Cite as: 609 U. S. ____ (2026) 5 ALITO, J., dissenting election occur on election day, it preempts Mississippi’s statute. B This conclusion finds support in legal authorities from the period when the federal election-day statutes were enacted. Legal dictionaries of the era described an “election” as including both the casting and receipt of ballots. See 1 J. Bouvier, Law Dictionary and Concise Encyclopedia 979 (8th ed. 1914) (“the act of casting and receiving the ballots”); W. Anderson, A Dictionary of Law 394 (1889) (“[v]oting and taking the votes”). Contemporary state statutes likewise provided that an “election” was not “finished” or “closed” until polls closed, by which point poll workers stopped accepting ballots. E.g., Tenn. Code §§860–861 (1858); Del. Rev. Stat., ch. 18, §§21, 22 (1874); N. C. Code, ch. 16, §2689 (1883). Indeed, under 19th-century election-law parlance, a voter’s presentation of a complete ballot constituted a mere “offe[r] to vote,” and it was not said that the person had “voted” until an election official took custody of the ballot. E.g., Cal. Pol. Code §§1225–1228 (1876); Md. Pub. Gen. Laws Art. 5, §15 (1878). State-court decisions from the era corroborate this interpretation. When statutes pegged certain legal consequences to an “election” or “voting,” courts held that ballot receipt triggered these consequences. For example, a Pennsylvania court held that a 10-day limitations period for contesting the outcome of a race began running once officials closed the polls on election night, a process that entailed sealing the ballot boxes shut. Collings’s Case, 2 Luz. L. Obs. 57 (Pa. Quar. Sess. 1861); Act of July 2, 1839, §§72–74, 1841 Purdon’s Dig. L. Pa. 351. Similarly, when the Supreme Court of Alabama resolved a charge that a defendant illegally voted, the court held that the defendant could not be found liable unless there was evidence that his ballot had been received by a poll worker and placed in the ballot box.