Former Secretary of State Kris Kobach used state funds to pay for continuing law education ordered by a federal court judge for his performance in a voter rights trial last year.

Kobach notified the court last week he had completed a six-hour course on civil trial basics through the National Business Institute.

Katie Koupal, spokeswoman for the secretary of state's office, confirmed Kobach made the $359 payment for the audio version of the class through the office.

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.

Robinson also said Kobach's late efforts to introduce new evidence showed a pattern of "flaunting disclosure and discovery rules that are designed to prevent prejudice and surprise at trial." She ordered coursework as a sanction.

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.