OHIO STATE JOURNAL ON DISPUTE RESOLUTION [Vol. 27:2 2012] complaint can be moved to an outside ADR agency for resolution. 11 The agency then has an additional sixty days to resolve the dispute and make a final determination. 12 New York contracts with the New York State Dispute Resolution Association to resolve these complaints.13 While the system is in place, thus far no claim has been resolved through this mechanism. 14 Although neither example reflects a robust incorporation of ADR into election processes, the FEC ADR Program and HAVA's ADR mandates mark federal recognition that ADR has a place in resolving election disputes. Aside from explicit statutory mention of ADR in resolving election disputes, the most common form of non-judicial resolution of election disputes is administrative. Connecticut provides an example of a state that routes election disputes through an administrative commission before proceeding to court. IS Connecticut's State Elections Enforcement Commission is charged with policing "[any] alleged violation . .. of any provision of the general statutes relating to any election or referendum [or) primary .... " 16 In a nod to informal dispute resolution measures, Connecticut statute requires that the Commission "attempt to secure voluntary compliance, by informal methods of conference, conciliation and persuasion, with [the requirements of Connecticut election statutes]."' 7 Another example is North Carolina, where election statutes require that those who wish to file an "election protest" must file with the county board of elections for preliminary consideration, with an appeal to the state board of elections.18 Many other states require an administrative process before a party may II N.Y. ELEC. LAW§ 3-105(7) (Consol. 2011). 12 !d. 13 According to Bill McCann, Deputy Enforcement Counsel for the New York State Board of Elections, very few HA VA complaints reach the state level each year. McCann stated that the majority of complaints are resolved on the local level. 14 Since the Election Law §3- 105 was enacted, the ADR provision has never been used. McCann says that the Legislature enacted the law to provide the Board of Elections with more control and flexibility to resolve disputes and address complaints (e.g., by providing more access to the polls), but the administrative process has not yet progressed to the point where the provision is necessary. McCann noted that this provision is not particularly useful in avoiding litigation because it addresses HAVA complaints specifically; HAVA provides no right to sue in itself. New York does not have an ADR provision for any other election law complaint process. N.Y. ELEC. LAW § 3 -105 (Consol. 2011). 15 CONN. GEN. STAT.§ 9-7a(g) (2011). !6 CONN. GEN. STAT.§ 9-7b(a)(l) (2011). !7 CONN. GEN. STAT.§ 9-7b(a)(6) (2011). 18 N.C. GEN. STAT. §163-182.9-11 (2011). 328 HeinOnline -- 27 Ohio St. J. on Disp. Resol. 328 2012