Guidelines for Understanding, Adjudicating, and Resolving Disputes in Elections This willingness to grant sovereign power to those who hold public office is a key aspect of all representative democracies. But, as Lord Acton said more than a century ago, “Power tends to corrupt and absolute power corrupts absolutely.”1 Thus, for a democracy to succeed, it must not only have an institutionalized system to vest sovereign power in public officials, but just as importantly, it must have a means to peacefully revoke that limited grant of power. Such a system will hopefully avoid the corruption that Lord Acton feared. The question then becomes how a democratic society establishes a system that allows for a peaceful implementation of change or, in essence, how a society can institutionalize the ability to have periodic, peaceful revolutions. The answer is the establishment of a system of regular, free, and fair elections where the people can vote for those in whom they want to vest sovereign power. The right to vote guarantees the people the right to participate in their government. Honest elections not only guarantee the right of the people to speak, but more importantly, they guarantee the people’s right to be heard. A system of free and fair elections anticipates the need for change. Elections permit adjustments in the allocation of power and provide a method for a society to correct its mistakes. Thus, for a democracy to thrive there must be a valid means to vindicate each citizen’s most important individual right — the right to vote. It has long been recognized in the United States that “the right to vote freely for the candidate of one’s choice, is the essence of a democratic society and any restriction on that right strikes at the heart of representative government.” Reynolds v. Sims, 377 U.S. 555, 84 S.Ct. 1362, 12 L.Ed.2d 500 (1964). This right to vote is precious. Palm Beach Circuit Court Judge Jorge Labarga, one of the judges involved in the 2000 Bush v. Gore presidential election dispute, said it well in one of his opinions rendered during the early stages of that election contest. Judge Labarga wrote: 1 xvi Letter to Bishop Mandell Creighton, 3 April 1887, in Louise Creighton, Life and Letters of Mandell Creighton (1904) vol. 1, ch. 13; cf. Pitt 576; 22.