The Resolution of Election Disputes: Legal Principles that Control Election Challenges Six voters testified that they got the piece of paper from Lip or were told by him to vote for Mr. Phelps, voted, and then went to the Corner Store and got beer and/or cigarettes; a seventh voter said she was given the piece of paper and promised $5 by Lip. Of those seven voters, one said she had planned to vote for Mr. Nugent but instead sold her vote for two packs of cigarettes and voted for Mr. Phelps. Another voter said she voted as instructed by the paper because she thought that was what she was supposed to do; it was the first time she had voted. But the other five voters said that they voted the way they wanted to even though they took beer or cigarettes from Lip at the Corner Store; two of those voters said they did not vote for Mr. Phelps. The incarceration of three of Mr. Nugent’s campaigners resulted from an investigation begun the year before and involved their activities in the operation of the Winnfield Housing Authority. All three had been called before the grand jury during the week before the election, and all said that their grand jury subpoenas kept them from campaigning for Mr. Nugent. All three also said that they would have voted for Mr. Nugent had they not been in jail and prevented from voting. They could not get out of jail in order to vote because the district attorney’s office had filed a motion to deny them bond, and a bond hearing was not set until the following Monday. Mr. Nugent claimed that the district attorney, Terry Reeves, was a friend of Mayor Thornton and Mr. Phelps, and that the judge, James Wiley, was a former assistant district attorney who worked for Mr. Reeves. One of the Nugent campaigners claimed that, if he had not been in jail, he could have gotten hundreds of people to vote for Mr. Nugent. Mr. Nugent also spent the week before the election testifying under subpoena before the grand jury and was unable to campaign during that time. The trial court dismissed the case, and Mr. Nugent appealed (Judge Wiley had been scheduled to hear the case but recused himself and was replaced by another judge at trial). The Louisiana Court of Appeal had to decide whether the evidence that at least seven voters were given bribes was enough to order that seven votes be subtracted from Mr. Phelps’ vote total and change the result of the election. The statutory standard for deciding the case was that the election could be voided and a new election held if: 1. it is impossible to determine the result of the election, or 2. the number of qualified voters who were denied the right to vote by election officials was sufficient to change the result if they had been allowed to vote, or 3. the number of unqualified voters who were allowed to vote by election officials was sufficient to change the result if they had not been allowed to vote, or 4. a combination of the factors referred to in (2) and (3) would have been sufficient to change the result had they not occurred. …[A] party contesting an election no longer must show that “but for” the irregularity he would have won the election. Although a party contesting an election is no longer limited to the “but for” standard, we note that a party contesting an election still must show at least that because of fraud or irregularities, the outcome of the election is impossible to determine. Thus, it is the effect of the irregularity on determining the outcome rather than the fact of an irregularity by itself, that guides us in these matters. Accordingly, we conclude that a vote should not be cast out simply because a voter was offered a bribe, or even because a voter accepted something of value for the vote, provided that voter still voted the way he originally intended. Regardless of criminal implications, our focus is on whether the alleged activities actually changed 90