the federal judge ordered the state to reinstate the voters. The judge ruled that the state's actions were in violation of the NVRA. His decision noted that there was no way to prevent qualified voters from being disfranchised as their cards may be returned as undeliverable by postal error, clerical error, inadvertent routing within a multi-unit dwelling, or even simple misspelling or transposition of numbers in an address. In December 2007, Kansas Republican Chair Kris Kobach sent an email boasting that "to date, the Kansas GOP has identified and caged more voters in the last 11 months than the previous two years!" Republicans sent out fundraising mailers to voters in five Florida counties: Duval, Hillsborough, Collier, Miami-Dade and Escambia, with 'do not forward' on the letters. The mailers included inaccurate voter ID numbers and ostensibly confirmed with voters they were registered as Republican. The RNC declined to discuss the mailer with the St. Petersburg Times. A representative denied that the mailing had anything to do with caging. Two top Florida elections officials, both Republicans, faulted the Republican mailing, calling it "confusing" and "unfortunate" because of a potential to undermine voter confidence by making them question the accuracy of their registrations." Some officials expressed concern that the RNC would try to use a caging list derived from the mailers. In Northern California, reports of voter caging emerged when letters marked 'do not forward' were sent to Democrats with fake voter ID numbers. The description of the letters matched the letters that were sent out in Florida. Many details on the letters were false; for example, the letters referred to a Voter Identification Division, but RNC personnel said they had no such department. The RNC did not return calls from a news organization regarding the letters. On October 5, 2008, the Republican Lieutenant Governor of Montana, John Bohlinger, accused the Montana Republican Party of vote caging to purge 6,000 voters from three counties that trend Democratic. The purges included decorated war veterans and active duty soldiers. Terri Lynn Land, the Secretary of State of Michigan, was found to be purging thousands of voters from voting rolls based on Voter ID cards being returned as undeliverable. The American Civil Liberties Union (ACLU) took Michigan to court over the purges. Judge Stephen J. Murphy ruled the purge illegal under the National Voter Registration Act of 1993 and directed Land to reinstate the affected voters.