Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections that their claims were not adequately addressed at the CSE level.220 Establishing an independent mechanism of review for electoral complaints, or granting ordinary courts broader jurisdiction to hear appeals regarding electoral complaints, could remedy such a gap. In Brazil, the constitution provides for a right to appeal the decisions from the Regional Electoral Courts to the Superior Electoral Court. This right to appeal is limited to: decisions that are rendered against an express provision of the Constitution or of a law; instances when there is a divergence in the interpretation of a law between two or more electoral courts; and when decisions relate to ineligibility or issuance of certificates of electoral victory in federal or state elections.221 However, the “decisions of the Superior Electoral Court are unappealable, expect for those which are contrary to this Constitution and those denying habeas corpus or writs of mandamus.”222 Brazil provides an example of a codified right to appeal that maintains a clear and coherent interpretation of relevant law. Appeals should not be confused with referrals. When it has jurisdiction, a regional or provincial post-election remedy body cannot refer a case to the national entity without first ruling on the case. The electoral law should also define when the decision becomes final and is no longer challengeable. For example, in the Philippines, complaints concerning elections for the House of Representatives and the Senate are heard by special tribunals. The latter will issue decisions that can be appealed to the Supreme Court but only on certiorari.223 The Nicaragua system provides for a reviewing process by the electoral management body (CSE) regarding the electoral challenges and irregularities at the polling stations. The CSE does not provide for an appeals process. However, the criminal electoral offenses will be handled by the ordinary criminal courts that do provide for an appeal. Thus, while an appeals process does not exist in every Id. at 20. Constituição Federal [C.F.] [Constitution] art. 121, § 4 (Braz.). 222 Id. art. 121, § 3. 223 “Certiorari” is a Latin word meaning "to be informed of, or to be made certain in regard to."  It is also the name given to certain appellate proceedings for re-examination of actions of a trial court, or inferior appeals court. A “writ of certiorari” is defined as an order by a higher court directing a lower court, tribunal, or public authority to send the record in a given case for review.  Erben et al., supra note 150, at 27. 220 221 72