Voter disenfranchisement has been a theme much on the mind of the Clinton campaign. Campaign manager Maggie Williams recently penned a memo stating, “Hillary Clinton respects those voters [in the states yet to vote] and their right to participate in this historic contest. Their votes, along with all the others, will determine when this contest is at an end. It’s the American way – everybody counts in this country. The last time that we were told we’d better cut the process short or the sky would fall was when the Supreme Court stopped the Florida recount in 2000. But Chicken Little was wrong. What was true then is true now: there is nothing to fear – and everything to gain – from hearing from all of the voters.” Meanwhile, in an interview with a Montana TV station, Hillary Clinton asserted, “A lot of Senator Obama’s supporters want to end this race because they don't want people to keep voting. That's just the opposite of what I believe. We want people to vote. I want the people of Montana to vote, don’t you?”

These arguments, of course, aren't terribly logical. Even if Senator Clinton were to end her campaign tomorrow, the Montana Democratic primary would still occur on June 3, her name would still be on the ballot, and voters could, if they so chose, select her. And by Williams’ apparent definition of disenfranchisement—the lack of an active and closely contested primary campaign—Indiana voters have been disenfranchised in at least the last five Democratic nominating contests, including those of Bill Clinton in 1992 and 1996.

This looseness with a serious charge—voter disenfranchisement—is particularly troubling given that, for the last several weeks, Clinton supporters urged uncommitted superdelegates to base their preferences on a metric that would essentially disenfranchise the Democratic voters of Iowa, Nevada, Washington, and Maine. The Clinton campaign is the first in the history of the modern (post-1968) nominating process to suggest that the popular vote total should be considered as important as the number of pledged delegates won (indeed, to suggest that the popular vote total has any relevance at all in the nominating process). Yesterday, the latest Clinton superdelegates to raise the issue, New Jersey governor Jon Corzine and Pennsylvania congressman John Murtha, stated that Clinton needed to pass Obama in the popular vote total to justify superdelegates backing her at the convention.

The problem with this argument: Iowa, Nevada, Washington, and Maine have caucuses that don’t report the popular vote total (unsurprisingly, since the popular vote total has never been claimed to matter). While Real Clear Politics has produced a popular vote estimate of the final outcome in these four states (Obama by 110,218, for an overall lead of 827,308 votes), neither the Clinton campaign nor the media generally use this figure.

The Maine caucus has none of the problems that the Clinton campaign has regularly attributed to caucuses. Only registered Democrats can participate; those who can’t attend the caucus can vote by absentee. (From Israel, I joined over 4000 Maine Democrats who caucused by absentee in 2008). Maine isn’t a state with a lot of upper-middle class voters or students, the kind of people that Bill Clinton in particular has claimed skew caucus results. And in contrast to caucuses in states like Kansas, Nebraska, or Idaho, the state party leadership, headed by Governor John Baldacci, backed Clinton, not Obama. In a record turnout, Obama nonetheless prevailed, 59 percent to 38 percent. But because the state party records state delegates won, not individual caucus tallies, the votes of Mainers play no role in the Clinton campaign’s popular-vote metric. Governor Baldacci nonetheless remains a Clinton superdelegate.

The situation in Washington state is even more complicated. Since the late 1990s, the state’s nominating process has been mired in litigation. In 2000, the Supreme Court declared the state’s “blanket” primary (in which all candidates appeared on the primary ballot, and the top vote-getters from each party advanced to the general election) unconstitutional. In 2004, state voters passed an initiative to effectively restore the system, which the Supreme Court upheld—but not in time for the presidential primary. So Washington Democrats chose their delegates through a caucus, which Obama overwhelmingly won. (The party also had a non-binding primary, which was marred by disallowed ballots.)

Clinton has three Washington superdelegates—Senators Patty Murray and Maria Cantwell and DNC member Ron Sims. (Cantwell has backtracked some from this position, though not because the popular vote total doesn’t count her constituents.)

At least the popular votes of Washington and Maine can be roughly estimated. In Iowa and Nevada, even that’s not possible, because of the nature of multi-candidate caucuses. In many individual Iowa caucuses, Bill Richardson, Chris Dodd, Joe Biden, or Dennis Kucinich failed to reach the 15 percent viability threshold. Their supporters thus switched to Obama, Clinton, or John Edwards. In individual Nevada caucuses, Edwards frequently failed to reach the 15 percent viability threshold; his supporters thus switched to Obama or Clinton. In estimating the popular tally, how should such voters be counted? They can’t be, fairly—which is why the party has never before used the popular vote as a relevant tool in the nominating process.

Even though the votes of their constituents don’t count in the Clinton campaign’s preferred metric, Representatives Leonard Boswell (IA) and Shelley Berkley (NV); and DNC members Sandy Opstvedt (IA), Mike Gronstal (IA), and Dina Titus (NV) remain Clinton superdeleates.

Why do the caucus figures matter? In a recent column, Michael Barone offered a best-case projection for Clinton, suggesting that she could, theoretically, end the primary season with a popular vote advantage. But, given polls published after Barone’s column, Clinton seems far more likely to win Pennsylvania by around 10 points, rather than the 20 points that Barone projected. Adjusting that figure but keeping the rest of Barone’s (very Clinton-friendly) estimates yields a final Clinton popular vote lead of around of around 30,000 votes—less than the estimated Obama margin in the uncounted caucus states.

Unlike their colleagues in Florida and Michigan, the state parties in Washington and Maine followed DNC rules in setting up the timing and mechanism of their caucuses. Unlike party members in Michigan, Washington and Maine Democrats participated in record numbers. Yet, judged by the way that most in the media are reporting the popular vote margin, the votes of Maine and Washington Democrats don’t seem to count.

Somehow, I doubt we’ll be seeing a Maggie Williams memo decrying this disenfranchisement.