Automated vote counting is seen by some to have a greater potential for election fraud; IRV supporters counter these claims with recommended audit procedures, or note that automated counting is not required for the method at all. John Russo, Oakland City Attorney, argued in the "Oakland Tribune" on 24 July 2006 that "Instant runoff voting is an antidote to the disease of negative campaigning. IRV led to San Francisco candidates campaigning more cooperatively. Under the method, their candidates were less likely to engage in negative campaigning because such tactics would risk alienating the voters who support 'attacked' candidates", reducing the chance that they would support the attacker as a second or third choice. In 2013–2014, the Rutgers-Eagleton Poll surveyed more than 4,800 likely voters in 21 cities after their local city elections—half in cities with IRV elections and 14 in control cities selected by project leaders Caroline Tolbert of the University of Iowa and Todd Donovan of Western Washington University. Among findings, respondents in IRV cities reported candidates spent less time criticizing opponents than in cities that did not use IRV. In the 2013 survey, for example, 5% of respondents said that candidates criticized each other "a great deal of the time" as opposed to 25% in non-IRV cities. An accompanying survey of candidates reported similar findings. Internationally, Benjamin Reilly suggests instant-runoff voting eases ethnic conflict in divided societies. This feature was a leading argument for why Papua New Guinea adopted instant-runoff voting. However, Lord Alexander's objections to the conclusions of the British Independent Commission on the Voting System's report cites the example of Australia saying "their politicians tend to be, if anything, more blunt and outspoken than our own". Some critics of IRV misunderstand the tally to believe that some voters get more votes than other voters. In Ann Arbor, Michigan, for example, arguments over IRV in letters to newspapers included the belief that IRV "gives minority candidate voters two votes", because some voters' ballots may count for their first choice in the first round and a lesser choice in a later round. The argument that IRV represents plural voting is sometimes used in arguments over the "fairness" of the method, and has led to several legal challenges in the United States. In every instance, state and federal judges have rejected this argument. The argument was addressed and rejected by a Michigan court in 1975; in "Stephenson v. the Ann Arbor Board of City Canvassers", the court held "majority preferential voting" (as IRV was then known) to be in compliance with the Michigan and United States constitutions, writing: The same argument was advanced in opposition to IRV in Maine.