Denison University Complaint 11.19.18

RECEIVED
November 17, 2018 LICKING COU,H Y

BOARD OF ELECTIONS
1018 NOV 1q A fl: 02
Larry D. Wise, Chairman
Licking County Board of Elections
20 South Second Street
Newark, OH 43055
Dear Mr. Wise:
We are residents of the Granville Exempted Village School District. Together with other
Granville residents, we believe that the Licking County Board of Elections and its duly
appointed poll workers in Granville Village Precinct C permitted many Denison University
students to cast ballots in the November 6, 2018, General Election without offering some form
of identification required by the Ohio Secretary of State.
Specifically, poll workers were observed allowing Denison University students to pass Ohio's
required identity check by using a so-called "utility bill" that any student could request at the
college bookstore. Students were advised about the availability of this document through a
sign posted by an unregistered campus-based voter education group. A photograph of this
-
sign is attached to this letter.
Ohio administrative code requires poll workers to accept utility bills as a form of legal voter
identification. Secretary of State Directive 2008-80 specifies that "[a] 'utility bill' includes, but
is not limited to, water, sewer electric, natural gas, heating oil, cable or satellite television,
telephone or digital telephone, and cellular telephone service." Denison University, however,
is not a utility and does not issue utility bills except on the occasion of an election. Its
published schedule of tuition and fees does not include direct charges or fees for any utility.
Whatever costs Denison may recover for utility services provided students, they are not
explicitly enumerated and are just embedded and undefined in one or more of its broad
service charge categories that currently include: full-time tuition, activity fee, health center
fee, room, or board (see https://denison.edu/campus/finances/tuition-costs).
To be sure, it has been claimed by some that faux utility bills like Denison's can be used as
legal identification at polling places. Indeed, if this were true, utility bills could be issued by
any organization or individual without any chain of custody. Their validity would hinge on
nothing more than containing certain nominal information required by the Secretary of State.
It appears, however, that the Secretary of State anticipated this problem in Directive 2008-80.
This measure describes a wide range of particular and unspecified documents (including
possibly faux utility bills) which a student might use as legal identification, but it explicitly
requires that a public university or college must issue any such documents. Denison
University, however, is not a public institution. It is and always has been private.
While we suspect that Denison's "utility bill" is a byproduct of its need to exhibit compliance
with federal student voting regulations, the college surely is well-aware that the great
letter to licking County Board of Elections Page 2 of 3
majority of its students, whether registered to vote or not, fail to act as bona fide residents.
The college openly claims that more than 75 percent of its students are not Ohioans. It
knows that students with cars from out-of-state rarely register them in Ohio. Its post-
graduation tracking of recent graduates almost certainly shows, as one independent survey
found, that less than 5 percent remain in licking County after moving out of their
dormitories.
Based on data published by the licking County Board of Elections, it is apparent that, valid or
not, the utility bills presented as identification by Denison students will not change the
outcome of any race among the various candidates for election. The 432 votes cast by
Denison students Granville Village Precinct C, however, could have a material impact on the
outcome of Granville's school district's hotly contested income tax referendum, which
unofficially won by a margin of just 142 votes. Had the Board of Elections last week granted
our written request for the uncertified "Yes" and "No" votes on this measure in Granville
Village Precinct C, we might have been able to prove our point on this matter categorically,
and especially so given the fact that the count of non-Denison students voting in Precinct C
totaled only 202.
We respectfully petition the Board of Elections to refrain from certifying any ballots from this
November's general election that were cast in Granville Village Precinct C until the legitimacy
and legality of Denison student votes there can be determined. Failure to investigate this
matter thoroughly easily could cause irreparable harm to many Granville school district
residents. We do not in any way question the right of the school district to seek approval of
additional tax revenue. The law, however, dictates that the outcome of any election must be
conditioned exclusively by qualified electors, a result that has been compromised by the
failure of the Board of Elections and its poll workers to apply Ohio law properly.
Should you or members of your staff desire additional information, we are willing at your
convenience to share all that we have managed to learn both about the issue addressed in
this letter as well as related topics, which have a direct bearing on the eligibility of Denison
students to cast ballots in state and local elections.
Sincerely,
;6/~
lisa L Englefield
a~~~
Paul R. Jenks Paul D. Rice
2356 Hankinson Road 190 Pinehurst Drive 466 Glyn Tawel Drive
Granville, OH 43023 Granville, OH 43023 Granville, OH 43023
~~~~
170 Pinehurst Drive 474 Glyn Tawel Drive
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Granville, OH 43023 Granville, OH 43023
cc: Andrea LH. Eastman, Grace Cherrington, Richard E. Salvage, Sue Penick, Brian Mead
letter to licking County Board of Elections Page 3 of 3

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RECEIVED

November 17, 2018 LICKING COU,H Y

Dear Mr. Wise:

Granville, OH 43023 Granville, OH 43023

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