In a commentary responding to a Washington Post editorial that said voter ID laws "inflict harm on democratic rule," Kansas Secretary of State Kris Kobach argued that "photo IDs have become ubiquitous and unavoidable" and "it's absurd to suggest that anyone is 'disenfranchised'" by laws requiring photo ID to vote. He also repeated his claim that Kansas had "221 incidents of voter fraud" between 1997 and 2010 — without clarifying that these were claims of fraud, not actual violations. As for why there were only seven convictions, Kobach said it was because county attorneys didn't have the resources to conduct investigations. But Sedgwick County officials reviewed the local claims on Kobach's list and determined that nearly all of them were either groundless or were honest mistakes, not fraud. Meanwhile, Rep. Marcia Fudge, D-Ohio, urged the U.S. Department of Justice last week to investigate whether photo ID laws violate the Voting Rights Act.