Open Primaries, the Democrats and 2020

Early last month the Democratic National Committee-sanctioned Unity Reform Commission convened for their second meeting in San Antonio. While the agenda at the first meeting in May in Washington, DC served to provide an overview of the nomination process to the members of the commission, the San Antonio meeting was dedicated to drilling down on a couple of specific issues. Mainly, time was spent hearing from a series of presenters and discussing 1) the overlapping/diverging interests of state governments and the parties in the presidential nomination process and 2) the idea of drawing unaffiliated voters into the process.

[For more on the first meeting in Washington, see here.]

FHQ has spent (and will likely continue to spend in the future) an inordinate amount of time discussing the former agenda item, particularly through the lens of presidential primary scheduling. However, here I will focus more on the latter agenda point; those unaffiliated voters. Typically national parties, if they have weighed in at all during their nomination rules making over time, have tended move in the opposite direction. That is, the national parties have been guided by an impetus to make the nomination process one where only registered partisans participate rather than opening up the floodgates to those outside the party. The principle from the party's perspective, for better or worse, has most always been, "if you want to participate, join the party."

At the state level, the story is different and varied. There, most but not all states utilize a primary as the means of allowing voters to express their presidential preference, the results of which determine the delegate allocation to candidates. And therein lies one of those aforementioned points of overlapping jurisdiction. State parties, by opting into the government-run and funded primary cede in part some of their ability to directly determine the parameters of the election. That is clearest on something like the date of the contest. It is state governments that make that "when" determination whether or not either of the state parties is on board.

And that same relationship exists to a slightly lesser degree where participation is concerned. By opting into a state government-funded election, the state parties yield to the state government to decide which voters can participate in a partisan primary. Unlike setting the dates of those various contests, however, state parties have been more willing to challenge the extent of state government control over determining who can vote. And those challenges -- Tashjian, for starters and some of the blanket primary cases such as California Democratic Party v. Jones -- have tended to find the courts siding with the parties, emphasizing the private organizations' freedom of association protections.

But not all state parties have or have had conflicts with the decisions made by state governments. Those state parties are, on the one hand, fine with more open processes that allow them to woo independents and/or those affiliated with the other party. But on the other hand, some state parties are perfectly happy with state laws dictating a closed primary. And as Meinke, et al. (2006) found, the ideological proximity of the state party to party registrants in a state has a significant bearing how open the process is. If there is convergence between the party and rank-and-file partisans, the primaries tend to be more open. But the wider the distance between the two, the more likely it is that the state party makes some attempt to protect their position by closing off the process to partisans of their own party or limiting participation even further through a caucus/convention system of nomination.

Of course, other state parties have not challenged those conflicts at all through legal channels, opting instead to leave well enough alone or to seek a solution through advocating for legislation making the necessary changes to who can participate. A final subset of state parties have chosen to (attempt to) opt out of state-funded primaries altogether at the presidential level and on down the ballot. It was this last subset that was most active during the Obama years. Tea Party and Ron Paul-aligned state Republican parties pursued -- mostly unsuccessfully -- a path of nominating candidates via low turnout caucuses closed but for registered partisans.

Yet, that action -- state parties attempting to create a process closed to those outside the party -- was consistent with how the national parties have tended to behave (when they have sporadically chosen to attempt to intervene on the matter). In fact, in an extension of the Tea Party maneuvering of the Obama years, a proposal was discussed and debated in the Convention Rules Committee meeting preceding the 2016 Republican National Convention to provide incentives to states with closed presidential primaries.

But the Democratic Party did not follow a similar, parallel trajectory at their 2016 national convention in Philadelphia. Rather, the pressure from Sanders delegates and supporters was to open the process up. That push, along with that on other points of contention like the superdelegates issue, culminated with the charter that created the Unity Reform Commission in the first place. However, while there were clear guidelines in that charter regarding the recommendations the commission would make with respect to superdelegates, the language on the open primaries question was more passive. Mainly, that is due to the some of the complexities described above.

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Now that the Unity Reform Commission has had this discussion, though, there are a couple of points FHQ would raise on open primaries. One is semantical. The other is a recitation on a theme I have raised a few times since primary season in 2016.

1. Open primaries?
While "open primaries" is often the shorthand used, they are not necessarily for what the Sanders folks have been pushing. And that is pretty clear in how the URC dealt with the issue. The approach of the commission was about attracting unaffiliated voters instead of an outright call for open primaries. There is some nuance there that is absent in calls for open primaries.

Categories based on National Conference of State Legislatures definitions

After all, Sanders did not fare all that well in open contests. Many of them were scattered across the South, where Clinton idd better than the Vermont senator, especially among African American voters. Looking at the wins each viable Democratic presidential aspirant had in 2016 (by contest participation type), Sanders clearly bested Clinton in states that held caucuses rather than primaries. Clinton only won in the earliest two caucuses in Iowa and Nevada. On top of that, her numbers were buoyed in the territories that held caucuses. But this was a category -- arguably the most closed of the bunch -- Sanders ironically dominated.

Sanders also had a 4:1 advantage in the states where law allowed unaffiliated voters to participate.

But Clinton dominated on either end of the spectrum in both completely closed and open primary states. The former was the true sticking point among the Sanders set as Sanders lone win in a closed primary was in the late calendar Oregon primary. The impetus of the call for change through the Unity Reform Commission, then, are those closed primaries. It is really a call fewer closed primaries or for more openness, not necessarily more open primaries.

2. Obstacles galore
Yes, this differs from what is happening on the Republican side -- the pressure there is in the opposite direction -- but that does not make a full scale change to more open primaries or incentivizing an increase in their number at the state level any more likely.

Why?

The answer lies in the fact that Democrats are in an inferior position relative to their Republican counterparts in state governments across the country. There are a lot of red and yellow stripes across the closed primary states in the map below. Republicans have unified control of more state governments, they control more state legislative chambers and they control more governor's mansions. That may change in the elections in New Jersey and Virginia later this year and/or in 2018, but that will not necessarily be clear when the Unity Reform Commission is making its recommendations (by the beginning of 2018), nor when the Rules and Bylaws Committee (and the DNC later) will finalize the 2020 rules in the late summer of 2018.

Sources: NCSL (participation type, 2017 partisan composition), New York Times (2016 Democratic results)

And even if Democrats improve their position on the state level in 2018, bringing about a change on the openness of the primaries may continue to prove difficult based on the mix of partisan control and local custom on a state by state basis. That circles back around to the Meinke, et al. conclusion above.

There is a reason the Rules Committee stalemate -- delay really -- yielded firmer guidance on the superdelegates question than on either the caucus-to-primary or open primaries questions. It was an issue the national party could more easily dictate. The latter two require some interaction with governments in the various states. And legislative action is just as difficult on the state level as it is in the national capital. It is a heavy lift and on open primaries, one that is political to say the least. Set your expectations accordingly.

Michigan Republicans Vote Down Proposal to Switch to a Closed Caucuses System in 2016

During the Michigan Republican State Central Committee meeting on Saturday, May 9, the big news was the election to fill the state party's national committeewoman position vacated when current Michigan Republican Party chair, Ronna Romney McDaniel, was elected in February 2015. Perhaps more interesting was an effort that had been brewing in the lead up to the meeting to have the state party reverse course, switching to a caucuses/convention process closed to only registered Republican voters.

The State Central Committee voted in support of a resolution endorsing a March 15 presidential primary last fall. The actual move required action from the Michigan state legislature, which the party got earlier this year. However, the outcome in the legislature was a March 8 date. That left Michigan Republicans with an open primary as mandated by state law in the proportionality window as set by the Republican National Committee. That combination was mostly what the Michigan Republican Party wanted. The date was early enough, but will force them to proportionally allocate national convention delegates to presidential candidates based on the results of the primary. The party had last fall settled on a hybrid, winner-take-most system of delegate allocation.

On the openness of the primary -- who can participate -- the Michigan Republican Party has tended to defer to state law. And that calls for an open primary that leaves the door ajar not only to independents participating but also potentially Democrats. It is that latter conflict that partially gave rise to the proposal to restrict participation to just Republican voters. But as there is no effort in the hopper or on the horizon in the Michigan state legislature to close off the primaries to just partisans (voting in their own primary), the only move would have been to switch from an open primary to a closed caucus.

FHQ said "partially" gave rise to the switch push because the effort was supported and advanced by Rand Paul-aligned members of the State Central Committee, notably District 8 Republican Party chair, Tom McMillin. The grassroots organizing of activists that the Ron Paul campaigns have done over the last two presidential election cycles, it has been argued, potentially gives Rand Paul a leg up in caucus states. This is not a new idea. It has been discussed in the context of the probable Kentucky Republican Party switch from a primary to caucuses (though there are other factors driving that switch as well) and the more recent quiet RNC push to trade out caucuses for a primary in carve-out state Nevada.

The former would theoretically help Paul in his home state while the latter would hurt the junior Kentucky senator in a state where his father finished in the top three in 2008 and 2012.

The attempt in Michigan was to make a move similar to that in Kentucky. However, it was just an attempt at the State Central Committee meeting last weekend. The Michigan Republican Party Policy Committee tabled the proposal with no support but did resolve to study closing the process in future election cycles (Again, that decision is only totally in the state party's control if it switches to a caucus in the future or the state legislature changes the law regarding who can participate. Court challenges to the law by the party are also a possibility.).

Yet, that was not the end of the discussion. The issue was also brought to the floor of the State Central Committee meeting a well by McMillin. The discussion there was not all that different from the one in the Policy Committee. On the floor the proposal to close the nomination system needed a two-thirds vote of the 112 member committee, but supporters could muster only a handful of votes and saw the standing vote on the motion fail.

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In the grand scheme of things in this 2016 Republican presidential nomination race, this maneuvering in Michigan will be little more than a footnote. That said, it is indicative of some of the behind-the-scenes efforts made by the possible and announced candidates, their campaigns and proxies on the state level. It is not unusual activity, but keeps popping up in the context of these caucuses versus primaries, pragmatism versus purism discussions within the Republican Party both nationally and in the states over the last handful of years. The extent to which the rules matter ebbs and flows, but political actors perceive them to matter and act accordingly to shape them.

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Connecticut Republicans Strategize About Opening Primaries, Moving Presidential Primary Up

Neil Vigdor has the story at the Connecticut Post about Nutmeg state Republicans' short-term (move the presidential primary)/long-term (open primaries to independents/unaffiliateds) plans.

In Democratic-controlled Connecticut, the state GOP will need some help from across the aisle in the state legislature to make either happen.

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A couple of quickie clarifications on this one:

1. "Until 2008, both parties in Connecticut held their primaries on Super Tuesday, which fell in early February and drew visits from then-U.S. Sen. Barack Obama, D-Ill., and future first lady Michelle Obama."


Connecticut did not join Super Tuesday -- typically the earliest date the national parties allow contests to be held -- until 1996. And then, the primary was on the first Tuesday in March. It stayed there until the 2008 cycle, when the primary was moved to the first Tuesday in February. 2004 was a bit quirky too. Democrats caught up with an RNC that was already allowing February contests, but few states actually moved for 2004. Connecticut, like many states, waited until 2008 to react to that change.


2. "In 2011, looking to create a regional primary with New York, Rhode Island, Pennsylvania and Delaware, the General Assembly ended the tie-in with Super Tuesday. But the inability of the states to get on the same page for setting a date for the proceedings relegated the regional primary to April 24. By that point in 2012, Mitt Romney had all but wrapped up the GOP's nomination."


This sequence is strange. New York, Rhode Island, Pennsylvania and Delaware created a regional primary on April 24 for the 2012 cycle, but could not get on the "same page" to do it? FHQ would argue that four Democratic-controlled states opted to join perpetually-April Pennsylvania on that late April date, and they did it on purpose. Democratic states that were non-compliant under the new 2012 rules moved back much further on the calendar than Republican-controlled states. There may or may not have been ulterior motives involved. 

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New Hampshire Straw Poll To Be Held Saturday

I hope they invite a representative and proportional group of independents to this straw poll to mimic what next year's primary in the Granite state might actually be like.

From the National Journal:

WMUR-TV is partnering with ABC News to conduct a straw poll on Jan. 22 at the state GOP's convention when it elects its new chair. The attendees will be the state party's nearly 493 committee members, which include many of the most important endorsements for the 2012 presidential contenders.

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The Links (12/3/09)

1. Remember the Idaho Republican Party's complaint? Well, they are moving forward with their court case to close their primaries:

By January 15, the Republican Party will present a summary of the evidence it will be presenting at the upcoming trial. This will include a copy of the expert report by one of the party’s witnesses, Michael Munger, who is a professor of political science and an expert in political parties. Then, there will be another status conference on January 26 to set the details for the upcoming trial.

FHQ might try and pull some strings and get a hold of that report if possible.


2. What exactly happened to those Chris Daggett supporters on November 3? David Redlawsk (at the Eagleton Poll) has a go at explaining it.


3. The Democrats got their man in North Carolina to challenge Richard Burr. We'll see how that turns out. They thought they had their man in 2002 with Erskine Bowles. That didn't work out well in 2002.

...or 2004. But FHQ is on the ground here in the Old North state and has a vested interest in a competitive race.


4. Also, notice that State of Elections (the blog of the William and Mary Election Law Society) has been added to FHQ's blogroll. Welcome State of Elections.


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Purity Tests? Not for the NC GOP

There has been a lot of talk about true conservatives (think NY-23) and purity tests within the Republican Party lately. But what's been lost in all of this is a rare -- at least in terms of getting news attention -- instance of pragmatism. Late last week, the North Carolina Republican Party considered a proposal to discontinue allowing independents to vote in the party's primaries.

"Unfortunately there are times when independents are swaying elections to a candidate that is not as conservative as we would like," said Onslow County GOP Chairman Patrick Lamb, identifying moderates as people like John McCain last year and George H.W. Bush in 1988.

"We are not attempting to eliminate independents from the process. We absolutely need them," said Bob Pruett of Beaufort, chairman of the 3rd Congressional District committee, who supports the closed primary idea. "But we want to make sure that we have conservative candidates elected in our primaries."

Compare that sentiment to the line of argument that ultimately prevailed:

"History shows us that the passage of this resolution would not bode well for the goal of a Republican victory in 2010," state party Chairman Tom Fetzer wrote in an e-mail to executive committee members.

"All of us know at least one Conservative Republican – and probably many more – that have switched to Unaffiliated out of frustration with the national or state Republican Party," the three lawmakers [Phil Berger, Paul Stam and Eddie Goodall] wrote. "Are we sending these Conservatives the right message and encouraging them to return to the Republican Party by telling them they cannot participate in a Republican Primary and can only participate in the Democratic Primary?"

Obviously, there was a purist element within the NC GOP pushing this resolution, but they were voted down in the party's executive committee meeting this past weekend. Why? FHQ suspects that state party Chairman Tom Fenty is absolutely correct: with the state legislative elections coming up in 2010, North Carolina Republicans have an opportunity to win both chambers. Limiting the potential base, though, could have affected the calculus for attaining that goal (especially with unaffiliateds in the state growing by leaps and bounds).

Now, why, you may ask, is this any different than what FHQ discussed recently in terms of the Idaho Republican Party's efforts to end the Gem state's open primary -- for much the same reason? Why, indeed? Again, it is up to the state to decide the extent to which its primaries are opened or closed to independent and unaffiliated voters. The state of Idaho, as we highlighted, has allowed not only independents but partisans of the opposite party to participate in primary elections for both major parties over the last nearly four decades. But in North Carolina, the system is slightly different. Technically, the Tarheel state's primaries are closed to independents, but a change to the law in allowed the state parties to decide whether they would invite independents to participate in their primary elections. The North Carolina Republican Party began allowing independents in in 1988 with the Democrats in the state following suit in 1996.

And this not really an issue for the Republican Party in North Carolina to take lightly. The conventional wisdom after the 2008 presidential election was that Obama's organizational efforts during the primaries in North Carolina helped push the president over the top in the Tarheel state in November; turning the state blue for the first time since 1976. Getting independents to vote for you in the primary has the potential to go a long way for a candidate when the general election rolls around. The dynamic, though, has the potential to be different in a midterm election than in a presidential election.

Still, in the battle of pragmatism versus purism with in the Republican Party, pragmatism won out for once.


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Is the Idaho GOP Still After a Closed Primary?

From Ballot Access News:

Idaho is an open primary state and has never had registration by party. On primary day, any Idaho voter is free to choose any party’s primary ballot. Last year, the Idaho Republican Party filed a federal lawsuit, to force the state to give it a closed primary. But on September 4, 2009, U.S. District Court Judge B. Lynn Winmill ruled that the lawsuit requires a trial to determine whether it is true that voters hostile to the Republican Party have been voting in its primary. The Republican Party then said it would soon reveal its plans on how to proceed.

However, the party has not met the informal deadlines for revealing its plans for the trial. The Judge has set a status conference for November 30 to get an updated version of the party’s plans.

This sets off a series of questions. Usually, the courts yield to the parties on free association grounds, but it really is interesting to see how much this differs from state to state. In Idaho, the state Republican Party is demanding that the state government -- also dominated by Republican elected officials -- close the state's primaries. As the party argues, open primaries, like the ones held in Idaho for nearly four decades, potentially allow voters from outside the party to influence Republican nominations which by extension negatively impacts the party's freedom of association.

Why not, indeed?

What's interesting is that the same argument has been made in courts regarding open primaries. This movement in the courts -- at least on this particular question -- began with the 1986 Tashjian case before the Supreme Court. At issue in that instance was the fact that the Republican Party of Connecticut wanted to open up its primaries -- not close them as in the Idaho case -- but was prevented from doing so because of a Connecticut law, on the books since the 1950s, that kept primaries closed.

What did the Court decide?

Well, the Court sided with the Connecticut GOP: the law violated the party's rights to free association; specifically the party's right to invite -- in this case independents -- to vote in its nominating contests.

But this is a moving target, isn't it? Some states like Idaho or California have gone in quite the opposite direction. Faced with open primaries, parties in both the Gem state and the Golden state claimed that their free association rights were being threatened by partisans (and non-partisans, for that matter) of the other party. That the parties were unable to determine who would participate in its nominations was something Antonin Scalia, in the 7-2 opinion of the Court in the California Democratic Party v. Jones case, found to be "both severe and unnecessary."

That brings up an interesting distinction -- and there are several, actually -- between the California case and the one in Idaho. In California, all the major parties sued to have the blanket primary law invalidated. In Idaho, however, it is just the dominant Republican state party that is attempting to tear down the open primary system. The Democratic Party in Idaho could almost be considered a minor party in the state. And they could care less about the law simply because no or very few Republicans are crossing over to vote in the Democratic primaries. To top it off, the Democrats have often eschewed the primary as a means allocating presidential delegates; instead opting for a closed caucus on the state party's dime.

This, however, raises the biggest problem for the Idaho Republican Party in this case: the burden of proof is one the Republican Party. Their argument is that independents and Democrats could have undue influence (read: a moderating influence) on Republican nominations in the state. Proponents of the current open primaries law have simply said, "Prove it." In other words, how have nominations been negatively impacted by the inclusion of Democrats and independents in the process?

That's where this Idaho case is currently. It's stuck with the Idaho Republican Party trying to determine the extent to which Democrats and independents have made Republican nominees any less Republican/conservative. If Idaho Republicans want a closed primary or a closed nomination process, they are either going to have to do what the Democrats have done at the presidential level (Though, truth be told, Democrats in Idaho use a caucus as a means of keeping out Republicans and limiting, through a caucus, who participates and decides how delegates are allocated. See Meinke, et al. (2006) for more.) or just deal with it.

For now, though, it doesn't look like this particular case is going anywhere.

Read more about the Idaho case here and here.


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Could Open Primaries Actually Help the GOP in 2012?

Conservative talk radio host, Hugh Hewitt, had RNC chair, Michael Steele, on his show yesterday and they got into a discussion about the 2012 primaries and the potential for idle Democrats to turn the tables and employ Operation Chaos in the Republican presidential nomination process. Hewitt sees this as a real problem for the GOP in 2012, but I'm not so sure. [In fact, I don't know that these complaints aren't a complete contradiction. But I'll get back to that in a moment.]

First of all, which states even have open primaries or caucuses? In 2008, there were 17 states with an open primary rule on the books and another six states that were semi-open (allowing only Republicans and independents to vote). In the latter category I'm including states like Ohio where the enforcement of the rules that call for voters to vote in the same party's primary as they voted last time are lax.

Well that's about half the country, right? Perhaps Hewitt has a point. Maybe, but we also have to consider when a primary or caucus is being held. Unless the GOP in 2012 is divided in a way similar to the way Democrats were in 2008 (and that's certainly possible), then Super Tuesday is likely to decide who the Republican presidential nominee will be. If, then, a state falls after that point, being opened or closed won't really matter. All that really does is remove Idaho's open primary and the semi-open primary in North Carolina from the equation. I could also strike off Mississippi, Ohio, Rhode Island, Texas and Vermont, but since the most likely outcome of the reform efforts underway in both parties (see posts related to the Democratic Change Commission and the Republican Temporary Delegate Selection Committee for more.) is that the February activity from 2008 gets moved to March in 2012, then those states will be part of a massive group of contests.

That said, what would Democrats need to know to be able to make some noise on the Republican side in 2012? If Democrats with nothing better to do, decided to cross-over and vote in open (or semi-open) primaries, the first bit of information they would need is the identity of the frontrunner. It would also be helpful if said frontrunner was also the Republican candidate seen as the best possible candidate to run against President Obama. Those are the conditions where Democrats-turned-Republican primary voters would have the maximum impact. In essence, they would know who to vote against; just as Republicans cross-overs had the choice of Clinton or Obama in 2008.

The more likely scenario is that there is a nominal frontrunner, making the strategic end of things more difficult for would-be cross-over "Republicans." In other words, the earlier in the process it is, the more likely it would be to have an uncertain outcome. Uncertain outcomes make strategic voting, especially en masse, that much more difficult. Faced with that situation Democrats would either vote for the worst possible candidate, but simultaneously run the risk of having no impact or vote for someone who had a chance of winning the primary contest in question but does the worst against Obama head-to-head.

In the case of the former, envision a scenario where Democrats were idle in 2008 and opted to vote for someone like Duncan Hunter in the New Hampshire primary. I can't see a situation where Democrats outnumbered Republicans in a cross-over vote. The best/worst case scenario (depending upon which side of the aisle you're on) would see Democrats make up approximately 20% of the primary electorate. [Too high? Too low? Sound off in the comments section.]. Even if all those Democrats voted for Hunter, that wouldn't really make much difference. If that figure is layered in with the 2008 New Hampshire primary results, Hunter would have placed third and had no impact. Democrats would have been better served staying home and voting in their own uncontested primary (uncontested in the sense that we are assuming Democrats are crossing over because their nomination battle is either decided or uncontested).*

The alternative would have that faction of Democrats choosing from among the possible winners of the Republican contest, and preferably one who would not do well against their nominee. Let's assume again that Obama was already the Democratic nominee by the time New Hampshire's primary rolled around and that a pick the worst candidate strategy had been eliminated as a possibility for Democrats crossing over. Who do the Democrats vote for? The odd men out among the list of viable candidates at that point were Mike Huckabee and Fred Thompson. McCain, Romney and Giuliani could have attacked Obama from the middle better than either Thompson or Huckabee.**

If that's the case, though, wouldn't either of those two have been palatable to the Hewitt crowd; at least more so than, say, McCain? There appears to be a disconnect between choosing "one of our own" and choosing someone who is electable among this group of Republicans. It is an age-old question, but one that seems unanswered in this case. If the answer is, "we want one of our own" (a social conservative), then holding open primaries really doesn't seem to make that much difference. Democrats would actually help Republicans reach that goal; they'd be better off in the general election for their efforts. If hijacking of the nomination by Democrats is a real concern, then, it isn't because they'd select someone like McCain, but because they'd help select someone who social conservatives like, but couldn't get elected.

[Such a coalition isn't unheard of. African Americans and Republicans across the South have worked together on redistricting plans following the last couple of Censuses. The result was that African Americans got an increased number of majority-minority districts and Republicans got more districts of their own. In the process, Democrats lost representation in Congress which, on its face, was perhaps somewhat counter to the interests of the overwhelmingly Democratic African Americans.]

Just for an open discussion/thought experiment, let's discuss how the 2008 Republican nomination would have played out if Obama ran uncontested and Democratic primary voters behaved rationally, as described above: selecting someone who could win, yet fared the poorest against Obama. Here's the 2008 primary calendar and here are the actual results of the primaries to reference. The comments section awaits.

*For Democrats to vote in the New Hampshire primary, though, they have to register as Republicans ahead of time; not on election day. Plus, another factor here is that if the Democratic race was uncontested, all the independents would flock to the Republican contest. That would advantage McCain.
**The Real Clear Politics averages for all the candidates are only marginally different in hypothetical match-ups against Obama in 2008. Huckabee did worst, but essentially trailed by the same margin as both Giuliani and Romney. McCain did best and Thompson proved difficult to locate.


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