Chapter 3 …By unintentional wrongdoing, we mean noncompliance with statutorily mandated election procedures in situations in which the noncompliance results from incompetence, lack of care, or, as we find occurred in this election, the election officials’ erroneous understanding of the statutory requirements. In sum, we hold that even in a situation in which a trial court finds substantial noncompliance caused by unintentional wrongdoing as we have defined it, the court is to void the election only if it finds that the substantial noncompliance resulted in doubt as to whether a certified election reflected the will of the voters. At 725 (emphasis in the original). And finally, the supreme court defined the term “gross negligence”: …[T]he term gross negligence as used in Boardman is not, as in a tort action, a measurement of the degree of care by election officials. Rather, in this context, gross negligence means negligence that is so pervasive that it thwarts the will of the people. At 725 (emphasis supplied). Thus, gross negligence is action comparable to fraud and intentional wrongdoing that can void the result of an election. Gross negligence occurs when substantial noncompliance with statutory directions by election officials prevents the expression of the will of the voters. C.2. Procedural requirements are directory after the election Note that the concept of the will of the electorate has broadened considerably from its use in Boardman. There, it was used to allow most of the absentee votes to be counted because the voters were found to be qualified, legitimate voters, even though many of the 1,450 challenged ballots that election officials accepted had technical errors. In Beckstrom, the concept of the will of the electorate was used to accept nearly four and a half times as many absentee ballots where election officials had obliterated all original evidence of the voters’ choice of candidate. This was the result because there was no proof that the election officials did not accurately mark-over the 6,500 absentee ballots, nor was there fraud in over-marking the ballots. In essence, the Florida Supreme Court decided that the directions in the state statutes on how absentee ballots are to be executed, and how to treat absentee ballots where the voters’ markings are not read by the tabulating machines, were directory after the election was over. These same directions, however, would have been held to be mandatory if the election officials’ actions were challenged before the vote count, i.e., when there still was a chance to correct those actions. It is whether or not the irregularity still can be corrected that determines whether words in a statute regulating the actions of election officials are to be read as mandatory or directory (in the absence of a specific statement that a particular action or lack of action would render a ballot invalid).61 This does not mean that after an action no longer can be corrected, when the election is over, election officials can violate the law with impunity. The Florida Supreme Court was very specific on this point in the Beckstrom decision. We expressly state that our decision in Boardman is not to be read as condoning anything less than strict adherence by election officials to the statutorily mandated election procedures…Neither Boardman nor this case concerns potential sanctions for election officials who fail to faithfully perform their duties. It is for the legislature to specify what sanction would be available for enforcement against election officials who fail to faithfully perform their duties. 61 Recall that earlier we said that this basis for the distinction between mandatory and directory provisions is commonly, although imprecisely, couched in terms of whether the irregularity occurred before or after the election. And that often in common usage most election procedures that are said to be mandatory before an election are considered to be directory once the election is over. 57