Post-election On November 8, 2016, Trump won the 2016 United States presidential election, but lost the popular vote to opponent Hillary Clinton by about 2.9 million votes. Trump falsely claimed that he won the popular vote "if you deduct the millions of people who voted illegally" and that three to five million people voted illegally in the 2016 election. Kris Kobach proposal On November 22, 2016, Kobach met with then President-elect Trump in his Trump National Golf Club in Bedminster, New Jersey in consideration for Secretary of Homeland Security position. The Associated Press photographed Kobach taking into his meeting with Trump a document entitled "Department of Homeland Security, Kobach Strategic Plan for First 365 Days" referencing a possible amendment to the National Voter Registration Act of 1993. The American Civil Liberties Union, representing plaintiffs in a voting rights case, asked the federal judge to prevent Kobach from withholding from the public documents he presented to Trump by virtue of marking them "confidential". The plaintiffs demanded the public release of those documents that had been prepared with state funds, claiming Kobach "made statements to the public, the Court, and the President, suggesting that noncitizen registration fraud is a serious, widespread problem," while at the same time trying to hide those same documents that reject his claim, to prevent having to testify in open court about those materials. In June 2017, the federal magistrate judge found that Kobach had made "patently misleading representations" to the court in the course of the document dispute. Kobach was fined $1,000 for "deceptive conduct and lack of candor" and ordered to submit to questioning under oath by the ACLU about the documents and about a draft amendment to the National Voter Registration Act "which would have added a line to the federal voter law that said states could request any information from voters they deem necessary." Voter irregularities in the United States Voter impersonation Only US citizens have the right to vote in federal elections. While the United States Congress has jurisdiction over laws applying to federal elections, it has deferred the making of most aspects of election laws to the states. Therefore, the administration of voter registration requirements, voting requirements, and elections vary widely across jurisdictions. Voter impersonation (also sometimes called in-person voter fraud) is a form of electoral fraud in which a person who is eligible to vote in an election votes more than