The Resolution of Election Disputes: Legal Principles that Control Election Challenges “…For this Court to render such a drastic order, there must be a clear showing that a course of fraudulent conduct was employed which effectually prevented the electors from expressing their will.” Lewis v. Democratic Executive Committee, 232 La. 732, 95 So.2d 292 (1957). At 4. Then to confuse matters further, this alternative was immediately undermined by the supreme court, saying, No case has been called to our attention (and we know of none) where an election has been upset because of serious and pervasive irregularities when the evidence falls short of proving that “but for” the irregularities, the one contesting the election would have won. At 4. In the end, despite its acknowledgement of this standard, the supreme court sided with Mr. Tonry and allowed the election results to stand. Is this the same standard that was used 20 years later in the Louisiana case of Valence v. Rosiere? There, the court said, …“if the court finds the proven frauds and irregularities are of such a serious nature as to deprive the voters of the free expression of their will, it will decree the nullity of the entire election—even though the contestant might not be able to prove that he would have been [elected] but for such fraud and irregularities.”…Generally, however, the allegations of the petition must show a sufficient number of contested votes to change the results of the election… At 1139. It sounds very similar. The facts are similar, too. In fact, the Lewis case cited by the court in the above quotation from Moreau also was cited by the court in Valance (at 1139). But the Valance court adhered to the line of cases that followed Lewis, while the Moreau court did not. The supreme court in Moreau was well aware of the line of cases that followed Lewis. One of the two dissents in Moreau said, The applicable rule, reiterated by this Court in several decisions, is as follows: “[I]f the Court finds the proven frauds and irregularities are of such a serious nature as to deprive the voters of the free expression of their will, it will decree that nullity of the entire election…” See Garrison v. Connick, La., 291 So.2d 778 (1974); Dowling v. Orleans Parish Democratic Committee, 235 La. 62, 102 So.2d 755 (1958); Lewis v. Democratic Executive Committee, 232 La. 732, 95 So.2d 292 (1957). * * * These frauds and irregularities were both systematic and flagrant. They infected far more votes than the vote margin between the two competing candidates. This means that the voters have been deprived of the free expression of their will, because the outcome of the election cannot be determined. At 5. All three of the cases cited by the dissent in Moreau—Garrison, Dowling and Lewis—are cited by the Supreme Court of Louisiana in reaching its decision in Valance. In Valance, the Supreme Court of Louisiana also relied on a different statute, LSA-R.S. 18:1432(A), which 26