The Resolution of Election Disputes: Legal Principles that Control Election Challenges or polling place officials actually saw the vote cast on any voter’s ballot. Rather, the wholesale failure to provide the voters with any secrecy of the ballot was seen by the court as being fundamentally unfair in George. The South Carolina Supreme Court in Taylor also may have recognized that the combination of factors that led to voiding the election in George was unlikely to recur and that holding ballot secrecy to be mandatory under all circumstances put too great a burden on the electoral process. In other words, the South Carolina Supreme Court used the overarching principle of preserving the fundamental integrity of elections to achieve a fair election ensured by the secrecy of the ballot in George. But later, in Taylor, the court returned to traditional principles of election dispute resolution to resolve cases dealing with ballot secrecy in that case and in future cases. The result was that the supreme court in Taylor effectively restricted the decision in George to its particular facts, limiting the precedential value of George’s extreme remedy of voiding an election. The Wisconsin Supreme Court in McNally combined these approaches in one decision. That court applied an overarching principle, the principle of the right to vote, to achieve a fair distribution of ballots to all county residents, while acknowledging that in most cases the more usual application of the traditional principles of election dispute resolution would be appropriate. The Wisconsin Supreme Court made a pointed comparison of the facts in McNally with an earlier decision where the result in an election with a 13-vote margin was not disturbed even though 18 voters were not permitted to vote. While the distinctions that the supreme court made between those two cases freed the McNally decision from the court’s precedents in election dispute resolution cases, the distinctions also highlighted the limitation of McNally to its facts and isolated its precedential value. It is likely that the traditional principles of election dispute resolution will be applied to future cases dealing with ballot allocation in Wisconsin, unless fairness demands otherwise. C. Votes for ineligible candidates reflect the will of the electorate. There is an old saying that there is nothing sure except death and taxes. It’s death that we will talk about here, the death of the winning candidate. Carroll H. Christian was the incumbent Treasurer of Pima County, Arizona, until he died on August 22, 1968, 19 days before the September 10, 1968, Democratic Party primary election, which he won. The results of the September 10 primary election, as related in Tellez v. Superior Court in and for County of Pima, 450 P.2d 106 (Ariz. 1969), were: Carroll H. Christian Bill Dumes Robert F. Tellez 8,087 7,864 5,209 In this case, Mr. Tellez appealed a lower court decision that ruled that Mr. Dumes was the victor and that his name should be put on the ballot as the Democratic Party nominee in the general election. The Arizona Supreme Court said that the lower court reached its decision by following the “English Rule,” which holds that votes cast for a dead person, or someone otherwise ineligible or disqualified, are 114