The Resolution of Election Disputes: Legal Principles that Control Election Challenges other extraneous markings—but to turn in a spoiled ballot and get a fresh one, and then to vote on the fresh one. But this law, the supreme court said, did not make the spoiled ballots invalid, it simply allowed voters to exchange them. And if the voters did not exchange the spoiled ballots—if they put them in the ballot box—the ballots were “not invalid so long as the voter’s intent can be ascertained and the markings were not placed on the ballot for the purpose of identifying it.” At 626 (emphasis supplied). The supreme court said that the statute that required write-in votes to be put in the proper place on the ballot served three purposes: First, it helps prevent the fraudulent alteration of ballots to conceal votes properly marked by another for a different candidate…Second, it limits the opportunity to use placement of stickers to identify the ballot…Third, it serves the obvious purpose of preserving the integrity of the ballot by insuring the vote is cast as the elector intends. At 626. The supreme court then reviewed cases from Indiana, Iowa, Maine, Massachusetts, Michigan, Minnesota, New Jersey and North Dakota that dealt with where and how stickers could be put on ballots for the votes to be valid. Most of the decisions upheld stickers that were placed in various places on the ballot as long as the material parts of the ballot could be seen, while some of the cases did not uphold the use of stickers. These decisions included cases where, for example, the sticker was put over the opposing candidate’s name. But the Iowa Supreme Court said that it would not follow the cases that required strict compliance on the placement of stickers. It also said that most of the stickers in Devine were stuck in places that “substantially complied” with the statute, including 30 ballots where the stickers were stuck over the words “Township Ticket,” because “the voters’ intent to cast these sticker votes for Devine in the board of supervisors race remains clear.” At 627. The voters’ intent to vote for Mr. Devine was also read into the 77 ballots that were marked with just Mr. Devine’s last name, or his first initial and last name. On this point, the supreme court said, [T]he issue is to be decided in light of all facts of a general public nature surrounding the election which the voter may be presumed to know and in view of which he may be presumed to have exercised his franchise. Among the circumstances bearing on the determination of voter intent are whether the write-in candidacy was well publicized and whether other candidates and other residents of the locality involved had the same or similar names. At 627 (emphasis supplied). The facts of a general public nature that the supreme court considered included Mr. Devine’s prior candidacy, the fact that none of the other 10 people in Keokuk named Devine were likely to be mistaken for the candidate, and the fact that the publicity and advertising associated with the campaign made it unlikely that people who wrote in Mr. Devine’s name in an abbreviated fashion meant their vote to go for somebody else. Of the variations of Mr. Devine’s name, the Iowa Supreme Court said, The voter’s intention, if it can be ascertained, should not be defeated or frustrated by the fact the name of the candidate is misspelled, or the wrong initials were employed, or some other slightly 96