Voter Registration in 353 Counties in 29 States Exceeds 100% of Eligible Voters -- Says Judicial Watch

Judicial Watch has long been working to force reluctant local and state governments to comply with the federal law that requires them to keep accurate voter registration rolls.  This is a critical task if we are to have legitimate elections and it is one of several reasons why I am a Judicial Watch contributor.

Judicial Watch has released an updated study of the problem.  This problem is especially acute when the states are sending out mass mailings of ballots to everyone on the absurdly inflated voter registration rolls.  The highlights of the results follow from an email I just received from Judicial Watch:

Voter Registration in 353 Counties in 29 States Exceeds 100%

In 2018 the Supreme Court upheld a voter-roll cleanup program that resulted from our settlement of a federal lawsuit with Ohio. California settled a NVRA lawsuit with us and last year began the process of removing up to 1.6 million inactive names from Los Angeles County’s voter rolls. Kentucky also began a cleanup of hundreds of thousands of old registrations last year after it entered into a consent decree to end another Judicial Watch lawsuit. In September 2020, we sued Illinois for refusing to disclose voter roll data in violation of Federal law.

So we’ve been busy and effective. Unfortunately, the problem persists.

Our newly released study reveals that 353 U.S. counties had 1.8 million more registered voters than eligible voting-age citizens. In other words, the registration rates of those counties exceeded 100% of eligible voters. The study finds eight states showing statewide registration rates exceeding 100%: Alaska, Colorado, Maine, Maryland, Michigan, New Jersey, Rhode Island, and Vermont.

The September 2020 study collected the most recent registration data posted online by the states themselves. This data was then compared to the Census Bureau’s most recent five-year population estimates, gathered by the American Community Survey (ACS) from 2014 through 2018. ACS surveys are sent to 3.5 million addresses each month, and its five-year estimates are considered to be the most reliable estimates outside of the decennial census.

Our latest study is necessarily limited to 37 states that post regular updates to their registration data. Certain state voter registration lists may also be even larger than reported, because they may have excluded “inactive voters” from their data. Inactive voters, who may have moved elsewhere, are still registered voters and may show up and vote on election day and/or request mail-in ballots.

We rely on our voter registration studies to warn states that they are failing to comply with the requirements of the National Voter Registration Act of 1993, which requires states to make reasonable efforts to clean their voter rolls. We can and have sued to enforce compliance with federal law.

Earlier this month, we sued Colorado over its failure to comply with the National Voter Registration Act. In our new study, 42 Colorado counties—or two thirds of the state’s counties—had registration rates exceeding 100%. Particular data from the state confirms this general picture. As the complaint explains, a month-by-month comparison of the ACS’s five-year survey period with Colorado’s own registration numbers for the exact same months shows that large proportions of Colorado’s counties have registration rates exceeding 100%. Earlier this year, we sued Pennsylvania and North Carolina for failing to make reasonable efforts to remove ineligible voters from their rolls as required by federal law. The lawsuits allege that the two states have nearly 2 million inactive names on their voter registration rolls. We also sued Illinois for refusing to disclose voter roll data in violation of Federal law.

Our study updates the results of a similar study from last year. In August 2019 we analyzed registration data that states reported to the federal Election Assistance Commission (EAC) in response to a survey conducted every two years on how states maintain their voter rolls. That registration data was compared to the then-most-recent ACS five-year survey from 2013 through 2017. The study showed that 378 U.S. counties had registration rates exceeding 100%.
The new study shows 1.8 million excess, or ‘ghost’ voters in 353 counties across 29 states. The data highlights the recklessness of mailing blindly ballots and ballot applications to voter registration lists. Dirty voting rolls can mean dirty elections.

STATES AND COUNTIES WITH REGISTRATION RATES EXCEEDING 100%

(* means no separate reporting of inactive registrations)
 

Alabama: Lowndes County (130%); Macon County (114%); Wilcox (113%); Perry County (111%); Madison County (109%); Hale County (108%); Marengo County (108%); Baldwin (108%); Greene County (107%); Washington County (106%); Dallas County (106%); Choctaw County (105%); Conecuh County (105%); Randolph County (104%); Shelby County (104%); Lamar County (103%); Autauga County (103%); Clarke County (103%); Henry County (103%); Monroe County (102%); Colbert County (101%); Jefferson County (101%); Lee County (100%); Houston County (100%); Crenshaw County (100%)

*Alaska: Statewide (111%)

Arizona: Santa Cruz County (107%); Apache County (106%)

*Arkansas: Newton County (103%)

Colorado: Statewide (102%); San Juan County (158%); Dolores County (127%); Jackson County (125%); Mineral County (119%); Ouray County (119%); Phillips County (116%); Douglas County (116%); Broomfield County (115%); Elbert County (113%); Custer County (112%); Gilpin County (111%); Park County (111%); Archuleta County (111%); Cheyenne County (111%); Clear Creek County (110%); Teller County (108%); Grand County (107%); La Plata County (106%); Summit County (106%); Baca County (106%); Pitkin County (106%); San Miguel County (106%); Routt County (106%); Hinsdale County (105%); Garfield County (105%); Gunnison County (105%); Sedgwick County (104%); Eagle County (104%); Larimer County (104%); Weld County (104%); Boulder County (103%); Costilla County (103%); Chaffee County (103%); Kiowa County (103%); Denver County (103%); Huerfano County (102%); Montezuma County (102%); Moffat County (102%); Arapahoe County (102%); Jefferson County (101%); Las Animas County (101%); Mesa County (100%.

*Florida: St. Johns County (112%); Nassau County (109%); Walton County (108%); Santa Rosa County (108%); Flagler County (104%); Clay County (103%); Indian River County (101%); Osceola County (100%)

*Georgia: Bryan County (118%); Forsyth County (114%); Dawson County (113%); Oconee County (111%); Fayette County (111%); Fulton County (109%); Cherokee County (109%); Jackson County (107%); Henry County (106%); Lee County (106%); Morgan County (105%); Clayton County (105%); DeKalb County (105%); Gwinnett County (104%); Greene County (104%); Cobb County (104%); Effingham County (103%); Walton County (102%); Rockdale County (102%); Barrow County (101%); Douglas County (101%); Newton County (100%); Hall County (100%)

*Indiana: Hamilton County (113%); Boone County (112%); Clark County (105%); Floyd County (103%); Hancock County (103%); Ohio County (102%); Hendricks County (102%); Lake County (101%); Warrick County (100%); Dearborn County (100%)
Iowa: Dallas County (115%); Johnson County (104%); Lyon County (103%); Dickinson County (103%); Scott County (102%); Madison County (101%); Warren County (100%)

*Kansas: Johnson County (105%)
Maine: Statewide (101%); Cumberland County (110%); Sagadahoc County (107%); Hancock County (105%); Lincoln County (104%); Waldo County (102%); York County (100%)

Maryland: Statewide (102%); Montgomery County (113%); Howard County (111%); Frederick County (110%); Charles County (108%); Prince George’s County (106%); Queen Anne’s County (104%); Calvert County (104%); Harford County (104%); Worcester County (103%); Carroll County (103%); Anne Arundel County (102%); Talbot County (100%)

*Massachusetts: Dukes County (120%); Nantucket County (115%); Barnstable County (103%)

*Michigan: Statewide (105%); Leelanau County (119%); Otsego County (118%); Antrim County (116%); Kalkaska County (115%); Emmet County (114%); Berrien County (114%); Keweenaw County (114%); Benzie County (113%); Washtenaw County (113%); Mackinac County (112%); Dickinson County (112%); Roscommon County (112%); Charlevoix County (112%); Grand Traverse County (111%); Oakland County (110%); Iron County (110%); Monroe County (109%); Genesee County (109%); Ontonagon County (109%); Gogebic County (109%); Livingston County (109%); Alcona County (108%); Cass County (108%); Allegan County (108%); Oceana County (107%); Midland County (107%); Kent County (107%); Montmorency County (107%); Van Buren County (107%); Wayne County (107%); Schoolcraft County (107%); Mason County (107%); Oscoda County (107%); Iosco County (107%); Wexford County (106%); Presque Isle County (106%); Delta County (106%); Alpena County (106%); St Clair County (106%); Cheboygan County (105%); Newaygo County (105%); Barry County (105%); Gladwin County (105%); Menominee County (105%); Crawford County (105%); Muskegon County (105%); Kalamazoo County (104%); St. Joseph County (104%); Ottawa County (103%); Clinton County (103%); Saginaw County (103%); Manistee County (103%); Lapeer County (103%); Calhoun County (103%); Ogemaw County (103%); Macomb County (103%); Missaukee County (102%); Eaton County (102%); Shiawassee County (102%); Huron County (102%); Lenawee County (101%); Branch County (101%); Osceola County (101%); Clare County (100%); Arenac County (100%); Bay County (100%); Lake County (100%)

*Missouri: St. Louis County (102%)

*Montana: Petroleum County (113%); Gallatin County (103%); Park County (103%); Madison County (102%); Broadwater County (102%)

*Nebraska: Arthur County (108%); Loup County (103%); Keya Paha County (102%); Banner County (100%); McPherson County (100%)

Nevada: Storey County (108%); Douglas County (105%); Nye County (101%)
*New Jersey: Statewide (102%); Somerset County (110%); Hunterdon County (108%); Morris County (107%); Essex County (106%); Monmouth County (104%); Bergen County (103%); Middlesex County (103%); Union County (103%); Camden County (102%); Warren County (102%); Atlantic County (102%); Sussex County (101%); Salem County (101%); Hudson County (100%); Gloucester County (100%)

*New Mexico: Harding County (177%); Los Alamos County (110%)

New York: Hamilton County (118%); Nassau County (109%); New York (103%); Rockland County (101%); Suffolk County (100%)

*Oregon: Sherman County (107%); Crook County (107%); Deschutes County (105%); Wallowa County (103%); Hood River County (103%); Columbia County (102%); Linn County (101%); Polk County (100%); Tillamook County (100%)

Rhode Island: Statewide (101%); Bristol County (104%); Washington County (103%); Providence County (101%)

*South Carolina: Jasper County (103%)

South Dakota: Hanson County (171%); Union County (120%); Jones County (116%); Sully County (115%); Lincoln County (113%); Custer County (110%); Fall River County (108%); Pennington County (106%); Harding County (105%); Minnehaha County (104%); Potter County (104%); Campbell County (103%); McPherson County (101%); Hamlin County (101%); Stanley County (101%); Lake County (100%); Perkins County (100%)

Tennessee: Williamson County (110%); Moore County (101%); Polk County (101%)

Texas: Loving County (187%); Presidio County (149%); McMullen County (147%); Brooks County (117%); Roberts County (116%); Sterling County (115%); Zapata County (115%); Maverick County (112%); Starr County (110%); King County (110%); Chambers County (109%); Irion County (108%); Jim Hogg County (107%); Polk County (107%); Comal County (106%); Oldham County (104%); Culberson County (104%); Kendall County (103%); Dimmit County (103%); Rockwall County (102%); Motley County (102%); Parker County (102%); Hudspeth County (101%); Travis County (101%); Fort Bend County (101%); Kent County (101%); Webb County (101%); Mason County (101%); Crockett County (101%); Waller County (100%); Gillespie County (100%); Duval County (100%); Brewster County (100%)

Vermont: Statewide (100%)

Virginia: Loudoun County (116%); Falls Church City (114%); Fairfax City (109%); Goochland County (108%); Arlington County (106%); Fairfax County (106%); Prince William County (105%); James City County (105%); Alexandria City (105%); Fauquier County (105%); Isle of Wight County (104%); Chesterfield County (104%); Surry County (103%); Hanover County (103%); New Kent County (103%); Clarke County (103%); King William County (102%); Spotsylvania County (102%); Rappahannock County (102%); Albemarle County (101%); Stafford County (101%); Northampton County (101%); Poquoson City (100%); Frederick County (100%)

Washington: Garfield County (119%); Pend Oreille County (112%); Jefferson County (111%); San Juan County (108%); Wahkiakum County (108%); Stevens County (103%); Pacific County (103%); Clark County (102%); Island County (102%); Klickitat County (102%); Thurston County (102%); Lincoln County (101%); Whatcom County (100%); Asotin County (100%)

*West Virginia: Mingo County (104%); Wyoming County (103%); McDowell County (102%); Brooke County (102%); Hancock County (100%)

My Comments:

One of the reasons the Democratic Party opposed the Citizenship question on the 2020 Census so adamantly is because the only way the Census population can be used in the future to spot obviously bloated voter registration polls is if the registered voters exceed the sum of the age-eligible citizens and the same age range of non-citizens, who cannot legally vote.  The Democratic Party, for all its pretense of claiming that every vote must count, has long had a strongly vested interest in inflated voter registration rolls.  Of course, every legal vote is watered down when the dead, the out of district, and non-citizens vote in an election.  The Democratic Party is not concerned with this.

The Integrity of the Vote

It is illegal for non-citizens to vote in the U.S. except in a few localities of Maryland.  It is illegal for the dead to vote, thankfully everywhere in the U.S.  It is illegal to vote in more than one state in an election.  It is illegal for a person to vote while impersonating another person.  It is illegal to vote as a fictitious person.  In 38 states it is illegal to vote while serving time in prison as a felon, while in other states it is illegal for a period of time after the completion of serving time or until the felon has petitioned the state for the return of the right to vote.  Yet, each of these types of illegal votes are known to happen.  What we do not adequately know is how many of these illegal votes occur.

We do know that there is a great potential for illegal votes.  We also know that some politicians and their campaign associates eagerly court illegal votes.

During the 2016 election campaign, Obama was asked on a Spanish-speaking radio station broadcast if non-citizens were in danger if they cast a vote in the election.  He told them they, including undocumented aliens, were citizens and no one would come after them if they voted because they were citizens.  So as far as this Democrat is concerned, the naturalization laws established by Congress in accordance with the power invested in the Congress by our Constitution shall be ignored in the interest of the fact that more than 80% of the votes of non-citizens in 2008 were votes for the Democratic Party.

John Podesta, Hillary Clinton's campaign manager, wrote an e-mail advising non-citizen immigrants to get a driver's license and then state at a polling site that they were a U.S. citizen.  That greater than 80% portion of the vote is just too hard for a dedicated socialist Democrat to resist.  A Rasmussen poll in 2015 found that 53% of Democrats support allowing even illegal aliens to vote.

The Democrats have long opposed voter ID and they have long favored mail-in ballots whose validity is especially difficult to ascertain.  In most states one can register to vote simply by stating that you are a citizen, so many non-citizens are registered to vote.  One of the ways we know this is because jurors are called based on the voter registration roles and many of those called get out of jury duty by claiming that they are not citizens.  We also know from an Old Dominion University study of the Cooperative Congressional Election Study of voters in the 2008 and 2010 elections that 14% of non-citizens said they were registered to vote.

What is the potential for immigrants, and especially non-citizen immigrants, to affect the outcome of elections in the U.S.?  It is clearly a function of their numbers, their understanding that it is illegal for them to vote, and the protections against those determined to vote.  Let us examine the number of immigrants first:

Of the immigrants, 47.1% in 2014 were citizens.  So of the 42.4 million immigrants in 2014, 52.9% were non-citizens, making the number of non-citizens about 22.4 million.  About 20 million of them were older than 18 years of age.  Tom Fitton of Judicial Watch has been making the mistaken claim that there are 42.4 million non-citizens in the U.S.  But 14% registration of 20 million non-citizens is 2.8 million illegal registrations.

A 2012 Pew Research Center study found that about 2.75 million people are registered to vote in more than one state.  It also found that 1.8 million dead people were registered to vote.  Adding up the non-citizen registrants, the multi-state registrants, and the dead registrants, the voter registration rolls have a very worrisome 7.35 million registered illegal voters.  Some of these people may themselves use their false registrations to vote -- well excluding the dead ones --, but as worrisome as that is, there is great potential for an organized effort by a nefarious minded organization or party to convert that potential into actual election stealing results.

Mind you, I am not claiming that it is likely that President Trump is correct in saying that there were 3 - 5 million illegal votes in the 2016 election.  I am saying that it is not acceptable knowing what is at stake in elections to have such a large potential for election abuse.  Evil-minded socialists in particular are often inclined to trample on individual rights by using such potential tools to undermine American freedoms.

It is clear that the Democrats are especially keen on encouraging non-citizens to vote and other illegal voting practices.  There are some known cases of Republican politicians also doing so.  None of these nefarious activities should be tolerated in the least.  The integrity of the vote is a very serious matter. It is all the more so because voters unleash and direct the hugely exaggerated powers of our big governments which make a practice of hurting some citizens and other residents in favor of the whims of a plurality of votes collected.  This situation is bad enough when the votes are those of citizens cast in a legal manner.

The Old Dominion University study estimated that 6.4% of U.S. non-citizens themselves voted in the November 2008 election and that 81% of those votes were for Obama.  Such numbers were actually enough that had they not been cast, John McCain would have won the electoral votes of the state of North Carolina instead of Obama.  That did not change the outcome of that election nationally, but there are not infrequent presidential elections that are changed by flipping a state with 15 electoral votes.  It is also very likely that Al Franken became a Senator representing Minnesota because of the illegal votes cast in that election.  ObamaCare was made law as a result of his election.  The Colorado Secretary of State, Scott Gessler, in an investigation of the U.S. Senate election of 2010 found that almost 5,000 illegal aliens cast votes in that election.  In 2005, the U.S. GAO found that as many as 3% of the 30,000 people called to jury duty in one U.S. district court were non-citizens despite being on the voter registration rolls.

Elections have consequences.  It is, unfortunately, rather difficult to detect all of the illegal votes after an election.  One has to find a way to see to it that illegal votes are not cast at all.  And one has to do this despite the concerted efforts of the Democratic Party to maintain the huge potential for election fraud. The Obama administration refused to comply with the National Voter Registration Act (NVRA), which requires the states to keep accurate and up-to-date voter registration rolls, with help from the federal government in identifying those with citizenship and those without it.  The state of Maryland requested the help guaranteed by the NVRA to clean up its voter registration rolls from the U.S. Citizenship and Immigration Service and was denied the information under the claim that that agency had to "safeguard the confidentiality of each legal immigrant."  Few states have made the effort to comply with the NVRA and without help from the federal government, it is very difficult for them to do much.

In general, the Obama administration has opposed voter ID, which is required, contrary to Obama's claims, in most other nations.  It has favored same-day registrations, voting by mail, open borders, amnesty for illegal aliens, and every other measure to increase the immigrant vote.  To clean up this mess, the federal government must be required to help the states comb their voter registration rolls for non-citizens and it must help them identify the registered dead using its information on social security and Medicare.  To be sure, there are cases in which the states can probably help the federal government clean up its social security and Medicare records as well.  It is important that every vote actually cast is checked against provided voter identification, including absentee ballots.  No voter registration should be allowed without proof of citizenship.  And, there should be a concerted effort to inform non-citizens that it is illegal for them to vote.  Each and every case of illegal voting that is found should be prosecuted vigorously and punished severely.  There need to be frequent and careful investigations of elections looking for any voter fraud that has occurred.  Elections are too vitally important not to make a major law enforcement effort to insure their integrity.

One Person, One Vote?

The Supreme Court just heard a case on Tuesday, Evenwel v. Abbott, over whether state legislative districts must equalize the number of voters or the number of people.  The particular state in this case is Texas, where districts are apportioned by number of people and where the number of voters per district then differs greatly in some cases.

One person, one vote sounds nice -- until you give it some thought.  Of course children are persons, but we exclude them from voting.  Non-citizens are also not supposed to vote, though many do in some districts, especially those controlled by the Democratic Party.  Many people though eligible to become voters do not register to vote.  Many people who are registered to vote skip many or some elections.  There simply is no sense in which one person gets one vote and one share of representation.  There is no feasible way to achieve any such outcome in the future.

The Constitution originally handled the problem this way:

Representatives and direct taxes shall be apportioned among the several States which may be included within this Union, according to their respective numbers, which shall be determined by adding the whole Number of free Persons, including those bound to Service for a Term of Years, and Excluding Indians not taxed, three fifths of all other Persons.

Consequently, districts for the House of Representatives were equalized for the total number of people, excluding untaxed Indians and two-fifths of slaves.  The free Persons included non-citizens.  The idea at the time was that those men eligible to vote would represent all men with insufficient property to vote, children, women, non-citizens, those bound to service for a term of years, and all slaves.

The 14th Amendment changed the apportionment for the House Districts by only excluding Indians not taxed.  It went on to punish states that denied the right to vote to male citizens of 21 years of age or older by reducing the House representation in proportion to their numbers in ratio to the total number of male citizens 21 years of age and older.  The idea was still clearly that male citizens of 21 years or older would represent all women and all non-citizens.

But how should the House Districts properly be set up?  By extension, how should state legislative districts be set up?  Is it reasonable to assume that those who vote are trying and able to represent the good of those who cannot or will not vote when they cast their vote?  These are substantive questions.  It is not unreasonable for fairly reasonable people to disagree on the answers.

At the time the 14th Amendment was written, it was considered that House Districts should be apportioned in accordance with the number of voters or eligible voters.  That idea was shot down immediately when Representative James Blaine, Republican of Maine, examined the census data and found that since the ratio of men to women was much higher in Western states than in the Eastern states, the Eastern states would lose massive representation if it were based on the number of voters or eligible voters.  Women could not vote, but they were valuable for inflating the numbers of persons for representation, much as slaves had been in the South in the past.

It is now easy for all citizens of age to vote.  Despite this, in many areas very low fractions of the citizens chose to vote.  They are either not sufficiently interested or they are so infused with a sense of futility that they see no point in voting.  Should uninterested people or those so infused with a sense of doom and futility be given representation that they will not use? 

In most cases, such uninterested or futility-bound voters especially occupy highly Democrat districts.  So many Progressive Elitist Democrats believe such non-participating voters or potential voters should be represented because they, the Progressive Elitists, will cast their votes in the interest of the apathetic or doomed-in-futility persons.  Yet these same Progressive Elitists have long claimed to be doing this, especially to minimize economic inequality.  Nonetheless, the Congressional Districts with the worst economic inequality are almost exclusively Democratic and have been for decades.  Clearly, the Progressive Elitist voters, who do vote in high percentages, either do not actually vote to reduce economic inequality or they do so with a complete misunderstanding of the consequences of their votes.  They are clearly horrible at representing the interests of the less educated and less inclined to vote people in their districts.

In general, people who vote either vote their own interest or they vote for the interests of others without actually understanding their interests.  Let us be realists and recognize the facts and human nature.  People barely able to motivate themselves to vote rarely have any understanding of the legitimate role of government, the important political issues of the time, the principles of the candidates, and the manner in which new laws and regulations will affect our futures.  In the era of
Big Government these issues are often much more complex than they were in the past in America.

We should also note that it is clear that people are not good at representing the interests of children.  We see this in the miserable public education system we have, in the huge national debt, in the terrible future liabilities of Social Security and Medicare, and the complete disregard for the effect of compounded economic growth rates on the standard of living of Americans 30 or 40 years from now.  Few voters weigh the future enough to look to future outcomes.  Consequently, they are nearly worthless as representatives of the interests of today's children.

House districts, both federal and state, should simply be apportioned on the basis of the number of voters in the last several elections, assuming they do not exceed the number of eligible voters as they do in some Democrat districts.  This apportions representation according to the numbers of citizens of age to vote who actually have an interest in government.  Yes, many of them will not understand the issues and the consequences of their votes either, but this is the one form in which One Person, One Vote is actually achievable in the form of One Voter, One Vote.

Adding to the weight on political outcomes of those districts with higher voter turn-out is likely to raise the quality of the People's Voice about as high as one can accomplish by any means except an improved education system or other educational efforts.  If the reward in political outcomes is greater for those who already care enough to vote, perhaps they will make a greater effort in the future to think about their votes.  These more thoughtful voters then may even realize a bit greater responsibility not to do harm to others, including those others who do not care to vote.  But realistically, one will be giving a greater voting weight to those who are voting for the interests of those they know best, themselves and perhaps their immediate family and friends.  That is not a bad thing.  Most great wrongs are done when people vote or act for others they do not even know, or when they pretend to do so.

How might one determine the number of voters for these district apportionment purposes?  How about the last four elections in the previous decade with re-apportionment occurring once a decade?  It would be nice if one could just make this the last four elections, but the re-districting effort and battles would be too much.  As for why four elections, the fluctuations in voter turn-out are great, especially the differences between Presidential elections and those when voting on the President does not occur.  The last four elections will include two presidential and two non-presidential elections.  It will include elections when no vote was up in the state for Senator in Congress.  It is a good number to average out, though it may slightly lag overall population shifts.  I would gladly live with that population shift lag for the many benefits of One Voter, One Vote, One Share of Representation.

As for state legislative districts, a variety of formulas are fairly reasonable and determining what formula to use should be left up to the states.  Only very unreasonable state decisions should be corrected by the Supreme Court.  Among the unreasonable apportionments would be those that count non-citizens.  Perhaps counting citizen children should also be considered unreasonable, though I am less adamant about this than about the non-citizen count.

Which brings up the need to also tackle the problem of ineligible voters casting ballots as another aspect of the voter representation problem.