Chapter 4 of a false affidavit by a circulator is a much more serious matter involving more than a technicality. The legislature has sought to protect the process by providing for some safeguards in the way nomination signatures are obtained and verified. Fraud in the certification destroys the safeguards unless there are strong sanctions for such conduct such as voiding of petitions with false certifications. At 319-320 (emphasis supplied). The court of appeals drew support from a 1984 decision of the Supreme Court of Arizona that relied on the decisions of courts in Ohio, Illinois, Pennsylvania, New York and New Jersey to void petitions with false certifications and refuse to count the signatures on those petitions. With those signatures discounted, Mayor Williams was unable to get on the 2002 Democratic primary ballot and was forced to run in the general election as an independent, where he won election to another term in office. B. An anti-fraud statute will not apply to ballots that could not have been involved in the fraudulent activity. States take great pains to guard against fraud in elections. Many election procedures that are enacted by states have as their primary goal the prevention of fraud. Therefore, when fraud is alleged in a lawsuit that was brought to challenge an election, the court must squarely face the statutes that were enacted to prevent against fraud and determine whether those statutes were violated, in order to determine the will of the electorate as a whole. The cases in Chapter 3 that dealt with polling place officials’ responsibility for initialing the ballot are good examples of courts determining the will of the electorate while dealing with anti-fraud statutes. Remember, for example, Johnson v. Trnka, 154 N.W.2d 185 (1967), where the Minnesota Supreme Court decided that the requirement that the ballots be initialed on the back was mandatory because the initialing was crucial to preventing fraudulent ballots from being put into the ballot box. Therefore, the six ballots that were not initialed in that election were removed, and the remaining ballots were counted to determine the will of the electorate. A similarly straightforward result was reached in Fultz v. Newkirk 475 N.E.2d 706 (Ind. 1985), where uninitialed ballots also were determined to be invalid. A trial court determined, after the examination of many contested ballots, that John D. Fultz beat Frank D. Newkirk, Sr., to become mayor of Salem, Indiana. On appeal, the Indiana Court of Appeals followed then-recent decisions in Indiana that said that the initialing requirement ensures the integrity of the voting system by guaranteeing that only valid ballots went into and came out of the ballot box. Then the appeals court affirmed the trial court’s determination that none of the absentee ballots in three precincts should be counted because they were not initialed by the poll clerks as required by a state statute. In other cases in Chapter 3, where initialing requirements were not followed, the courts did not throw out the ballots because the purpose of the requirement (preventing fraud) could not have been achieved in those cases: the ballots had not been cast in a way that exposed them to the fraudulent activity that initialing could prevent. Two of those cases are good examples of the way the courts treated the anti-fraud aspects of the initialing requirement in light of the will of the electorate. 93