OK, so Hans von Spakovsky's nomination to the Federal Election Commission has left the Senate hopelessly gridlocked, and the FEC crippled. And he packed his bags and left the building months ago. But the man is still keeping busy.

The vote suppression expert has just released his latest call-to-arms on the voter ID front at the Heritage Foundation. It's called "Stolen Identities, Stolen Votes: A Case Study in Voter Impersonation."

In it, Spakovsky takes on those liberal critics who claim that there's no voter fraud (like, say, The New York Times) by unearthing a 1984 grand jury investigation in Brooklyn, NY during which, he says, numerous episodes of voter fraud dating back to 1968 were uncovered.

Just because the case was 24 years ago and no indictments were issued shouldn't give us pause. The point is that it's evidence that fraud does occur. And therefore there's a strong case for requiring ID at the polls. And if the law disproportionately disenfranchises minority voters, I guess that's just collateral damage. The Supreme Court is expected to decide by late June whether Indiana's voter ID law is unconstitutional.

So you can see that Spakovsky is still on the case, though thankfully not still at the Justice Department, where he took a number of steps that had the effect of making it more difficult for minorities to vote. Bush put Spakovsky on the FEC by a recess appointment in December, 2005.

As voting law expert Rick Hasen points out, the piece is a brazen move for a guy who's been accused of being too partisan. Apparently Spakovsky is not holding out for winning Democrats over.

A recent report (pdf) by the Election Assistance Commission's inspector general served as a reminder for why Spakovsky is so controversial. In it, former Commissioner Paul DeGregorio, a Republican who frequently clashed with Spakovsky when he was at the Justice Department, is quoted as saying that "too many of [von Spakovsky's] decisions are clouded by his partisan thinking" and that Spakovsky thought that DeGregorio should use his position to advance the Republican Party's agenda.