This is the preview version of the Wisconsin State Legislature site.
Please see http://docs.legis.wisconsin.gov for the production version.
AR18,11,2320 Administrator Wolfe's cooperation in this scheme was vital for covering the
21Zuckerberg Five Cities clerks. By participating in and facilitating this scheme,
22Administrator Wolfe betrayed the trust of Wisconsin citizens who had entrusted her
23with the position of Administrator of WEC.
AR18,11,25 24Article 8. Administrator Wolfe's Maladministration of Third-Party
25Submission of Absentee Ballot Applications
AR18,12,4
1Administrator Wolfe's actions regarding submitting absentee ballot
2applications by individuals other than the voter, contravening Wisconsin election
3laws, were unlawful. Administrator Wolfe is responsible for the guidance provided
4in the Election Administration Manual for Wisconsin Municipal Clerks.
AR18,12,85 According to the manual, “If an absentee ballot request is delivered by someone
6other than the registered elector (spouse, campaign volunteer, etc.), it is treated as
7a by-mail request." This directive lacked a legal basis, and Administrator Wolfe's
8actions in this regard were unlawful, as outlined in the Teigen case.
AR18,12,149 Wisconsin Statute § 6.86 describes six distinct “methods for obtaining an
10absentee ballot," and § 6.86 (1) (a) 2. specifies the law for submitting an absentee
11ballot application directly to the municipal clerk, stating, “In person at the office of
12the municipal clerk or at an alternate site under s. 6.855, if applicable." Notably, Wis.
13Stat. § 6.86 (1) (a) 2. allows the elector to personally submit their absentee ballot
14application at the clerk's office.
AR18,12,1915 Administrator Wolfe's directive to clerks, permitting a “spouse," “ campaign
16volunteer," or other agents to submit absentee ballot applications on behalf of
17electors, contradicted the plain language of Wis. Stat. § 6.86 (1) (a) 2. Furthermore,
18her treatment of absentee ballot applications submitted by agents as “by-mail"
19requests also conflicted with the statute's language.
AR18,13,220 How Wolfe mishandled the return of absentee ballot applications paralleled her
21maladministration of absentee ballot returns. In the Teigen case, the Wisconsin
22Supreme Court addressed the delivery of absentee ballots and emphasized that
23Wisconsin law did not allow agents or anyone other than the elector to submit an
24elector's absentee ballot directly to a clerk's office. Similarly, Wisconsin law did not

1permit a family member or agent to submit an elector's absentee ballot application
2directly to a clerk's office, as Administrator Wolfe allowed.
AR18,13,113 The court noted that the guidance provided by Administrator Wolfe in the
4March 2020 memo was contrary to Wis. Stat. § 6.87 (4) (b) 1., similar to the situation
5with absentee ballot applications. Wis. Stat. § 6.86 (1) (a) 2. required a
6person-to-person exchange between the elector submitting an absentee ballot
7application and the clerk or the clerk's authorized representative. The court
8reaffirmed that absentee ballots could only be returned through two authorized
9methods: mailing by the voter to the municipal clerk or personal delivery by the voter
10to the municipal clerk. Therefore, Administrator Wolfe's memos advising otherwise
11conflicted with the law and were rightly void.
AR18,13,13 12Article 9. Administrator Wolfe's Inadequate Absentee Ballot Request
13Web Page and Violation of Wisconsin Election Law
AR18,13,1514 Administrator Wolfe's absentee ballot request web page potentially facilitated
15ballot maladministration and contradicts Wisconsin election law requirements.
AR18,13,2316 On July 26, 2022, Harry Wait, the President of HOT Government, made
17absentee ballot requests on behalf of Wisconsin House Speaker Robin Vos, Racine
18Mayor Cory Mason, and several other registered Wisconsin voters. Mr. Wait
19intended to demonstrate the ease with which one person could request absentee
20ballots using the names of other voters without any intention of actually casting
21these ballots. Mr. Wait openly confessed to this practice in emails to various
22authorities, drawing state and national attention to the flaws in the WisVote
23system's absentee ballot mailing process.
AR18,14,424 Wisconsin Statute § 6.86 outlines six “methods for obtaining an absentee
25ballot," all of which require “proof of identification," with a few exceptions. Following

1Mr. Wait's public disclosure of absentee ballot requests on behalf of others, the WEC
2sent confirmation postcards to voters who had requested absentee ballots to new
3addresses. This action by WEC tacitly acknowledges the flaws in the WisVote
4absentee ballot request process.
AR18,14,105 Had Administrator Wolfe mandated that WisVote request proof of
6identification, as required by law, Mr. Wait would not have been able to obtain
7absentee ballots in other people's names, and WEC would not have needed to send
8out confirmation cards. The underlying issue lies in mailing absentee ballots
9without prior proof of identification, which underscores the importance of such
10verification in preventing voter fraud.
AR18,14,1611 WEC currently provides an online form on its web page, allowing voters to
12submit their names, addresses, and birth dates to request an absentee ballot.
13However, Wis. Stat. § 6.86 specifies six methods to obtain an absentee ballot, none
14of which state that WisVote's absentee ballot form is a lawful method for application.
15Wis. Stat. § 6.86 also requires voters to direct their absentee ballot requests to their
16municipal clerk, not WEC.
AR18,14,2417 The Wisconsin Supreme Court has previously ruled that Administrator Wolfe
18lacked the authority to establish a law allowing citizens to use ballot drop boxes to
19return their absentee ballots. Wis. Stat. § 6.86 allows an absent elector to make a
20written application to their municipal clerk for an official ballot but does not grant
21WEC the authority to serve as an intermediary in the absentee ballot application
22process. Administrator Wolfe apparently established WEC's absentee voting
23application method, potentially enabling absentee voters to circumvent Wisconsin's
24proof of identification requirement.
AR18,15,5
1When Mr. Wait submitted absentee ballot requests using others' names, none
2of these requests were legitimate because WEC lacked the legal authority to
3establish the WisVote absentee ballot request form. Consequently, WEC now seeks
4charges against Mr. Wait for conduct made possible only due to Administrator Wolfe's
5maladministration.
AR18,15,7 6Article 10. Administrator Wolfe's Maladministration of Addressing
7Accessibility Issues at Racine's Mobile Polling Place
AR18,15,98 Administrator Wolfe failed to address accessibility concerns at Racine's mobile
9polling place, which was funded by Zuckerberg/CTCL and used in two elections.
AR18,15,1610 On March 24, 2022, members of HOT Government, Sandy Weidner, and Sandra
11Morris, lodged a complaint with the WEC regarding the Racine mobile polling
12location—a converted recreational vehicle (RV) purchased by the city with funding
13from Zuckerberg/CTCL. The complaint highlighted that the RV did not provide full
14accessibility to every disabled person, a requirement mandated by Wis. Stat. § 5.25
15(4) (a), which states that “Each polling place shall be accessible to all individuals with
16disabilities."
AR18,15,2317 In response to the complaint, Racine Clerk Tara Coolidge contended that a bell
18had been placed outside the mobile polling location's door, which could be used by
19voters physically unable to enter the RV. Racine suggested that the bell constituted
20a “reasonable accommodation" for those unable to access the vehicle. However, the
21law governing handicap accessibility at polling places is categorical and cannot be
22met merely by placing a bell outside the entrance. The law explicitly states, “Each
23polling place shall be accessible to all individuals with disabilities."
AR18,16,424 Additionally, WEC requires a Polling Place Accessibility Survey to be
25conducted for each new polling place, a requirement that had not been fulfilled for

1Racine's RV. Upon discovering Racine's failure to submit such a survey,
2Administrator Wolfe committed maladministration by not instructing Racine to
3cease using the mobile polling location until WEC could ascertain whether the
4mobile unit complied with the accessibility requirements, as mandated by law.
AR18,16,105 Despite being aware of the RV's lack of handicap accessibility and the complaint
6filed on March 24, 2022, Administrator Wolfe did not take any action. Administrator
7Wolfe's failure to address this issue allowed Racine to employ its converted
8RV/mobile polling place in two elections for partisan purposes. The RV became a tool
9for partisan politics, favoring certain voters over others and making it easier for the
10preferred voters to cast their ballots.
AR18,16,12 11Article 11. Administrator Wolfe's Maladministration of CTCL Grants
12from the September 2020 Election Preparedness Report
AR18,16,1713 On September 1, 2020, Administrator Wolfe released a 125-page report titled
14“How Wisconsin is Prepared for the November 3, 2020 Election." She compiled this
15report in response to inquiries from legislators and WEC commissioners. While
16preparing this report, Wolfe requested election preparation plans specifically from
17the cities of Green Bay, Madison, and Milwaukee.
AR18,17,518 It is important to note that these three cities, Green Bay, Madison, and
19Milwaukee, held particular significance because they were among the five Wisconsin
20cities that received approximately 86 percent of the substantial funding provided by
21Mark Zuckerberg and the Center for Tech and Civic Life (CTCL) to support the
22administration of Wisconsin's elections. The publicly stated purpose of this funding
23was to safeguard Wisconsin voters from the spread of COVID-19. However, the
24actual allocation of funds, such as Green Bay's use of less than 1 percent for personal
25protective equipment (PPE), raised questions about the true intent behind these

1expenditures. Furthermore, the lack of transparency in the financial reporting of the
2other “Zuckerberg Five" cities has contributed to suspicions that these funds were
3used to promote voter turnout among specific demographic groups favored by
4partisan actors like Mark Zuckerberg, David Plouffe, David Becker, the mayors of
5the “Zuckerberg Five" cities, and the Biden campaign.
AR18,17,116 The central issue with Administrator Wolfe's maladministration of the “How
7Wisconsin is Prepared for the November 3, 2020 Election" report does not revolve
8around its contents but rather its omissions. Rather than disclosing the CTCL
9grants to the legislature, Administrator Wolfe conspicuously removed any references
10to Zuckerberg, CTCL, CTCL grants, CTCL partners, and their employees from her
11report on election preparedness.
AR18,17,1712 During a subsequent Assembly committee hearing, Administrator Wolfe
13claimed that she became aware of the CTCL funding only when a city (though
14unnamed in her statements, it is clearly Green Bay based on her email exchanges)
15submitted an addendum to a report on August 30, 2020. However, this claim does
16not align with the facts, as she had received emails from CTCL and its partners at
17least six weeks before publishing her report on September 1, 2020.
AR18,17,2518 Furthermore, it is highly improbable that Administrator Wolfe remained
19unaware of CTCL's grants until late August, as news of the $6.3 million in CTCL
20grants awarded to the “Zuckerberg Five" cities was widely covered by radio,
21television, and print news sources in early July. For Wolfe to assert that she first
22learned of CTCL's grants after compiling her “How Wisconsin is Prepared for the
23November 3, 2020 Election" report strains credibility. Additionally, she could have
24easily added an addendum regarding CTCL grants to her report after its initial
25submission, following the example set by the City of Green Bay.
AR18,18,3
1Article 12. Administrator Wolfe's Maladministration of Reporting
2CTCL and the “Zuckerberg Five" Clerks for Unauthorized Creation of
3Absentee Voter Instructions
AR18,18,114 Wisconsin Statute § 6.869 clearly stipulates that the WEC is responsible for
5prescribing uniform instructions to be provided by municipalities to absentee
6electors. This statute underscores the importance of standardized absentee voting
7instructions across the state. However, a substantial number of
8emails—approximately 80—reveal communications between CTCL, the Center for
9Civic Design (CCD), the clerks of the “Zuckerberg Five" cities, and Milwaukee
10Election Commission Executive Director Woodall-Vogg regarding the development
11and printing of absentee ballot instructions in both English and Spanish.
AR18,18,1412 The actions taken by municipal election officials to create their own absentee
13ballot instructions stand in violation of Wis. Stat. § 6.869, as the statute exclusively
14grants the authority to WEC to establish uniform absentee voting instructions.
AR18,18,2115 In one email from CTCL's Whitney May, the “Zuckerberg Five" city clerks were
16solicited for their feedback on ballot instructions and envelopes. On August 18, 2020,
17Administrator Wolfe updated Uniform Instructions for Absentee Voters. In this
18communication, Wolfe made it explicitly clear that these instructions would be
19utilized for all absentee voters, commencing with the absentee ballots that clerks
20would send out for the November 3rd General Election, following WEC's directive,
21which is evident maladministration.
AR18,19,622 On the very same day that Wolfe disseminated her uniform instructions for
23absentee voters, CTCL's Whitney May corresponded with the clerks of the
24“Zuckerberg Five" cities. May's email indicated CTCL's intention to halt an
25operation due to WEC's desire for statewide conformity in format and their plans to

1embark on new envelope design work in the following year. This communication
2raises questions regarding how May was privy to WEC's intentions and the fact that
3they were supplying uniform absentee ballot instructions. Notably, May's email did
4not mention that the creation of their own absentee ballot instructions by CTCL,
5CCD, and the clerks of the “Zuckerberg Five" cities potentially violated Wis. Stat. §
66.869.
AR18,19,157 In an additional incident, Madison Clerk Maribeth Witzel-Behl sent an email
8on September 17, 2020, to Whitney May and the other clerks of the “Zuckerberg
9Five," including an attachment containing Spanish-language absentee ballot
10instructions. It's imperative to note that Wis. Stat. § 6.869 does not differentiate
11between English and Spanish absentee ballot instructions; it unequivocally states
12that the commission shall prescribe uniform instructions for municipalities to
13provide to absentee electors. Wolfe's memo from August 18, 2020, left no room for
14ambiguity—it mandated the use of uniform absentee ballot instructions for absentee
15voters, which should be applied regardless of language.
AR18,19,1916 The discrepancy between Wolfe's memo and Witzel-Behl's actions, sending
17Spanish absentee ballot instructions, necessitates an investigation into whether any
18of the “Zuckerberg Five" cities distributed their versions of absentee ballot
19instructions in Spanish, potentially contravening Wis. Stat. § 6.869.
AR18,20,220 This situation exemplifies how CTCL and its partners influenced Wisconsin
21election officials leading up to the 2020 election. Even though the “Zuckerberg Five"
22clerks ultimately did not send out their versions of absentee ballot instructions, the
23act of creating them likely violated state law. What is certain is that Administrator
24Wolfe did not hold CTCL, CCD, the “Zuckerberg Five" clerks, or Milwaukee Election

1Commission's Claire Woodall-Vogg accountable for producing their own absentee
2ballot instructions in apparent violation of Wis. Stat. § 6.869.
AR18,20,5 3Article 13. Administrator Wolfe's Maladministration in Establishing a
4Systematic Program for the Removal of Incompetent Individuals from the
5Voter Roll
AR18,20,136 Wisconsin law dictates that individuals whose voting rights have been legally
7terminated by a court due to incompetence are ineligible to vote. However, this legal
8provision is not self-executing. To ensure the proper functioning of this process, it
9is incumbent upon the Administrator of the WEC to institute a system that enables
10municipal clerks to promptly identify cases of adjudication for incompetence,
11allowing for the removal of the affected individuals from the voter roll. Establishing
12and maintaining such a system is a legal obligation that falls within the purview of
13the Administrator's role.
AR18,20,1914 In the maladministration of the Administrator's fulfillment of this duty, there
15exists a substantial risk that the legislative intent to exclude from the voter roll those
16individuals who have been declared incompetent to vote will remain unfulfilled.
17Administrator Wolfe's failure to initiate and sustain such a system represents a
18significant deficiency in her execution of one of the fundamental responsibilities
19inherent in her position.
AR18,20,21 20Article 14. Administrator Wolfe's Unlawful Failure to Remove Names
21from the Wisconsin Voter Roll
AR18,21,222 In Wisconsin, the law distinguishes between two categories of voters: “eligible"
23and “ineligible." “Eligible" voters are those who meet the qualifications to register
24and have their names placed on the voter roll, while “ineligible" voters are not
25permitted to be listed on this roll. These designations are consistent with the

1statutes' language and align with the legislative intent and the reasonable
2expectations of Wisconsin's citizens.
AR18,21,113 Regrettably, Administrator Wolfe has initiated maladministration with a
4systematic replacement of “eligible” and “ineligible” with “active" and “inactive."
5These non-statutory designations, although seemingly harmless, have resulted in
6consequences that have compromised both the integrity and the public trust in our
7voter roll. Under Administrator Wolfe's leadership, names are never removed from
8the voter roll, even in cases of individuals who have passed away. Rather than
9designating these deceased individuals as “ineligible" voters, as the statute would
10dictate, Administrator Wolfe categorizes them as “inactive" voters, allowing their
11names to persist on the voter roll.
AR18,21,1612 One of Administrator Wolfe's past justifications for this practice was a reference
13to HAVA (Help America Vote Act), which requires states to maintain historical
14records of all those who have voted. However, her explanation lacks completeness,
15as there is no requirement to retain the names of deceased “historical" voters on the
16voter roll.
AR18,21,2417 At best, this practice of retaining deceased individuals on the voter roll
18needlessly complicates the list, making it more challenging for auditors and others
19interested in assessing its accuracy. At worst, it provides a reservoir of names that
20can be “activated" two weeks before an election and “deactivated" two weeks after,
21by anyone with access to the WisVote system. This process operates in a manner that
22conceals the identities of both the “activator" and the “deactivator." Consequently,
23it fosters suspicions of potential fraud or, at the very least, creates a fertile ground
24for such suspicions.
AR18,22,3
1In sum, Administrator Wolfe's oversight of this problematic system is
2unacceptable to the people of Wisconsin and raises serious concerns about the
3integrity of our voter roll.
AR18,22,5 4Article 15. Administrator Wolfe's Promotion of an Unlawful Voter
5Registration Form
AR18,22,166 On September 5, 2023, the Circuit Court for Waukesha County, presided over
7by the Honorable Michael P. Maxwell, issued a summary judgment in favor of a
8concerned citizen who contested the use of the WEC's voter registration form. The
9court's decision was based on two primary grounds: firstly, that the form did not
10conform to state law requirements, and secondly, that WEC had never engaged in the
11statutory rule-making process of the additional information requested on the form,
12which was not mandated by Wisconsin law. Throughout this relevant period, it
13remains undisputed that Administrator Wolfe actively promoted this
14maladministration and encouraged clerks to accept it. Administrator Wolfe was
15likely aware and should have certainly been aware, that the disputed form solicited
16more information from citizens than what was authorized by Wisconsin law.
AR18,22,2217 As emphasized by the Circuit Court, “WEC was granted authority by the State
18Legislature to administer Wisconsin's election laws and was subsequently tasked
19with using that authority to prescribe the voter registration forms permissible for
20use in our state. WEC, however, has failed in this fundamental duty by permitting
21the use of the National Form in Wisconsin, despite never officially prescribing its
22use."
AR18,23,323 Administrator Wolfe, in her capacity as Wisconsin's “chief elections official,"
24has exhibited reluctance or incapacity to fulfill this fundamental responsibility,
25much like several others detailed herein. Her mismanagement of WEC has

1transformed the agency into one requiring substantial reform or, possibly,
2dissolution, as was the case with its predecessor, GAB. The crucial initial step
3toward achieving either goal is the impeachment of Administrator Wolfe.
AR18,23,7 4Resolved by the assembly, That per Article VII, section 1, of the Wisconsin
5Constitution and Wis. Stat. § 17.06 (1), the Assembly hereby initiates proceedings
6for the impeachment of Meagan Wolfe, the Administrator of the Wisconsin Elections
7Commission, based on allegations of maladministration in office.
AR18,23,88 (End)
Loading...
Loading...