Former Kansas Secretary of State Kris Kobach didn’t open his own wallet to pay for six hours of legal education a federal judge ordered he take due to his “repeated and flagrant violations of discovery and disclosure rules.

Previously, Kobach paid a $1,000 fine for misleading the federal court with a state-issued card left behind by an employee who was deployed to Ukraine with the Oklahoma Army National Guard.

Both instances stem from litigation over a state law that required new voters to show a birth certificate or other proof of citizenship when registering to vote. The American Civil Liberties Union challenged the law, which was argued at trial last year, and Judge Julie Robinson ruled the requirement unconstitutional.

The secretary of state’s office also is responsible, pending appeal, for paying $26,000 in ACLU legal fees after Kobach was found in contempt of court for failing to comply with Robinson’s orders.