The Resolution of Election Disputes: Legal Principles that Control Election Challenges with the court’s desire that the vote buyers be prosecuted for their criminal activities.78 A.2. Fraud will invalidate procedures early in the election process as well as during the balloting and the vote count In Flower v. D’Apice, 104 A.D.2d 578 (N.Y. 1984), aff’d, 468 N.E.2d 1119 (1984), Daniel Sadofsky’s nominating petition as a candidate for the Westchester county council was invalidated, and Mr. Sadofsky’s name was taken off of the ballot, because his nominating petition contained the names of people who did not sign the petition (at least one was in California at the time he was supposed to have been in New York signing Mr. Sadofsky’s petition and another was dead). In addition, the veracity of each page of the petition had to be sworn to by a subscribing witness who was to have asked each person to verify his or her identity before getting the person to sign the page. Significantly, the court found that one person let someone else complete the subscribing witness statements on three pages sometime later and another subscribing witness did not ask the signatories to identify themselves. In addition, Mr. Sadofsky testified that, when he signed as a subscribing witness, he knowingly got signatures that were invalid—he knew that people signed the names of other people—and did not ask the signatories to identify themselves. The court concluded, Since Sadofsky is a candidate, his fraudulent acts warrant that his name be stricken from the ballot. Moreover, we also find that fraud and irregularity so permeated the designating petition as a whole as to call for its invalidation. At 578 (emphasis supplied). Similarly, the District of Columbia Board of Elections and Ethics disallowed nominating petitions for Washington, D.C., Mayor Anthony Williams that had been circulated by Scott Bishop, Scott Bishop, Jr., and Crystal Bishop, leaving Mayor Williams short of the 2,000 signatures that were required to become a candidate on the 2002 Democratic Party primary election ballot. The petitions had a variety of names on them that clearly were fraudulent, including actors’ names and the names of TV and cartoon characters. Many names were written and signed in the same handwriting on page after page, and all were attested to by the Bishops as the circulators of those petitions. Scott Bishop, Jr., who also signed pages dated June 31 (a nonexistent date), coordinated the petition process for the mayor. In Williams v. District of Columbia Board of Elections and Ethics, 804 A.2d 316 (D.C. 2002), the D.C. Court of Appeals held, In the circumstances of this case, where the Board found, with the support of substantial evidence in the record, that the integrity of the nominating process has been seriously compromised by the actions of the Bishop circulators, we hold that it was within the Board’s authority to disallow all of the signatures affected by the wrongdoing. At 318 (emphasis supplied). Defects either in circulation or signatures deal with matters of form and procedure, but the filing 78 As an alternative to the above analysis, the Nugent decision can be looked at as being wrongly decided on the grounds that bought votes are invalid and should not be counted. It is not clear that votes that have been bought would be counted in other states. 92