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Congressional Research Service: "The truth of the matter is that the electors are not 'officers' at all, by the usual tests of office." citing U.S. v. Hartwell (1868)
Legal Historians brief in CREW v. Trump 17 n.59: "As holders of an office 'of trust' under the United States, electors would also be subject to the [Foreign Emoluments] [C]lause." No citation in support. No citation to Hartwell. No citation to Kesavan's article on this question.
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