“. . . the right to vote is as precious as life itself to those who have been victimized by the horrors of war, to those whose not-too-distant relatives were prohibited from exercising the right to vote simply because of their race or gender, and to those who have risked it all . . . in order to one day exercise the right to vote.” Charles L. Zeldon, Bush v. Gore: Exposing the Hidden Crisis in American Democracy, 76 (2010) Any society that wishes to have a system of regular, free, and fair elections must acknowledge that such elections cannot exist without a commitment to the concept of the rule of law. Democratic governments exist and thrive in many different forms, forms that are frequently adjusted to the specific societal norms, cultural needs, and traditions of the people who compose that society. But, whatever form it takes, a democracy cannot exist unless there is a commitment to the rule of law. A government of, by, and for the people cannot flourish when some people are above the law. Under a system governed by the rule of law, systems and procedures can be put in place before an election that will guarantee that the intent of the voters is accurately reflected in the outcome of the election. Laws, rules and regulations put in place before an election provide a template for these systems and procedures. The voters can be educated on how to properly cast their votes. Poll workers can be trained on the use of best practices to ensure that votes are properly cast and counted. Proper security measures can be put in place to secure the ballots once they are cast. Accountability by election officials can be enhanced by having systems that promote transparency. Experience has taught me that an essential component for accountability in an election is a written ballot. With a written ballot, the intent of the voter is verifiable. If the voters’ intent is independently verifiable, when and if there is a recount or review of election procedures, accountability by election officials is enhanced and the possibility of fraud is decreased. xvii