and we are proud to be home to refugees across the state who are breathing new life into their communities as members of the family of New York. While President Trump undermines the values that built this state and this nation, New York will always welcome immigrants and refugees with open arms.”[6]


[1]  See these posts to U.S. Sets 18,000 Quota for New Refugee Admissions to U.S. for Fiscal 2020 (Nov. 4, 2019; U.S. Senators Oppose U.S.Reduction in Refugee Admissions for Fiscal 2020 (Nov. 11, 2019);Latest U.S. Struggle Over Refugees (Dec. 11, 2019); Minnesota and Minneapolis Say “Yes” to Refugees (Dec. 14, 2019); Updates on States’ Consents to Refugee Resettlement (Dec. 16, 2019);  Tennessee Consents to Refugees Resettlement (Dec. 20, 2019).

[2] State Dep’t, Bureau of Population, Refugees, and Migration (PRM), FY 2020 Notice of Funding Opportunity for Reception and Placement Program, Funding Opportunity Number: SFOP0006252 (Nov. 6, 2019) FY2020 R&P FINAL NOFO.

[3]  State Dep’t, State and Local Consents Under Executive Order 13888.

[4] See prior posts listed in footnote 1. See also Assoc. Press, Oklahoma governor give consent for refugee resettlement, (Dec. 22, 2019); Assoc. Press, GOP Governors Grapple With Whether to Accept Refugees or Not, N.Y. Times (Dec. 23, 2019); Assoc. Press, 15 GOP Govs Request Refugee Resettlement in Their States, NEWSMAX (Dec. 26, 2019); CBSChicago, Mayor Lightfoot Issues Letter To U.S. State Department Authorizing Refugee Resettlement in Chicago (Dec. 24, 2019); Assoc. Press, John Bel Edwards to Trump: Louisiana will keep taking refugees, Advocate (Dec. 23, 2019); Carson, Evers says Wisconsin is open to refugee resettlement in response to presidential order requiring states, counties to consent, Milwaukee Sentinel (Dec. 18, 2019); Stoddard, Gov. Pete Ricketts says he’ll consent to refugees continuing to resettle in Nebraska, Omaha-World Herald (Dec. 19, 2019).

[5] It appears that Texas is on the PRM list only because Bexar County has submitted a consent. On December 26, 2019, a Texas newspaper reported that Texas Governor Greg Abbott has not submitted such a consent letter and that his spokesman “did not return multiple calls, texts, and emails seeking comment.” On the other hand, “Mayors and county leaders of all Texas’ biggest cities —including Houston, San Antonio, Dallas and Austin — sent letters opting in,” but those consents are effective only if the state consents.  (Kriel, Trump give states power to admit refugees. As other GOP governors sign on, Abbott is silent, Houston Chronicle (Dec. 26, 2019).)

[6]  Statement from Governor Andrew M. Cuomo on the Trump Administration’s New Refugee Cap (Sept. 17, 2019).





The Antiquated Constitutional Structure of the U.S. Senate 

This year’s U.S. election re-emphasizes, for this blogger, the antiquated nature of the U.S. Constitution, especially the U.S. Senate.

Alec MacGillis, a government and politics reporter for ProPublica and the author of “The Cynic: The Political Education of Mitch McConnell,” points out that Democratic voters are increasingly concentrated in certain cities and urban areas while the Constitution allocates two Senate seats to each state regardless of population. The juxtaposition of these phenomena “helps explain why the Democrats are perpetually struggling to hold a majority. The Democrats have long been at a disadvantage in the Senate, where the populous, urbanized states where Democrats prevail get the same two seats as the rural states where Republicans are stronger. The 20 states where Republicans hold both Senate seats have, on average, 5.2 million people each; the 16 states where the Democrats hold both seats average 7.9 million people. Put another way, winning Senate elections in states with a total of 126 million people has netted the Democrats eight fewer seats than the Republicans get from winning states with 104 million people.”[1]

Nevertheless, Democrats are seeing signs that they may gain control of the Senate this election.

However, Chris Cillizza, a Washington Post columnist, points out that this control may last only two years. The reason? In the next election in 2018, 25 of the 33 Senate seats up for election are currently held by Democrats, and five of these Democratic seats are in states that then-Republican presidential nominee Mitt Romney carried in 2012 (and even Trump is likely to carry on this year’s election): Indiana, Missouri, Montana, North Dakota and West Virginia. Three other Democratic seats are far from “safe” seats:  Sen. Bill Nelson (Florida) Sen. Sherrod Brown (Ohio) and Sen. Tammy Baldwin (Wisconsin). The Republican seats up for election in 2018, on the other hand, look like difficult challenges for the Democrats.[2]

These consequences of the current constitutional structure of the U.S. Senate suggest, as argued in a prior post, “that the U.S. Senate in particular needs radical reform if we are to retain a bicameral national legislature. To require 60% of the Senators to agree in order to do almost anything [due to the filibuster rule,] for me, is outrageous. It should only be 51% for most issues. This deficiency is exacerbated by the fact that each state has two and only two Senators regardless of the state’s population. Yes, this was part of the original grand and anti-democratic compromise in the late 18th century when there were 13 states. But the expansion of the union to 50 states has made the Senate even more anti-democratic.” [3]

Since “I believe that it would not be wise to increase the size of the Senate to reflect the population of the states (like the allocation of seats in the U.S. House of Representatives) and that each state should continue to have two Senators in a bicameral upper house, I suggest for discussion that there be weighted voting in the Senate. Each Senator from Wyoming (the least populous state in 2010 with 564,000) would have 1 vote, for example, but each Senator from California (the most populous state in 2010 with 37,254,000) would have 66 votes (37254/564 = 66.05). This approach would produce a total Senate vote of 1,094 (total U.S. population in 2010 of 308,746,000 divided by 564,000 (population of Wyoming) = 547 x 2 = 1094). The weightings would be changed every 10 years with the new census population figures.”

Such changes would aid the U.S. government in addressing the many problems facing the nation, instead of the continuation of the gridlock that has helped to prevent progress on these many problems.


[1] MacGillis, Go Midwest, Young Hipster, N.Y. Times (Oct. 22, 2016).

[2] Cillizza, Even if Democrats Win the Senate in 2016, their majority is unlikely to endure, Wash. Post (Oct. 23, 2016).

[3] The Antiquated U.S. Constitution, (Mar. 28, 2012).

Book Group Tackles Norman Maclean’s “A River Runs Through It”

Bill Linder-Scholer [1]


Norman Maclean
Norman Maclean

For its monthly book read for November 2015, the Men’s Book Group of Westminster Presbyterian Church of Minneapolis chose Norman Maclean’s short novel, “A River Runs Through It.” By the end of our 90-minute discussion about the novel, most of our members were convinced that Maclean’s novella is much more than a story about three men who like to fly fish the rough rivers of western Montana. We cast our questions widely to open up the deeper pools of the story’s meanings by looking to the text, to the facts of Maclean’s life, and to the images of water and the Biblical Word for guidance. We shared thoughts about the author’s direct use of Presbyterian theology to structure his plot and meaning. And in the final analysis, we acknowledged that although the novel ends with a haunting tragedy, it also leaves us with the abiding consolation provided by notions of a loving God and grace-filled moments in each of our lives.



“A River Runs Through It” is the story of Maclean’s family of origin, a religious family in which, as the author tells us famously in the novel’s opening line, “there was no clear line between religion and fly fishing.” Maclean is the older son of a Scottish Presbyterian minister. From their father, Norman and his younger brother Paul receive training in theology, fly fishing, and writing, but since fishing is religion in the Maclean world and fly fishermen the penultimate species of anglers, the novel’s key scenes involve fly fishing on rivers between Missoula and Helena, in the summer of 1937. “It is hard work,” Maclean insists, “living in such fast water all the time” (page 63 in the 25th Anniversary Edition by the Univ. of Chicago Press), a comment not only about the tenacious trout these men seek to catch, but also about the younger brother, whose stubborn habits of drinking too much, fighting local customs, and getting in over his head in serious gambling games means he is always swimming against the current. The story line ends with Paul’s brutal death at the hands of angry gambling partners, which leaves Norman and his parents with deep grief and few answers about why.

Key to our discussion of this novel were two obvious points–”A River Runs Through It” is a deeply Presbyterian work as well a carefully contrived story in which the characters and the events are reflective of an overriding message about family relationships, our individual search for success and meaning, and the mystery of God’s grace.

From the opening paragraphs, Maclean uses Presbyterian theology to give meaning and order to the events of the story. His quote from the Westminster Shorter Catechism [2]–that “man’s chief end is to glorify God, and to enjoy Him forever”–provides a way of understanding why the Reverend Maclean taught his sons to appreciate the glory of the Montana setting and to find enjoyment in working the Big Blackfoot River in search of the perfect catch. Such purposeful activity in beautiful surroundings reflects Maclean’s sense of how to appreciate the beauty and majesty of the divine.


If “fly fishing stands for life” in this story, as Roger Ebert suggested in his 1992 review of the Robert Redford movie version of the novel, then it is no surprise that Norman and Paul take to the river to fish whenever they can, and in our discussion we noted the ways in which the fishing scenes are bookmarks around which the rest of the story is built–a story with the characteristics of a good trout fishing river (pp. 61-63): first the fast action of the rapids, then the inevitable complications of the deep pools, and finally the calm waters resolving at the end.

The first fishing scene of the story (pages 12-21) tells us a good deal about the brothers and the basis of their relationship, flawed though it is. Norman works diligently if slavishly to replicate his father’s approach to fly fishing (“an art that is performed on a four-count rhythm between ten and two o’clock”) and has admirable if moderate success, whereas his younger brother Paul has all the grace and power of a natural and soon exceeds the mechanical limitations of his father’s discipline to attain a masterful casting technique (“shadow casting,” Maclean calls it, as if to emphasize its origins in a world beyond ours) which his father can only describe as “beautiful.” About his younger brother, Norman says (with potent foreshadowing): “ He was a master of an art. He did not want any big brother advice or money or help, and in the end, I could not help him” (p. 6). “Helping” is a code-word for relating to and loving others, in Maclean’s taxonomy.

The notion of salvation by grace through faith is the other point of Presbyterian theology that helps structure the story as well as hint at its ultimate meanings. “My father,” says Norman, “was very sure about certain matters pertaining to the universe. To him, all good things–trout as well as eternal salvation–come by grace and grace comes by art and art does not come easily” (p. 4). Of course, Maclean has given the standard Presbyterian line a bit of a twist, adding in the role of art, the human effort to glorify God, as part of the essential human response to the promise of grace. So it is that the Reverend Maclean believes his son Paul is simply, divinely “beautiful” in his fishing artistry.

But then our discussion foundered on the obvious dilemma of this story: why is it that Paul–the wayward son eventually overcome by his own shortcomings–is the one who is described by his minister father as “beautiful,” with the implication that Paul more than the others has attained something extraordinary, something akin to divine perfection? (At one point of climax in a fishing scene, Maclean describes Paul as surrounded by a “halo” of water” as he performs his miracle cast [p. 21].) This led our discussion to the paradoxical mystery of divine grace, a grace given without qualifying effort on our part (but which also engenders effort to “glorify”).

For the Maclean brothers, these are troubled waters and when the police call Norman to come to the station house to rescue his drunken brother and girlfriend, Norman is not surprised. Despite his mastery of fly fishing, Paul seems bent on a destructive life course, drinking heavily and slipping dangerously into debt at the famed Lolo poker game. The brothers try to reach out to each other, but neither understands the other well enough to be helpful. The best they can do is to set up another fishing trip. To that end, they agree to take Norman’s no-count brother-in-law fishing, a trip that (literally) reveals the brother-in-law as a true failure but helps bring the Maclean brothers together in support of one another at least temporarily. But how should we understand their relationship?

Our deepest point of discussion of “A River Runs Through It” focused finally on two Biblical themes–the Genesis story of Cain’s question, “Am I my brother’s keeper?” and the New Testament parable of the prodigal son [3].

The notion of the younger Maclean brother Paul as a ‘prodigal son’ provides both motive and meaning. It is clear from the start of the story that the family thinks highly of Paul despite his indiscretions, and desperate to understand and love their younger son, the parents go to great lengths to show their love for Paul, nowhere more clearly than in the humorous dinner scene at the family home the evening before what proves to be Paul’s final fishing trip. The mother fusses over Paul and gratuitously butters his dinner roll for him; father and brother eagerly ask to hear Paul’s latest stories. But when Paul leaves the house early (to go gambling), the party collapses. “Although only one left,” Norman says, “all the voices had gone” (p. 80). The Rev. Maclean tries to express his (mixed) feelings about Paul to Norman, but he can only muster his conclusion that “help is giving part of yourself to somebody who comes to accept it willingly…[and so it is] that we can seldom help anybody” (p. 81). But Paul is gone; this prodigal son can’t quite make it all the way home, it seems.

By the same token, Norman is burdened from the start by his perceived sense of duty to help his younger, troubled brother. But Paul doesn’t want his help, and in fact when Norman gets in trouble with his wife and her family for the fiasco fishing trip with the brother-in-law, Paul overtly offers to “help” Norman by setting up yet another fishing trip, this one to include their father as well, on the Big Blackfoot River, their cherished chapel in the woods. When Paul suggests that they fish together, Norman says “I knew then that he was still taking care of me, because we almost always split up when we fished” (p. 85). Despite the their imperfect relationship and Paul’s growing troubles, the brothers find a moment of unity in this fishing trip, when “all things came together.” Thin place moments of sacred unity abound when the brothers are together, fishing the waters of the Blackfoot. Watching Paul catch his limit of trout on this trip, the father exclaims, “He is beautiful,” but by the very next day Norman has to deliver the news of Paul’s death to their dumbfounded parents.

Running through the book are the rivers, their waters providing thematic momentum. Like the flow of life that captures us all, the characters of this novel live and breathe and have their being on the water. After Paul’s death, Norman remembers him “both as a distant abstraction in artistry and as a closeup in water and laughter” (p. 101). In the end, Norman admits that, some thirty years after the events of the story, he is still “haunted by waters.”

So it is that, in the Maclean scheme of things, we labor mightily to glorify God, each in our own way, and to love one another despite the distance that inevitably separates us one from another. When Reverend Maclean struggles to make sense of Paul’s life and death, Norman reminds himthat “you can love completely without complete understanding” (p. 103).


[1] Bill Linder-Scholer is a member of Westminster Presbyterian Church of Minneapolis and an enthusiastic participant in its Men’s Book Study Group. Prior to his retirement in 2011, Bill was a foundation executive and consultant on strategic corporate philanthropy and public education. His participation in the Westminster men’s book group reflects his stint in teaching at the University of Illinois, Urbana-Champaign, where he completed a Ph.D. in English literature and taught classes in rhetoric and fiction.

[2] The Westminster Shorter Catechism from 1646-1647 is one of 11 creeds and confessions contained in the Book of Confessions of the Presbyterian Church (U.S.A.) (as of 2014). In such creeds and confessions, according to the Church’s Book of Order (Section F-2.01), “the church declares to its members and to the world who and what it is, what it believes, and what it resolves to do; they also “identify the church as a community of people known by its convictions as well as by its actions [and] guide the church in its study and interpretation of the Scriptures.” Such creeds and confessions, however, “are subordinate standards in the church, subject to the authority of Jesus Christ, the Word of God, as the Scriptures bear witness to him.” (Id. Section F-2.02.)

[3] For the “brother’s keeper” theme, see Genesis 4:1-16, where Cain responds to God’s inquiry about the missing (murdered) younger brother, “Am I my brother’s keeper?” Jesus’s teaching via the parable of the prodigal and his brother is recounted in the Gospel of Luke 15: 11-32. For a detailed explication of the use of this parable in Maclean’s novel, see Dooley, Patrick K. “The Prodigal Son Parable and Maclean’s “A River Runs Through it,” RENASCENCE 58.2 (Winter 2005): 165-175.

U.S. Governors Call for Ending the U.S. Embargo Against Cuba

On October 9, nine U.S. governors sent a letter to congressional leaders calling for decisive steps to open up trade with Cuba and put an end to the embargo.[1]

They expressed their “support for an end to current trade sanctions levied against Cuba. It is time for Congress to take action and remove the financial, travel, and other restrictions that impede normal commerce and trade between our nation and Cuba.”

Federal legislation in 2000,“ they stated, “allowed for the first commercial sales of food and agricultural products from the U.S. in nearly half a century.” Since then “Cuba has become an important market for many American agricultural commodities. Thus far, our country’s agriculture sector has led the way in reestablishing meaningful commercial ties with Cuba, but a sustainable trade relationship cannot be limited to one sector or involve only one-way transactions.”

Nevertheless, the Governors added,  “financing restrictions imposed by the embargo limit the ability of U.S. companies to competitively serve the Cuban market. Our thriving food and agriculture sectors coupled with Cuba’s need for an affordable and reliable food supply provide opportunities for both our nations that could be seized with an end to the remaining trade restrictions. Foreign competitors such as Canada, Brazil, and the European Union are increasingly taking market share from U.S. industry, as these countries do not face the same restrictions on financing.”

“Ending the embargo will create jobs here at home, especially in rural America, and will create new opportunities for U.S. agriculture. Expanding trade with Cuba will further strengthen our nation’s agriculture sector by opening a market of 11 million people just 90 miles from our shores, and continue to maintain the tremendous momentum of U.S. agricultural exports, which reached a record $152 billion in 2014.”

In addition, “bilateral trade and travel among citizens of both nations will engender a more harmonious relationship between the U.S. and Cuba, while providing new opportunities for U.S. interests to benefit economically from improved relationships. The benefits of fully opening Cuba to free market trading with the U.S. go beyond dollars and cents. This positive change in relations between our nations will usher in a new era of cooperation that transcends business. Expanded diplomatic relations, corporate partnerships, trade and dialogue will put us in a better position to boost democratic ideals in Cuba. This goal has not been achieved with an outdated strategy of isolation and sanctions.”

“While normalized trade would represent a positive step for the U.S. and Cuban economies, we appreciate and support the Administration’s executive actions taken thus far to expand opportunity in Cuba and facilitate dialogue among both nations. We now ask that you and your colleagues in the U.S. House of Representatives and Senate take decisive steps to support U.S. commerce and trade relations and fully end the embargo on Cuba.”

The letter is signed by Governors Robert Bentley (Rep., AL), Jerry Brown (Dem. CA), Butch Otter (Rep., ID), Mark Dayton (Dem.MN), Steve Bullock (Dem., MT), Thomas Wolf (Dem., PA), Peter Shumlin (Dem., VT),Terry McAuliffe (Dem., VA) and Jay Inslee (Dem., WA).


[1] Letter, Governor Robert Bentley (and eight other Governors) to Senate Majority Leader McConnell, et al. (Oct. 9, 2015); Bullock, Governor Bullock Encourage End to Trade Sanctions with Cuba (Oct. 14, 2015); Shumlin, Governor Shumlin Urges End to U.S. Trade Sanctions with Cuba (Oct. 13, 2015); Governor supports trade with Cuba, Great Falls Tribune (Oct. 14, 2015); Thurston, Could Farmers Cash in with More Open Trade with Cuba? Necn (Oct. 14, 2015); Prentice, Otter, Eight Other Governors, Urging Congress to Lift Cuba Trade Embargo, Boise Weekly (Oct. 14, 2015); Nine U.S. governors call for an end to the blockade, Granma (Oct. 14, 2015).



Excesses of People Falsely Alleging Voter Fraud

The prior post discussed the need to fight efforts to restrict voting in the U.S., including those purportedly aimed at squashing voter fraud.

A new article by Justin Levitt, an associate professor of law at Loyola Law School, Los Angeles, discusses the problems created in Montana in the 2008 election by people who made false accusations of voter fraud.

For the 2012 election, Levitt reports, there have been “challenges based on ostensible felony status in Florida, ostensible deaths in North Carolina and ostensible address problems in Ohio, among others. Some of these challenges appear to be the work of isolated individuals, others are coordinated by local groups ’empowered by’ national entities like True the Vote. The common thread is that the challenges are based not on personal information about particular voters, but computerized scans of data records.”

There are at least three major problems with such challenges, according to Levitt.

First, the underlying databases for the challenges are inaccurate.

Second, some challenges are aimed at situations that may be unusual, but legitimate: (a) “voters registered at business addresses, ignoring the fact that small business owners or managers may live where they work;” (b) “immigrants, ignoring the fact that noncitizens may have become naturalized [U.S. citizens];” and (c) “students and others in group housing.”

The third major problem created by such challenges is the burdens they place on “overworked and underpaid officials desperately trying to make sure that the elections run smoothly” and on “eligible citizens [who are pulled] away from jobs and families into unnecessary legal hearings.” It is even worse for such challenges to absentee ballots from legitimate voters who have little practical chance to defend themselves.

Many of these challenges, according to Levitt, have been resisted by most election officials.

On election day itself, such officials should be skeptical of anyone “walking around with long lists of ostensibly illegal voters” that are most likely full of mistakes. The officials should “swiftly reject challenges that are not founded on credible personalized knowledge about individual voters, and they must remove volunteers who become overzealous. There must be room for civic participation, but there can be no room for unfounded disruption to the right to vote.”