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At the same time, in Texas, an increasing number of counties are rethinking who should run elections altogether.
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As secretary of state, Fort Worth attorney John Scott would oversee election administration in Texas.
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The indictment comes after a three-year investigation into the business dealings of the former president's family business by the Manhattan district attorney's office.
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The bill creating the commission, which would have subpoena power, passed 252-175. Republican U.S. Reps. Tony Gonzales of San Antonio and Van Taylor of Plano were the only two GOP Texans to support the measure.
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The high court's decision marks a major setback for Trump, who for years has fought to shield his finances and business practices from scrutiny.
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President Biden said that "even those opposed to the conviction, like Senate Minority Leader McConnell, believe Donald Trump was guilty of a 'disgraceful dereliction of duty'."
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In a statement issued shortly after a final vote in the Senate on a charge of inciting an insurrection, Trump said the "movement to Make America Great Again has only just begun."
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The Senate minority leader condemned the actions taken by Trump on the day of the Capitol insurrection but said he didn't believe the impeachment trial was constitutional.
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Seven Republicans joined with all Democrats and independents to vote to convict the former president for inciting an insurrection, but the tally is short of the two-thirds vote needed.