"The New York Times" counts apathy, anger and frustration at the relentlessly negative tone of the campaigns as the reasons of low turnout and stated, "Neither party gave voters an affirmative reason to show up at the polls." Connecticut State Representative Christina Ayala (Democrat) was arrested in September 2014 on 19 voting fraud charges, specifically "eight counts of fraudulent voting, 10 counts of primary or enrollment violations and one count of tampering with or fabricating physical evidence." In September 2015 she pleaded guilty to state election law violations, received a one-year sentence (suspended) along with two years 'conditional discharge', and agreed not to seek elective office for two years. Her mother, Democratic Registrar of Voters Santa Ayala, was also the subject of an investigation in the case, but was not charged. California State Senator Roderick Wright (Democrat) resigned from office in September 2014 and was sentenced to 90 days in Los Angeles county jail for perjury and voter fraud. Despite being convicted months earlier for 8 felonies, Wright was allowed to take a paid leave of absence as State Senator. In Chicago, election judges said they had received automated phone calls between October–November 3 with apparently false instructions about voting or required training, according to the "Chicago Sun-Times". In Pontiac, Michigan, local Democrats cited reports of voter harassment and intimidation by Republicans over questioning legally-cast ballots with election workers repeatedly having had to ask them to step aside. A clerk called police for help. In June 2013, the Supreme Court invalidated part of the Voting Rights Act of 1965, permitting nine (mostly Southern) states to change their election laws without advance federal approval. Since 2010, 22 states enacted new voting restrictions. The 2014 federal election was the first federal election where 15 states enacted new voting restrictions, many of which faced challenges in court. Scattered issues with voting machines occurred, with miscalibrated machines recorded a vote cast for one candidate as a vote for another candidate. They occurred in Virginia, Maryland, Illinois, and North Carolina. In Bexar County, Texas, the Republican candidate for governor, Greg Abbott, was accidentally replaced on the ballot by David Dewhurst on one machine, on which 12 votes were cast before the problem was caught. A series of milestones were set for women, African-Americans, and Hispanics, among others, in the U.S. Congress and American politics in general. These include:  Bold indicates a change in partisan control. Note that not all states held gubernatorial, state legislative, and United States Senate elections in 2014.