registered voters to vote by mail.10 Following the beginning of the COVID-19 outbreak in March 2020, the General Assembly enacted laws regulating the mail-in voting system.11 Section 3150.16 of the Election Code sets forth procedural requirements that voters must follow in order for their ballot to be counted.12 These procedures require, for example, that voters mark their ballots in pen or pencil, place them in secrecy envelopes, and that ballots be received by the county elections board on or before 8:00 P.M. on Election Day.13 Nowhere in the Election Code is any reference to “curing” ballots, or the related practice of “notice-and-cure.” This practice involves notifying mail-in voters who submitted procedurally defective mail-in ballots of these deficiencies and allowing those voters to cure their ballots.14 Notified voters can cure their ballots and have their vote counted by requesting and submitting a provisional ballot.15 Recently, the Supreme Court of Pennsylvania in Democratic Party of Pennsylvania v. Boockvar addressed whether counties are required to adopt a notice-and-cure policy under the Election Code.16 Holding that they are not, the 10 11 12 13 14 15 16 Id. at 352 (citing 25 P.S. §§ 3150.11-3150.17). Prior to the enactment of Act 77, voters were only permitted to vote by mail if they could “demonstrate their absence from the voting district on Election Day.” Id. (internal citations omitted). E.g., 25 P.S. § 3150.16. Id. Id. Pa. Democratic Party, 238 A.3d at 372. Doc. 93 at 9. Pa. Democratic Party, 238 A.3d at 374. -4-