The Resolution of Election Disputes: Legal Principles that Control Election Challenges [T]he undisputed evidence regarding all of the machines in question was that they registered total numbers of write-in votes that were consistent with the numbers registered on the machines that were never questioned. There was no basis, therefore, for an inference that these particular malfunctions were a surrogate for other, unidentified malfunctions of the process of write-in votes for the plaintiff, either on the machines in question or on the other machines in use during the election… [W]e conclude that [the evidence] falls short of establishing substantial mistakes in the count of the votes in the election. We also conclude that even if we were to regard these mistakes in the count as substantial, the evidence falls short of establishing that those mistakes rendered the reliability of the result of the election, as reported by the election officials, seriously in doubt. At 123. One year later, in In re Gray-Sadler, 753 A.2d 1101 (N.J. 2000), the same kind of machines were involved, with a very different result. Kati Gray-Sadler challenged the refusal to count 64 write-in ballots when she lost the November 2, 1999 election for Mayor of Chesilhurst Borough, New Jersey, by 20 votes, 172 to 152. Two other write-in candidates, John Sturgis and Edward Geiger, who ran for borough council lost the election by 31 and 30 votes, respectively. In this election, the write-in paper advance mechanism worked well. But 64 of the voters who tried to write in Ms. Gray-Sadler’s name wrote the name on the wrong place on the paper. So did at least 19 people who tried to write in John Sturgis’s name, and 25 people who tried to write in Edward Geiger’s name. The paper for writing a candidate’s name had specific spaces for each office on the ballot. The voters were supposed to write a candidate’s name in the space for the office for which the candidate was running. Of the 64 write-in votes that were not counted, 49 were written in by voters in blank spaces that did not specify any office: 15 of the votes were for Ms. Gray-Sadler, 19 were for Mr. Sturgis and 15 were for Mr. Geiger. Another 15 votes were written in spaces for offices other than the ones for which the write-in candidates were running: two votes for Ms. Gray-Sadler were written in spaces for candidates for the general assembly, and six votes for her were written in spaces for the borough council.38 There were written instructions on how to operate the write-in mechanism posted inside of the voting machines, but there were no mechanical models or demonstration machines available for the voters as was allowed by state law. The courts in this case focused on the instructions for writing in candidates’ names. The trial court decided that the instructions were so confusing that, in the absence of a demonstration machine, the confusing instructions constituted irregularities that deprived voters of the right to cast their ballots for the candidates of their choice. The court voided the election results and ordered a special election to be held. The appellate court reversed the trial court. Ms. Gray-Sadler, Mr. Sturgis and Mr. Geiger appealed to the New Jersey Supreme Court. The New Jersey Supreme Court said, A citizen’s constitutional right to vote for the candidate of his or her choice necessarily includes the corollary right to have that vote counted at full value without dilution or discount. The principle also encompasses “the right of all qualified electors to vote for [a write-in candidate] by such means.” To preserve those rights, our state election laws are designed to deter fraud, safeguard the secrecy of the ballot, and prevent disenfranchisement of qualified voters. In furtherance of those goals, we have held that it is our duty to construe election laws liberally. 38 The New Jersey Supreme Court’s opinion does not say how many votes Mr. Sturgis and Mr. Geiger got, or who got the other seven votes that were written in spaces for the wrong offices. 30