The Resolution of Election Disputes: Legal Principles that Control Election Challenges the wrongly decided case should be limited to its facts and therefore does not serve as precedent for cases that come after it. Some of the cases in this book can be looked at in this light. One case that is not included in this book is Bush v. Gore, 531 U.S. 98 (2000), the decision of the United States Supreme Court in the election dispute that arose in Florida during the vote count of the 2000 Presidential election between the Democratic Party nominee, Vice President Al Gore, and the Republican Party nominee, Governor George W. Bush. In Chapter 3, we discussed Jacobs v. Seminole County Canvassing Board, 773 So.2d 519 (2000), one of the Florida lawsuits that arose during the 2000 Presidential contest. In that case, the traditional principles of election dispute resolution were applied by Judge Clark and the Florida Supreme Court to resolve a challenge to the use of official county office space and resources by Republican Party operatives to correct errors they had made in printing absentee voter application ballot request forms. That case ended after the Florida Supreme Court’s decision. We also discussed Fladell v. Palm Beach County Canvassing Board, 772 So.2d 1240 (Fla. 2000), where the “butterfly ballot” was not in substantial noncompliance with the operative state statute. The other cases that were involved in contests of the 2000 Presidential election in Florida—the lawsuits that ended up in the United States Supreme Court in Bush v. Gore—also percolated through the Florida state court system and were decided by the Florida Supreme Court using the traditional principles that apply to the resolution of election disputes.94 But the United States Supreme Court did not base its decision on traditional principles of election disputes. The Supreme Court did not vitiate those traditional principles; it just said it was applying both more specific and more overarching legal authorities to the particular issues in the 2000 Presidential race. In Bush v. Gore, the United States Supreme Court said that it decided the case under United States statutes that apply to choosing Presidential electors as well as under the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. The impact of Bush v. Gore and the extent to which the decision is based on sound legal reasoning have been the subject of many and varied opinions in law review articles and books. We know that Bush v. Gore led to the enactment of the Help America Vote Act of 2002, 42 U.S.C. §§ 15301-15523, and had an immediate impact on states’ decisions to adopt voting devices. But because Bush v. Gore purports to deal with legal theories outside of the traditional principles of election dispute resolution, that analysis would take another book. For that reason, Bush v. Gore is not discussed in this book. It is fitting to end this book that way it started. As was said in the introduction, the legal principles that apply to the resolution of election disputes were derived from court decisions which, taken together, reflect a broad analytical approach to achieving certain goals: to give effect to the will of the electorate, to give effect to the desire of the voter, to avoid upsetting the results of an election (where possible), and to respect specific legislative commands. In many cases, a court’s decision depends upon how the court balances respect for legislative commands, on the one hand, and effecting the voters’ will, on the other. In sum, it is the goal of election dispute resolution to achieve, in the words of the Florida Supreme Court in Boardman v. Esteva, 323 So.2d 259, 265 (Fla. 1975), “a full, fair and free expression of the public will.” 94 Especially Boardman v. Esteva, 323 So.2d 259 (Fla. 1975), and Beckstrom v. Volusia County, 707 So.2d 720 (Fla. 1998). 134