be made of the discretionary power to regulate the time, place, and manner of elections granted the States, including attempts at partisan entrenchment, malapportionment, and the exclusion of political minorities. As the Supreme Court has recognized, the Elections Clause empowers Congress to protect the elections on which its existence depends , Ex parte Yarbrough, 110 U.S. 651, 658 (1884), and protect the citizen in the exercise of rights conferred by the Constitution of the United States essential to the healthy organization of the government itself , id. at 666. (4) The Elections Clause grants Congress plenary and paramount jurisdiction over the whole subject of Federal elections, Ex parte Siebold, 100 U.S. 371, 388 (1879), allowing Congress to implement a complete code for congressional elections . Smiley v. Holm, 285 U.S. 355, 366 (1932). The Elections Clause, unlike, for example, the Commerce Clause, has been found to grant Congress the authority to compel States to alter their regulations as to Federal elections, id. at 366–67, even if these alterations would impose additional costs on the States to execute or enforce. Association of Community Organizations for Reform Now v. Miller, 129 F.3d 833 (6th Cir. 1997). (5) The phrase manner of holding elections in the Elections Clause has been interpreted by the Supreme Court to authorize Congress to regulate all aspects of the Federal election process, including notices, registration, supervision of voting, protection of voters, prevention of fraud and corrupt practices, counting of votes, duties of inspectors and canvassers, and the making and publication of election returns . Smiley v. Holm, 285 U.S. 355, 366 (1932). (6) The Supreme Court has recognized the broad substantive scope of the Elections Clause and upheld Federal laws promulgated thereunder regulating redistricting, voter registration, campaign finance, primary elections, recounts, party affiliation rules, and balloting. (7) The authority of Congress under the Elections Clause also entails the power