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    2014 Washington and Sacramento Political Forecast 2014 Washington and Sacramento Political Forecast Presentation Transcript

    • CLE Seminar for In-House Counsel January 7, 2014 Beverly Hills, CA UNDERSTAND CAMPAIGNS AND YOU'LL UNDERSTAND THE LEGISLATIVE AGENDA Darry Sragow Partner, Los Angeles Dentons US LLP 213 892 2925 darry.sragow@dentons.com John Russell, IV Principal, Washington, D.C. Dentons US LLP 202 408 6392 john.russell@dentons.com
    • Global presence Jan 7 2014 Dentons US LLP 2
    • Roadmap for the Presentation 2014 Atmospherics -- 5 to Watch Senate Elections: 2014 and Beyond 2014 House Elections Legislative Outlook Jan 7 2014 Dentons US LLP 3
    • Here is what matters on November 11th Presidential Job Approval Ratings Consumer Confidence Public Attitudes Towards ACA Democratic and Republican Party Favorability Ratings Generic Congressional Ballot Test Jan 7 2014 Dentons US LLP 4
    • The Second-Term Jinx Presidents tend to run into trouble during their second terms The President’s Second-Term Jinx Second-term pitfalls among presidents President Pitfall G.W. Bush Iraq War Clinton Lewinsky Scandal Reagan Iran Contra Scandal Nixon/Ford Watergate Scandal/Impeachment/Pardon Kennedy/Johnson Vietnam War Eisenhower Recessions in 1958 and 1960 Analysis • The novelty is wearing off, energy is waning, administration is running out of fresh ideas, and the A-team from the first term has largely moved on • In the past, recessions, scandals, and wars have plagued second-term Presidents—this second term appears to be no exception • In years 5 through 8, voters often become increasingly open to the idea of change Source: National Journal Research, 2013. Jan 7 2014 Dentons US LLP 5
    • The Six-Year Itch The president’s party fares poorly in second-term midterm elections The President’s Second-Term Jinx Change in congressional party makeup after midterm elections during president’s second term Year President Party Pres. Party Seat Change: House Pres. Party Seat Change: Senate 2006 G.W. Bush Republican -30 -6 1998 Clinton Democrat +5 0 1986 Reagan Republican -5 -8 1974 Nixon/Ford Republican -48 -4 1966 Kennedy/Johnson Democrat -48 -4 1958 Eisenhower Republican -48 -12 -29 -6 Average Analysis The President‟s party has been hammered in the House and/or Senate in five of the last six “six-year itch” elections since World War II Source: 2008 Vital Statistics on Congress. Jan 7 2014 Dentons US LLP 6
    • Presidential Job Approval: Gallup Polling I. Presidential Job Approval Ratings Gallup Weekly Presidential Approval Tracking: 2013 Year to Date Source: Gallup Presidential Approval Center, November 18, 2013. Jan 7 2014 Dentons US LLP 7
    • Presidential Job Approval: Other Polls to Watch I. Presidential Job Approval Ratings Approve ABC News/ Washington Post Disapprove Fox News 11/14-11/17 (1006 Adults) 11/10-11/12 (1006 Registered Voters) 10/17-10/20 (1002 Adults) 10/20-10/22 (1020 Registered Voters) CBS News/ New York Times NBC News/ Wall Street Journal 10/25-10/28 (800 Adults) 11/15-11/18 (1010 Adults) 10/18-10/21 (1007 Adults) 9/5-9/8 (1000 Adults) CNN/ORC Pew Research 11/18-11/20 (843 Adults) 10/30-11/6 (1605 Registered Voters) 9/6-9/8 (1022 Adults) 9/4-9/8 (1201 Registered Voters)** ** With USA Today Jan 7 2014 Dentons US LLP 8
    • The Economy: Consumer Confidence II. Consumer Confidence Consumer Confidence and Consumer Sentiment Current Consumer Sentiment level (Nov. „13): 75.10 Current Consumer Confidence (Nov. „13): 70.4 Source: Conference Board, November 26, 2013; Thomson Reuters/University of Michigan Surveys of Consumers, November 27, 2013. Jan 7 2014 Dentons US LLP 9
    • ACA: Tracking Public Attitudes III. Public Attitudes Towards ACA The Kaiser Family Foundation Health Tracking Poll “As you may know, a health reform bill was signed into law in 2010. Given what you know about the health reform law, do you have a generally (favorable) or generally (unfavorable) opinion of it?” (Rotated - Participants then asked to choose between very/somewhat favorable/unfavorable) Current Levels Total favorable: 33% Total unfavorable: 49% Net favorability: -16% Source: Henry J. Kaiser Family Foundation, Kaiser Health Tracking Poll, November 2013. Jan 7 2014 Dentons US LLP 10
    • ACA: Tracking Public Attitudes III. Public Attitudes Towards ACA The Kaiser Family Foundation Health Tracking Poll “Do you think the nation as a whole will be (better off) or (worse off) under the health reform law, or don’t you think it will make much difference? (options rotated) Net favorability: -9% Source: Henry J. Kaiser Family Foundation, Kaiser Health Tracking Poll, November 2013. Jan 7 2014 Dentons US LLP 11
    • ACA: Tracking Public Attitudes III. Public Attitudes Towards ACA The Kaiser Family Foundation Health Tracking Poll “Do you think you and your family will be (better off) or (worse off) under the health reform law, or don’t you think it will make much difference?” (options rotated) Net : -12% Source: Henry J. Kaiser Family Foundation, Kaiser Health Tracking Poll, November 2013. Jan 7 2014 Dentons US LLP 12
    • Democratic and Republican Party Favorability Ratings IV. Democratic and Republican Party Favorability Ratings Democratic Party % Favorable ABC News/ Washington Post 10/17-10/20 2013 (1002 Adults) 9/26-9/30 2012 (1024 Adults) Republican Party % Unfavorable 46% 32% 49% 39% CBS News/ New York Times 3/20-24 2013 (1181Adults) 2/6-2/10 2013 (1148 Adults) CNN/ORC 9/27-9/29 2013 (803 Adults) 62% 5/17-5/18 2013 (923 Adults) Jan 7 2014 Dentons US LLP 13
    • Democratic and Republican Party Favorability Ratings (Cont’d) IV. Democratic and Republican Party Favorability Ratings Democratic Party % Favorable Republican Party % Unfavorable Pew Research 10/9-13 2013 (1504 Adults) 7/17-21 2013 Jan 7 2014 Dentons US LLP 14
    • Democrats vs. Republicans: The Generic Ballot V. General Congressional Ballot Test Democratic Party ABC News/ Washington Post Republican Party Fox News 10/17-20 2013 (1002 Registered Voters) 5/16-19 2013 (Registered Voters) 11/10-12 2013 (1006 Registered Voters) 10/20-22 2013 (1020 Registered Voters) CBS News/ New York Times Gallup 10/25-28 2012 (563 Likely Voters) 10/22-26 2010 (Likely Voters) 11/1-4 2012 (2551 Likely Voters) 9/24-27 2012 (1301 Registered Voters) CNN/ORC NBC News/Wall Street Journal 10/18-20 2013 (841 Registered Voters) 11/2-4 2012 (Registered Voters) Jan 7 2014 10/25-28 2013 (800 Registered Voters) 10/7-9 2013 (Registered Voters) Dentons US LLP 15
    • Roadmap for the Presentation Senate Elections: 2014 and Beyond 2014 House Elections 2014 Gubernatorial Elections Jan 7 2014 Dentons US LLP 16
    • Current Senate Breakdown Senate Elections: 2014 and Beyond Number of Senate seats in the 113th Congress, by party 50 Analysis In 2014, Democrats will be playing defense to protect their hold on the Senate * Includes two Independents, Angus King (I-Maine) and Bernie Sanders (I-Vt.), who caucus with the Dems Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 17
    • Dems, Republicans Will Take Turns Playing Defense in Midterms Ahead Senate Elections: 2014 and Beyond Senate seats in play, by election year Democrats over-exposed Republicans over-exposed Democrats over-exposed Source: Cook Political Report. Jan 7 2014 Dentons US LLP 18
    • 2014 Senate Races by 2012 Presidential Performance Senate Elections: 2014 and Beyond Senators running in 2014 by 2012 presidential performance (Obama vs. Romney) Obama + 15 or Greater Obama +5 to +14.9 Obama +4.9 to Romney +4.9 Romney +5 to +14.9 Romney +15 or Greater DEMOCRATS (21) Coons (DE) +19 Schatz (HI) +43 Durbin (IL) +17 Markey (MA) +23 Reed (RI) +27 Booker (NJ) +17 M. Udall (CO) +5 Harkin* (IA) +6 Levin (MI) +10 Franken (MN) +8 Shaheen (NH) +6 T. Udall (NM) +10 Merkley (OR) +12 Hagan (NC) R+2 Warner (VA) D+4 Begich (AK) +14 Baucus* (MT) +14 Pryor (AR) +24 Landrieu (LA) +17 Johnson* (SD) +18 Rockefeller* (WV) +27 Chambless* (GA) +8 Cochran (MS) +12 Graham (SC) +10 Scott (SC) +10 Sessions (AL) +22 Risch (ID) +32 Roberts (KS) +22 McConnell (KY) +23 Johanns* (NE) +22 Inhofe (OK) +34 Alexander (TN) +20 Cornyn (TX) +16 Enzi (WY) +41 REPUBLICANS (14) Collins (ME) +15 * Senator seat is open Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 19
    • Dem Seats On the Ballot in a Range of LeftLeaning Districts Senate Elections: 2014 and Beyond Breakdown of Democratic-held seats by Cook Political Report Rating 21 total Democratic seats Coons (DE) D+8 Durbin (IL) D+8 Udall (NM) D+4 Merkley (OR) D+5 Reed (RI) D+11 Warner (VA) EVEN Booker (NJ) D+6 Udall (CO) D+1 Schatz (HI) D+20 Shaheen (NH) D+1 Markey (MA) D+10 Franken (MN) D+2 Begich (AK) R+12 Harkin* (IA) D+1 Landrieu (LA) R+12 Levin* (MI) D+4 Hagan (NC) R+3 Pryor (AR) R+14 Note: Sens. Baucus (DMT), Rockefeller (D-WV), and Johnson (D-SD) hold seats * Senator is retiring ** Potential retirement currently rated Lean/Likely Note: A Cook Political Report rating of Lean D/R or Toss Up denotes races that are currently considered to be competitive Republican. Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 20
    • Most GOP Seats On the Ballot in GOP Strongholds Senate Elections: 2014 and Beyond Breakdown of Republican-held seats by Cook Political Report Rating 14 total Republican seats Sessions (AL) R+14 Risch (ID) R+18 Roberts (KS) R+12 Cochran** (MS) R+9 Johanns* (NE) R+12 Inhofe (OK) R+19 Graham (SC) R+8 Alexander (TN) R+12 Cornyn (TX) R+10 Enzi (WY) R+22 Scott (SC) R+7.8 Collins (ME) D+6 Chambliss* (GA) R+6 McConnell (KY) R+13 * Senator is retiring ** Potential retirement Note: A Cook Political Report rating of Lean D/R or Toss Up denotes races that are currently considered to be competitive Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 21
    • 2014 Senate Race Vulnerabilities Senate Elections: 2014 and Beyond Breakdown of all Senate seats by Cook Political Report Rating 35 total seats Democrat-held seats (21) Republican-held seats (14) 7 5 5 1 (Pryor, AR) 2 (Rockefeller, WV; Baucus, MT) 1 (McConnell, KY) 1 1 (Johnson, SD) 12 Note: A Cook Political Report rating of Lean D/R or Toss Up denotes races that are currently considered to be competitive Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 22
    • Senate Republicans Primaries to watch Jan 7 2014 Dentons US LLP 23
    • The Senate’s Incredible Shrinking Swing Seat Senate Elections: 2014 and Beyond Number of Senate seats by State Partisan Voter Index, 1994-2014 Republican (R+5 or Greater) Swing (D+5 to R+5) Democratic (D+5 or Greater) 70 60 58 52 50 44 40 38 38 46 40 40 30 32 30 28 22 20 10 34 22 2002 2006 22 26 16 12 0 1994 1998 2010 2014 Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 24
    • Roadmap for the Presentation 2014 House Elections Legislative Outlook Jan 7 2014 Dentons US LLP 25
    • Current House Breakdown 2014 House Elections Number of House seats in the 113th Congress, by party* Analysis Democrats need a 17-seat gain to win control of the House in 2014 * Includes two currently vacant Republican seats and one currently vacant Democratic seat Source: Cook Political Report. Jan 7 2014 Dentons US LLP 26
    • Only 74 Competitive or Potentially Competitive Seats in the House in 2014 2014 House Elections Number of House seats in the 113th Congress, by party 218 Only 74 seats currently competitive or potentially competitive Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 27
    • Most House Midterms in Friendly Territory 2014 House Elections 2014 House races by 2012 presidential performance (Obama vs. Romney) Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 28
    • 24 of 201 Democratic Seats in Serious Danger, 15 More Potentially Competitive 2014 House Elections Breakdown of competitive Democratic-held districts by Cook Political Report Rating 39 total competitive or potentially competitive Democratic districts Garamendi (CA-03) D+3 McNerney (CA-09) D+6 Costa (CA-16) D+7 Capps (CA-24) D+4 Esty (CT-05) D+3 Duckworth (IL-08) D+8 Foster (IL-11) D+8 OPEN (IA-01) D+5 Walz (MN-01) R+1 Peterson (MN-07) R+6 Horsford (NV-04) D+4 Schrader (OR-05) EVEN Kuster (NH-02) D+3 Maffei (NY-24) D+5 DelBene (WA-01) D+4 Sinema (AZ-09) R+1 Brownley (CA-26) D+4 Miller (CA-31) D+5* Barrow (GA-12) R+9 Enyart (IL-12) EVEN Bustos (IL-17) D+7 OPEN (ME-02) D+2 Tierney (MA-06) D+4 Nolan (MN-08) D+1 Bishop (NY-01) R+2 Maloney (NY-18) EVEN Owens (NY-21) EVEN McIntyre (NC-07) R+12 Gallego (TX-23) R+3 Matheson (UT-04) R+16 Kirkpatrick (AZ-01) R+4 Barber (AZ-02) R+3 Bera (CA-07) EVEN Ruiz (CA-36) R+1 Peters (CA-52) D+2 Murphy (FL-18) R+3 Garcia (FL-26) R+1 Schneider (IL-10) D+8 Shea-Porter (NH-01) R+1 Rahall (WV-03) R+14 * Bolded name denotes opposing party’s seat Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 29
    • 20 of 234 Republican Seats in Danger, 15 More Potentially Competitive 2014 House Elections Breakdown of competitive Republican-held districts by Cook Political Report Rating 35 total competitive Republican districts Denham (CA-10) R+1 Webster (FL-10) R+6 Latham (IA-03) EVEN King (IA-04) R+5 Barr (KY-06) R+9 Amash (MI-07) R+4 Bentivolio (MI-11) R+4 Kline (MN-02) R+2 Daines (MT-AL) R+7 LoBiondo (NJ-02) D+1 Runyan (NJ-03) R+1 Pearce (NM-02) R+5 Meehan (PA-07) R+2 Rigell (VA-02) R+2 Duffy (WI-07) R+2 OPEN (AR-04) R+15 OPEN (AR-02) R+8 Valadao (CA-21) D+2 Southerland (FL-02) R+6 Davis (IL-13) EVEN Walorski (IN-02) R+6 Benishek (MI-01) R+5 Walberg (MI-07) R+3 Terry (NE-02) R+4 Heck (NV-03) EVEN Grimm (NY-11) R+2 Gibson (NY-19) D+1 Reed (NY-23) R+3 Johnson (OH-06) R+8 Joyce (OH-14) R+4 Fitzpatrick (PA-08) R+1 OPEN (WV-02) R+11 Coffman (CO-06) D+1 OPEN (FL-13) R+2 OPEN (NJ-03) R+1 * Miller (CA-31) is rated in the Lean D column Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 30
    • 2014 House Race Vulnerabilities 2014 House Elections Breakdown of competitive* House seats by Cook Political Report Rating 74 total competitive seats Democrat-held seats (39) Republican-held seats (35) 15 14 1 10 3 16 15 * A Cook Political Report rating of Lean D/R or Toss Up denotes races that are currently considered to be competitive; the 199 Republican seats and 162 Democratic seats which do not appear on these charts are rated Solid Republican and Solid Democratic, respectively, and are not considered to be competitive by the Cook Political Report at this time. Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 31
    • The House’s Incredible Shrinking Swing Seat 2014 House Elections Number of House seats by Partisan Voting Index of district Democratic (D+5 or Greater) Swing (D+5 to R+5) Republican (R+5 or Greater) 200 190 180 179 175 164 160 182 180 186 182 162 159 149 148 148 150 147 150 146 139 140 134 120 123 111 108 108 103 103 100 99 90 80 1998 2000 2002 2004 2006 2008 2010 2012 2014 Note: “Swing” districts are defined as having an average presidential vote margin over the last two elections within five points of the national average Source: Cook Political Report. Jan 7 2014 Dentons US LLP 32
    • 2014 Midterm Elections: All Seats in Play, by Party 65 35 14 21 Current outlook: At this early stage, the odds of Democrats losing seats are far greater than the odds of them gaining seats. Senate House All seats in play, but 74 considered competitive or potentially competitive 361 74 35 39 Governors 14 36 22 14 Current outlook: The current House breakdown is 232 Republicans, 200 Democrats, and three vacancies (two Republican and one Democratic). Democrats need a net gain of 17 seats to reach a majority in 2014. Because the House is well sorted-out, large shifts or a change in partisan control of the House are unlikely. If the election were held today, we would estimate a Republican gain of between zero and 10 seats. However, if House Republicans choose to pursue unpopular strategies similar to those that led to the October 2013 government shutdown, Democratic gains are possible. Current outlook: At this point in the cycle, it appears that Republicans are more likely to lose seats than gain them. Source: The Cook Political Report. Jan 7 2014 Dentons US LLP 33
    • Roadmap for the Presentation The President‟s Second-Term Jinx Senate Elections: 2014 and Beyond 2014 House Elections Legislative Outlook Jan 7 2014 Dentons US LLP 34
    • Legislative Outlook FOUR TRUTHS • THE LAST 20 YEARS HAVE SEEN NARROW MARGINS FOR THE MAJORITY PARTY • THESE MARGINS HAVE LEAD TO THE POLARIZATION WE NOW FACE • THIS POLARIZATION IS "HARDWIRED" INTO THE SYSTEM BY STATE LEVEL REDISTRICTING AND IS UNLIKELY TO CHANGE FOR 3 MORE CONGRESSES • BARRING A NATIONAL EVENT DIVIDED GOVERNMENT PRODUCES MODEST LEGISLATIVE ACHIEVEMENTS Jan 7 2014 Dentons US LLP 35
    • Legislative Outlook • HOUSE PASSED BUDGET DEAL SPEAKS TO THE SMALL BITES LEGISLATORS CAN SWALLOW. THESE BITES GET SMALLER AS PRIMARY AND GENERAL ELECTIONS TAKE ROOT • APPROPRIATIONS, FOR THE FIRST TIME IN REASONABLE MEMORY HAS A TOPLINE SPENDING NUMBER FROM WHICH TO WORK • APPRECIATE THE 'WEDGE ISSUE" IN AN ELECTION YEAR, YOU'LL SEE A LOT OF IT Jan 7 2014 Dentons US LLP 36
    • The Joy of California Politics: Our Shifting Political Terrain
    • Diminishing Support for the Two Major Parties Registration By Party DEM 44 43 47 REP 29 34 35 DTS/NPP 21 18 13 OTHER 6 5 5 Dentons US LLP 38
    • Restoring Competition • California Citizens Redistricting Commission Prop 11 Prop 20 2008 2010 • Top Two Primary Prop 14 2010 • Modified Term Limits for Legislature Dentons US LLP 39
    • Can the Republican Party Compete in California? Profile of Likely Voters ALL DEM REP IND OTHER - 45 32 19 5 WHITE 62 49 81 58 75 LATINO 17 25 9 15 10 ASIAN 11 12 7 17 4 BLACK 7 12 1 5 3 OTHER 3 3 3 5 9 ALL Dentons US LLP 40
    • Possible Initiatives (In Circulation) • Used Cars • Guns • Voter ID • Abortion • Cigarette Tax • Marijuana Legalization • Schools • Increase MICRA Cap, Drug Test Doctors • Protect Personally Identifying Information • Nuclear Power Dentons US LLP 41
    • Possible Initiatives (Awaiting Title & Summary) • Hospital Executive Compensation • Government Pension Reform • Road Repair Tax • Home Health Care Worker Wages • Marijuana Legalization • Death Penalty • Charter Schools Dentons US LLP 42
    • California Outlook • All 8 state executive offices are up for election, as well as the 20 evennumbered state senate seats, all 80 state assembly seats, and all 4 Board of Equalization seats, making 115 elections in total. • High (relatively high, at least) approval ratings for current government performance boost Democratic chances. Jerry Brown, the wizened face of California resurgence and leadership, most likely gains more from this than anyone else. Democrats have mostly been responsible in governance, cognizant of the fact that they have to defy undeserved stereotypes and doomsday predictions. They have hewed to a moderately progressive line and refused to raise taxes despite having the votes to do so. To most people, that's good enough Jan 7 2014 Dentons US LLP 43
    • California Outlook cont. • The Democratic state party machine has to show that it is more robust than ever before. In the red tidal wave of 2010 that washed over everywhere else, we managed to hold the line and keep all our seats, even gaining one in the state assembly. That is a high bar that we have set for ourselves. • The California Republican Party is still weak and rudderless. The party establishment is still very much in charge, as Tea Party activists and Paulists have yet to gain sufficient traction in the state GOP to take over the apparatus. However, they haven't quite learned how to compete in a state that is much more liberal than they are used to. They also have a very weak bench, decimated by demographics and desertion. Jan 7 2014 Dentons US LLP 44
    • Governor • 2010 results: 53.8% Jerry Brown (D), 40.9% Meg Whitman (R) Major candidates: Jerry Brown (D), Tim Donnelly (R), Abel Maldonado (R), George Radanovich (R) • Realistically, the only major candidate is Brown. Former lieutenant governor Abel Maldonado is the establishment favorite, but he's as inspiring as used tissue. State assemblyman and former Minuteman militia founder Tim Donnelly is a Tea Party favorite, but that's a political death sentence in California. No one knows who George Radanovich is. At this rate, Brown may win Orange County again. Jan 7 2014 Dentons US LLP 45
    • State Assembly Safe Dem Likely Dem Lean Dem Tossup Lean GOP Likely GOP Safe GOP 2*, 4*, 7*, 9*, 10, 11, 13, 14, 15*, 16*, 17*, 18, 19, 20, 22, 24, 25*, 27, 28*, 29, 30, 31, 37, 39, 41, 43, 45, 46, 47, 48, 49, 50, 51, 52, 53*, 54, 56*, 57, 58, 59, 61, 62*, 63, 64*, 69, 70*, 78, 79, 80 Dentons US LLP 32, 65 36, 40 60 44 49 ADs Jan 7 2014 8, 21, 66 1, 3*, 5, 6, 12, 23, 26*, 33*, 34, 35, 38, 42*, 55*, 67, 68, 71, 72, 73*, 74, 75, 76, 77 3 ADs 2 ADs 2 ADs 1 AD 1 AD 22 ADs 46
    • State Senate Safe Dem Likely Dem 2*, 6*, 10*, 18*, 20*, 22, 24, 26, 30, 32*, 40 11 SDs Lean Dem Tossup 14, 34* 0 SDs 2 SDs Lean GOP Likely GOP 4, 8, 1 6, 28*, 36 *, 38 12 0 SDs 1 SD 0 SDs 15 incumb ent Dem 26 SDs Jan 7 2014 Dentons US LLP Safe GOP 6 SDs 5 incumb ent GOP 0 SDs 2 SDs 0 SDs 1 SD 0 SDs 47 11 SDs
    • QUESTIONS? Jan 7 2014 Dentons US LLP 48
    • Thank you Dentons US LLP 1301 K Street, NW Suite 600 Washington, District of Columbia 20005-3364 USA © 2013 Dentons. Dentons is a global legal practice providing client services worldwide through its member firms and affiliates. This publication is not designed to provide legal or other advice and you should not take, or refrain from taking, action based on its content. Dentons US LLP. Please see dentons.com for Legal Notices.