Von Spakovsky, who had been a longtime voting rights activist and elections official in Georgia before serving at Justice, accepted a presidential recess appointment to a Republican slot on the Federal Election Commission in December 2005. He is scheduled to appear at a June 13 confirmation hearing before the Senate Rules and Administration Committee.

The House Administration Committee is also inquiring into von Spakovsky's communications with the Election Assistance Commission, a tiny agency that implemented a 2002 election reform law and serves as a national election information clearinghouse.

The bipartisan, four-member commission stirred a political tempest last year when it delayed the release of voter fraud and voter ID law studies, saying that more research was needed. A House panel revealed last month that the fraud study's central finding - that there was little evidence of widespread voter fraud - had been toned down to say that "a great deal of debate" surrounded the subject.

Commissioners rejected as flawed the second study's finding that voter ID laws tend to suppress turnout, especially among Latinos, and ordered more research.

Rich said that von Spakovsky usurped his seat on a commission advisory panel in 2004, although the law creating the panel allocated that spot for the Voting Rights Section chief "or his designee." Rich said he was not consulted.

After the commission hired both liberal and conservative consultants to work on the studies in 2005, e-mails show that von Spakovsky tried to persuade panel members that the research was flawed.

In an Aug. 18, 2005, e-mail to Chairman DeGregorio, he objected strenuously to a contract award for the ID study to researchers at Ohio State University's Moritz College of Law, who were teaming with a group at Rutgers University.

Von Spakovsky wrote that Daniel Tokaji, the associate director of Moritz' election program, was "an outspoken opponent of voter identification requirements" and that those "pre-existing notions" should disqualify him from federal funding for impartial research.

The criticism was ironic coming from von Spakovsky, who a few months earlier had written the anonymous article for the Texas Review of Law and Politics, in which he called voter fraud a problem of importance equal to racial discrimination at the polls. Von Spakovsky acknowledged writing the article after joining the FEC.

Months after its publication, he participated in the department's review of Georgia's photo ID law, as required under the 1965 Voting Rights Act for election laws passed in 16 Southern states. After the department approved it, a federal judge struck it down as akin to a Jim Crow-era poll tax on minority voters.

Rich called von Spakovsky's failure to withdraw from the case "especially disturbing, given the clear ethical concerns" over his prior work as a Georgia elections official and the bias in his article.

Von Spakovsky's tone toward DeGregorio grew increasingly harsh in 2005 as the chairman refused to take partisan stands, said two people close to the commission who declined to be identified because of the matter's sensitivity.

Their differences seemed to come to a head last year over two issues raised by Arizona's Republican secretary of state, Janice Brewer, who was implementing the toughest state voter identification law in the nation. In April 2005, the Justice Department erroneously advised her that Arizona did not need to offer a provisional ballot to those lacking proof of citizenship.

E-mails suggest that von Spakovsky contacted an aide to Missouri Republican Sen. Kit Bond, who inquired of DeGregorio whether the commission was "seriously considering taking a position against" the department on the provisional ballot question.

DeGregorio sent a testy message asking von Spakovsky if the note from Capitol Hill was "an attempt by you to put pressure on me."

"If so, I do not appreciate it," he wrote.

The next day, von Spakovsky wrote DeGregorio that he thought they "had a deal" under which the department would reconsider its position on provisional ballots if the commission would allow Arizona to modify the federal voter registration form to require proof of citizenship.

"I do not agree to `deals,' especially when it comes to interpretation of the law," DeGregorio replied.

Last September, the White House replaced DeGregorio with Caroline Hunter, a former deputy counsel to the Republican National Committee. DeGregorio confided to associates that he was told that von Spakovsky influenced the White House's decision not to reappoint him, said the two people close to the panel.

Asked about his ouster, DeGregorio said only that he "was aware that Mr. von Spakovsky was not pleased with the bipartisan approaches that I took."