an action he contended was intended to "suppress votes." State Senate Democratic Minority Leader Anthony Hensley said Kobach should reimburse Kansas for trips to Republican Party events, characterizing claims that the political functions coincided with official business was "probably just a ruse." Voter fraud claims As Secretary of State of Kansas, Kobach has implemented some of the strictest voter ID laws in the United States. In September 2016 it was reported he "agreed last month to add nearly 20,000 properly registered voters to the state's rolls only after being threatened with contempt of court." In response to a sufficient citizens petition that, as somewhat uniquely allowed in Kansas, requesting the convening of a grand jury for the purpose of investigating Kobach's actions, the state Court of Appeals ruled against him. He complained to the Kansas Supreme Court that Derek Schmidt, the Kansas Attorney General, who had withdrawn from the case, failed to properly represent him in the Appeals court. In deciding the merits, the state Supreme Court ruled on August 31, 2018 that a grand jury to investigate the matter must be convened in Douglas County, where he resided. The Brennan Center for Justice described him as "a key architect behind many of the nation's anti-voter and anti-immigration policies." Kobach has periodically made unsubstantiated claims about the extent of voter fraud in the United States. In a 2010 press conference, Kobach asserted there could be as many as 2,000 people who were using the identities of dead people to vote in Kansas, mentioning it "certainly seems like a very real possibility" that "Albert K. Brewer" was an example of one such deceased individual who had voted in a recent primary. When The Wichita Eagle followed up on Kobach's assertion, it discovered Brewer, 78 years old, was still alive, although his father, who was born in 1904 and had a different middle initial, had died in 1996. Brewer told the Eagle reporter, "I don't think this is heaven, not when I'm raking leaves." Kobach has also said that there are 18,000 non-citizens registered to vote in Kansas, a claim that NBC News described as "misleading" and "debunked". Kobach supported Trump's claims that millions of non-citizens voted in the 2016 presidential election. Kobach estimated that 3.2 million non-citizens voted, citing a widely debunked study. Kobach complained that, during one of his appearances, CNN ran text on the screen saying Kobach's claims that