Watson v. Republican National Committee

Majority reasoning

The majority held that the word "election" in the federal election-day statutes means the act of the electorate making its choice — that is, the act of voting — not the act of officials receiving ballots. The Court reasoned that dictionaries from the time the statutes were enacted consistently defined "election" as "the act of choosing a person to fill an office," and that the choice is complete when voters cast their ballots, not when ballots arrive at an election office. The majority also pointed to a related federal law, the Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA), which repeatedly treats ballot-receipt deadlines as a matter of state law — a structure that would make little sense if the election-day statutes already imposed a nationwide receipt deadline. The Court further noted that the Constitution itself separates the day of voting from the day of receipt in the Electoral College system, where electors vote on a uniform day but their ballots are transmitted and received later. Finally, the majority rejected the plaintiffs' historical, precedent-based, and policy arguments, finding that 19th-century voting practices do not automatically become frozen requirements of 19th-century statutes, that the key precedent (Foster v. Love) addressed a different question and did not mention ballot receipt, and that concerns about election integrity are properly addressed by legislatures, not courts.

Dissent reasoning

The dissent argued that an "election" is not complete — and the electorate's choice is not authoritatively made — until all ballots have been collected by election officials, not merely cast by individual voters. Justice Alito reasoned that because the electorate is a collective body, its choice is only expressed when the full set of ballots is in officials' hands; adding ballots received after Election Day effectively postpones the date of the election in violation of federal law. The dissent pointed to legal dictionaries from the era of the statutes' enactment that described an "election" as including both the casting and receiving of ballots, and to state court decisions holding that a vote is not complete until an official takes custody of the ballot. The dissent also argued that two centuries of unbroken historical practice — including Civil War-era states that went to great lengths to collect soldiers' ballots by Election Day even under difficult conditions — shows that "election day" was universally understood to mean ballot-collection day. The dissent further contended that the majority's reading of Foster v. Love contradicts that case's holding that an "election" requires the "combined actions of voters and officials," since under the majority's rule officials need not act until days after Election Day. Finally, the dissent warned that the ruling opens unresolved questions about how late ballots can arrive, what intermediaries may deliver them, and whether voters can recall mailed ballots before delivery, while also increasing opportunities for fraud and eroding public confidence in election results.