millions illegally voted in the 2016 election were "false". CNN also asked him if he had any proof of his allegation that thousands of Massachusetts voters actually had voted in New Hampshire in 2016. He replied that he had none. In September 2017, Kobach claimed to have proof that voter fraud swung the 2016 Senate race in New Hampshire and may have swung New Hampshire's 2016 presidential vote; fact-checkers and election experts found that Kobach's assertion was false. Kobach claimed that more than 5,000 individuals voted by using out-of-state driving licenses as identification, even though New Hampshire residents are required to update their licenses in order to drive. However, New Hampshire state law allows residents of the state who happen to have out-of-state driving licenses to vote. There are a number of reasons why some voters may use out-of-state driving licenses, with the most likely being that they are out-of-state college students. Numerous legitimate New Hampshire voters said that this was the case with them; they were students at colleges in New Hampshire who had yet to update their driving license. New Hampshire Public Radio also found that most instances of out-of-state driving licenses being used were in college towns. Another reason is that they may be military personnel on active duty. FactCheck.Org described Kobach's claim as "baseless" and "bogus", noting that Kobach "hasn't provided evidence of any illegal voting". Later that September, Kobach backtracked on his claims, but said that there have been "anecdotal reports" about voter fraud. Richard L. Hasen, the Chancellor's Professor of Law and Political Science at the University of California, Irvine, an election law expert, has described Kobach as a "charlatan", "provocateur" and "a leader nationally in making irresponsible claims that voter fraud is a major problem in this country." Prosecutions of voter fraud In 2015, Kobach received from the legislature and the governor the right to prosecute cases of voter fraud, after claiming for four years that Kansas had a massive problem of voter fraud that the local and state prosecutors were not adequately addressing. At that time, he "said he had identified more than 100 possible cases of double voting." Testifying during hearings on the bill, questioned by Rep. John Carmichael, Kobach was unable to cite a single other state that gives its Secretary of State such authority. By February 7, 2017, Kobach had filed nine cases and obtained six convictions. All were