black neighborhoods warning that violating election laws is a crime. The effect was to suppress or intimidate black voters. In Louisiana in 1986, the RNC tried to have 31,000 voters, mostly black, removed from the rolls when a party mailer was returned. Again, the action was challenged and dismissed. The consent decrees that resulted prohibited the party from engaging in anti-fraud initiatives that target minorities or from conducting mail campaigns to "compile voter challenge lists." 2004 elections BBC journalist Greg Palast obtained an RNC document entitled "State Implementation Template III.doc" that described Republican election operations for caging plans in numerous states. The paragraph in the document pertaining to caging was: V. Pre Election Day Operations New Registration Mailing At whatever point registration in the state closes, a first class mailing should be sent to all new registrants as well as purged/inactive voters. This mailing should welcome the recipient to the voter rolls. It is important that a return address is clearly identifiable. Any mail returned as undeliverable for any reason, should be used to generate a list of problematic registrations. Poll watchers should have this list and be prepared to challenge anyone from this list attempting to vote. Shortly before the 2004 election, Palast also obtained a caging list for Jacksonville, Florida, which contained many blacks and registered Democrats. The list was attached to an email that a Florida Republican Party official was sending to RNC headquarters official Tim Griffin. The Republican National Committee also sent letters to minority areas in Cleveland, Ohio. When 35,000 letters were returned as undeliverable, the party employed poll watchers to challenge the voters' right to vote. Civil liberties groups challenged the RNC in a case that went to the Supreme Court, but the RNC was not stopped from challenging the voters. Similarly, the RNC sent out 130,000 letters to minority areas in mostly-black Philadelphia, Pennsylvania, and it hoped to cage voters there in the Democrat stronghold. Journalists have found evidence that the RNC had also attempted to use voter caging to suppress or intimidate voters in states such as New Mexico, Ohio, Florida, Nevada, and Pennsylvania. For example, New Jersey RNC officials used caging lists to challenge absentee ballots and absentee ballot requests. 2008 elections As noted earlier, the Republican Secretary of State in Michigan was found purging voters from voting rolls when voter ID cards were returned as undeliverable. In the court challenge,