8
WATSON v. REPUBLICAN NATIONAL COMMITTEE
Opinion of the Court
interpretation “that courts do not interpret statutes in isolation, but in the context of the corpus juris of which they
are a part, including later-enacted statutes.” Branch v.
Smith, 538 U. S. 254, 281 (2003) (plurality opinion). And
UOCAVA confirms that while Congress has set the date by
which absentee ballots must be cast, States have the power
to set the date by which they must be received.
UOCAVA requires States to permit absent military and
overseas voters to cast absentee ballots in federal elections.
52 U. S. C. §20302(a)(1). As a backup, it establishes a federal absentee voting system. In detailing this system,
UOCAVA repeatedly presupposes that ballot receipt is a
matter of state law. For example, it specifies that a federal
absentee ballot shall not be valid if the State provides an
absentee ballot “at least 60 days before the deadline for receipt of the State ballot under State law.” §20303(e)(2). It
also mandates that the ballots of overseas military voters
be delivered “to the appropriate election officials” “not later
than the date by which an absentee ballot must be received
in order to be counted in the election.” §20304(b)(1). Finally, to avoid any double counting, UOCAVA provides that
federal absentee ballots “shall not be counted” if a State receives the voter’s state absentee ballot by “the deadline for
receipt of [that] ballot under State law.” §20303(b)(3). If
the election-day statutes established a nationwide ballotreceipt deadline, these references to state ballot-receipt
deadlines would make little sense.
Finally, this interpretation of the election-day statutes is
consistent with the way the Constitution treats elections.
Although most voting in our country’s early days occurred
in person—making casting and receipt simultaneous—that
was not true of the electoral college. For that, the Constitution establishes a system somewhat analogous to absentee voting: Presidential electors “shall meet in their respective States, and vote by Ballot,” and then “transmit” their
votes to the “Seat of the Government of the United States,