One prerequisite for a functioning democracy is the ability to hold free and

fair elections. But the question of how to go about assuring such elections is quite complex. One reason why is that States must balance competing goals when en- acting election laws. On the one hand, States must ensure that everyone has an opportunity to vote; elections reflect the People’s will only if all eligible electors have a chance to make their voices heard. On the other hand, States must make certain that their elections are not tainted by fraud, improper influence, or mis- takes; they must ensure that their elections reflect voter choices, as opposed to ran- dom chance or the preferences of election administrators, party machines, and those most capable of gaming the system. These two goals can be in tension with one another. After all, the need for accurate, verifiable counting of ballots cast by qualified electors necessarily imposes some small burdens on those who wish to vote. But it is not acceptable to eliminate the tension simply by pursuing one goal rather than the other. We must achieve both.