Office of Administrative Hearings Public Hearing on Proposed Permanent Rules Relating to Elections Administration
Docket No. 8-9019-39440 (Revisor’s ID R-4824)
October 10, 2025
Good afternoon, Administrative Law Judge Lipman, members of the Office of the Secretary of State, and fellow Minnesotans. My name is Phillip C. Parrish. I am a retired Lieutenant Commander in the U.S. Navy with 21 years of service in counterterrorism and foreign policy, a farmer, and an educator. Today, I testify in strong opposition to the proposed rules under Revisor’s ID R-4824, which amend Minnesota Rules Chapters 8200-8250. These rules, framed as mere “technical clarifications,” are a dangerous evasion of our sacred duty to secure elections. They not only fail to comply with state and federal law—they actively violate it, perpetuating fraud risks that threaten our Constitutional Republic.
Let me be clear: Minnesota’s voter rolls are a ticking bomb—3.6 million registered voters against a 4.2 million voting-age population, riddled with deceased entries, duplicates, post-election ghost additions (over 1,130 in 2024), and non-citizen vulnerabilities. The U.S. Department of Justice’s lawsuit against Secretary of State Steve Simon, filed September 25, 2025, demands full access to these rolls precisely because of NVRA and HAVA violations. Yet these rules do nothing to fix it. Instead, they lock in the status quo, defying the law and inviting exploitation.
First, on voter roll maintenance: The National Voter Registration Act (NVRA, 52 U.S.C. § 20507) mandates “reasonable efforts” to remove ineligible voters through regular cross-checks against sources like SSA death records and Census data. The Help America Vote Act (HAVA, 52 U.S.C. § 21083) requires “current and accurate” statewide lists with proactive audits. Minnesota Statutes § 201.071 echoes this, demanding prompt removals upon reliable evidence. But R-4824’s tweaks to § 201.071—merely clarifying forwarding of misrouted applications—omit any automatic, monthly purges. This breaks NVRA § 8(a)(4) by failing to maintain clean lists, as ruled in U.S. v. Virginia (DOJ NVRA suit, 2020), where courts ordered automated removals to prevent inflation. Without compliance, we’re complicit in the 100.88% “turnout” farce of 2024.
Second, citizenship verification: HAVA § 303(a) requires documentary proof of U.S. citizenship for registrants, reinforced by President Trump’s Executive Order 14,248 and the SAVE Act. Minnesota Statutes § 201.061, subd. 3, governs same-day registration, yet the rules expand unlimited vouching in facilities without verification—opening doors to non-citizen voting amid our 20% foreign-born surge. This violates NVRA § 4’s safeguards against ineligible registration, contravening Supreme Court precedent in Crawford v. Marion County Election Board (553 U.S. 181, 2008), which upheld strict ID to deter fraud. Lax vouching isn’t access—it’s abuse, as seen in July 2025’s guilty pleas for fake forms.
Third, data security and testing: HAVA § 202 demands “adequate safeguards” for computerized lists, including encryption and independent audits. NVRA § 7(d) prohibits foreign interference. But R-4824’s changes to § 206.82 extend public testing notices to five days without banning overseas software like Konnech—exposed in Nevada indictments for CCP ties. This breaches federal law, ignoring GAO reports (2019) on six states’ failures in basic security, and risks hacks like the July 2025 St. Paul ransomware attack that leaked 43 GB of data.
Fourth, training and transparency: Minnesota Statutes § 206.57 expands judge training but skips fraud detection (e.g., multi-state duplicates, ActBlue schemes), violating HAVA’s integrity mandates. § 201.091 “clarifies” notices but blocks public/DOJ access, defying NVRA § 8(c)(2)’s disclosure requirements—as in U.S. v. Louisiana (2020), where courts compelled transparency.
These violations aren’t oversights—they erode trust, disenfranchise citizens, and siphon billions in federal funds via padded headcounts. For 2026, they could rig races, mocking the 14th Amendment and Article IV’s republican form guarantee.
To comply and secure our elections, the rules must be amended as follows:
1. Real-Time Audits: Require monthly cross-checks against SSA, Census, and USCIS databases, with 30-day purges (amend § 201.071)—NVRA/HAVA compliant.
2. Citizenship Proof: Mandate birth certificates, passports, or REAL ID for all registrations; limit vouching to verified citizens (amend § 201.061, subd. 3)—align with SAVE Act and HAVA § 303(a).
3. Secure Systems: Ban foreign software; require U.S.-based encryption and public blockchain logging for changes (update § 206.82)—fulfill HAVA § 202 safeguards.
4. Post-Election Controls: Freeze rolls 30 days pre-election; publish daily change logs (amend § 203B.125)—prevent ghost additions.
5. Enhanced Training: Add modules on fraud detection, whistleblower protections, and penalties for non-reporting (revise § 206.57)—meet HAVA integrity standards.
6. Funding Accountability: Deduct grants for >1% roll inflation; redirect to audits (new under § 201.221)—end grift.
7. Transparency Mandates: Grant anonymized DOJ/public access; issue quarterly accuracy reports (amend § 201.091)—NVRA § 8(c)(2) compliant.
Judge Lipman, reject these rules as proposed. Demand amendments or withdrawal. As a concerned citizen, I urge enforcement of these fixes to protect Minnesota’s elections. Minnesotans, our North Star demands better—fair, secure votes for all. Thank you. I yield my time.
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