Watson v. Republican National Committee

(Slip Opinion) OCTOBER TERM, 2025 1 Syllabus NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337. SUPREME COURT OF THE UNITED STATES Syllabus WATSON, MISSISSIPPI SECRETARY OF STATE v. REPUBLICAN NATIONAL COMMITTEE ET AL. CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. 24–1260. Argued March 23, 2026—Decided June 29, 2026 The federal election-day statutes set the day for the “election” of Representatives, Senators, and the President on a Tuesday in November. See 3 U. S. C. §1, 2 U. S. C. §§ 1, 7. Mississippi permits certain residents, such as college students away from home and senior citizens, to vote in federal elections by absentee ballot. Miss. Code Ann. §23–15–713. Mississippi is one of roughly 30 States that count at least some absentee ballots mailed by election day but received af- terward. Absentee voters in Mississippi may dispatch their ballots by mail or common carrier, and all absentee ballots must be “postmarked on or before the date of the election and received by the registrar no more than five (5) business days after the election.” §§23–15– 637(1)(a), (3). In 2024, the Republican National Committee, the Mississippi Re- publican Party, and various individuals sued the Mississippi secretary of state and several election officials, contending that federal law pre- vents Mississippi from counting absentee ballots received after elec- tion day. According to plaintiffs, the election-day statutes use the word “election” to refer to two acts—ballot casting and ballot receipt—so by setting the day for the “election,” these statutes set the deadline for both. The Libertarian Party of Mississippi filed a similar suit, and the District Court consolidated the cases, and then granted summary judg- ment to Mississippi. The Fifth Circuit reversed, holding that Missis- sippi’s statute is preempted because the federal election-day statutes require ballots to be received by election day. Held: The federal election-day statutes do not prevent Mississippi from counting absentee ballots postmarked by election day but received up 2 WATSON v. REPUBLICAN NATIONAL COMMITTEE Syllabus to five days thereafter; nothing in the federal election-day statutes re- quires ballots to be received by election day. Pp. 5–21. (a) The question before the Court is narrow: whether counting bal- lots postmarked by election day, but received up to five days later, vi- olates the federal election-day statutes. Plaintiffs do not challenge the general practice of absentee voting, the use of the Postal Service or common carrier to transmit ballots, early voting, or the counting and certification of votes after election day. The Court also does not consider the scope of Congress’s authority to regulate federal elections. P. 5. (b) The federal election-day statutes do not preempt Mississippi’s law because the defining element of an “election” has always been the electorate’s choice of candidate. And a related federal statute—the Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA)— confirms that while federal law dictates when ballots must be cast, state law governs when they must be received. It is a “fundamental canon of statutory construction that words generally should be inter- preted as taking their ordinary meaning at the time Congress enacted the statute,” New Prime Inc. v. Oliveira, 586 U. S. 105, 113 (internal quotation marks and ellipses omitted), and at all relevant points, the word “election” was understood to mean “[t]he act of choosing a person to fill an office,” N. Webster, An American Dictionary of the English Language 433. The Court has likewise defined “election” as the ex- pression of the electorate’s choice, explaining that “[f]rom time imme- morial an election . . . has been . . . no more and no less than the ex- pression by qualified electors of their choice of candidates.” United States v. Classic, 313 U. S. 299, 318. The electorate’s choice is made when voting is complete, not when ballots are received. The most recent amendment to the Presidential election-day statute bears this out. While inserting the phrase “elec- tion day” into the statute and marking that date as a specific Tuesday, Congress also provided that when States “modif[y] the period of voting” in response to certain force majeure events, the term “election day” shall “include the modified period of voting.” 3 U. S. C. §21(1) (emphasis added). That Congress defined “election day” with reference to “voting” indicates that “voting” is the act governed by the statute. UOCAVA—which requires States to permit absent military and overseas voters to cast absentee ballots in federal elections and, as a backup, establishes a federal absentee voting system, 52 U. S. C. §20302(a)(1)—reinforces the point. In detailing this system, UOCAVA repeatedly presupposes ballot receipt is a matter of state law. For example, to avoid any double counting, UOCAVA provides that federal absentee ballots “shall not be counted” if a State receives the voter’s state absentee ballot by “the deadline for receipt of [that] ballot under  Cite as: 609 U. S. ___ (2026) 3 Syllabus State law.” §20303(b)(3). If the election-day statutes established a nationwide ballot-receipt deadline, UOCAVA’s references to state ballot-receipt deadlines would make little sense. Finally, this interpretation is consistent with the Constitution’s requirements for the electoral college. The Constitution requires the “Day on which [the electors] shall give their Votes” to be “the same throughout the United States,” Art. II, §1, cl. 4, but says nothing about the day for receipt. The Constitution thus envisions a system in which receipt of votes is necessarily divorced from voting. And it sets the crucial, uniform day as the day of voting while leaving receipt to happen later. The federal election-day statutes follow the same pattern. Pp. 5–9. (c) Plaintiffs’ contrary view—that the election-day statutes require ballots to be received by election day—relies heavily on historical practice, precedent, and policy. But the historical practice plaintiffs identify is not dispositive; plaintiffs overread the Court’s precedent; and policy cannot override the words Congress chose. Plaintiffs em- phasize that in the mid-to-late 19th century, ballot receipt occurred on election day, and that in the Civil War-era, States that authorized ab- sentee voting imposed strict election-day deadlines for ballot receipt. But plaintiffs admit they cannot precisely tie this historical practice to the text of the election-day statutes. State legislatures may have used an election-day deadline for any number of reasons unrelated to fed- eral requirements. For example, they may have shared plaintiffs’ view that an election-day deadline avoids the appearance of fraud from late- arriving ballots. At bottom, plaintiffs’ theory is that because 19th- century election-day statutes govern here, so too do 19th-century voting practices. But statutes do not “tra[p] in amber” every contem- porary practice on the same subject matter. United States v. Rahimi, 602 U. S. 680, 691. Plaintiffs’ interpretation of the election-day statutes is at odds with UOCAVA, which presupposes that States retain power to set ballot- receipt deadlines. At oral argument, plaintiffs and their amicus, the United States, offered ways to “reconcile” their interpretation of the election-day statutes with UOCAVA, Tr. of Oral Arg. 79–80, but their theories are unpersuasive. Plaintiffs argue that Foster v. Love’s definition of “election” as the “combined actions of voters and officials meant to make a final selection of an officeholder,” must mean the “combined actions” of ballot casting and receipt. 522 U. S. 67, 71. But Foster is not about ballot receipt and nowhere mentions it; Foster decides only that an election “may not be consummated prior to federal election day,” id., at 72, n. 4 (emphasis added), and specifically refuses to “isolat[e] precisely what acts a State must cause to be done” on election day, id., 4 WATSON v. REPUBLICAN NATIONAL COMMITTEE Syllabus at 72. Finally, plaintiffs’ policy arguments about election integrity and voter confidence are properly directed to legislatures, not courts, see, e.g., SAS Institute Inc. v. Iancu, 584 U. S. 357, 368, and regardless, plaintiffs’ definition of “election” would do little to address the concerns they identify. Pp. 9–21. (d) Plaintiffs argue that Mississippi’s election system violates the election-day statutes because the Postal Service and common carriers allow mail to be recalled before it is delivered to election officials, meaning that the electorate’s choice is not actually made as of election day. Even if plaintiffs are right about Mississippi law, they would still lose the challenge they have pressed in this litigation: that post-elec- tion-day ballot receipt is itself unlawful. Post-election-day receipt, con- sidered on its own, does not conflict with the election-day statutes, and state law is preempted only “ ‘so far as the conflict extends,’ ” Foster, 522 U. S., at 69. Pp. 21–22. 120 F. 4th 200, reversed and remanded. BARRETT, J., delivered the opinion of the Court, in which ROBERTS, C. J., and SOTOMAYOR, KAGAN, and JACKSON, JJ., joined. ALITO, J., filed a dissenting opinion, in which THOMAS and GORSUCH, JJ., joined, and in which KAVANAUGH, J., joined as to all but Parts II–C–2 and III.  Cite as: 609 U. S. ____ (2026) 1 Opinion of the Court NOTICE: This opinion is subject to formal revision before publication in the United States Reports. Readers are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. SUPREME COURT OF THE UNITED STATES _________________ No. 24–1260 _________________ MICHAEL WATSON, MISSISSIPPI SECRETARY OF STATE, PETITIONER v. REPUBLICAN NATIONAL COMMITTEE, ET AL. ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT [June 29, 2026] JUSTICE BARRETT delivered the opinion of the Court. Three federal statutes set the day for the election of Rep- resentatives, Senators, and the President. A Mississippi law permits the counting of absentee ballots postmarked by election day but received up to five days later. We must decide whether the federal election-day statutes preempt Mississippi’s law. They do not. I A The Constitution’s Elections Clause empowers state leg- islatures to “prescrib[e]” the “Times, Places and Manner of holding” congressional elections. Art. I, §4, cl. 1. Congress may “ ‘override’ ” most of these choices. Foster v. Love, 522 U. S. 67, 69 (1997) (quoting U. S. Term Limits, Inc. v. Thornton, 514 U. S. 779, 833 (1995)). By “default,” how- ever, “responsibility for the mechanics of congressional elec- tions” belongs to States. Foster, 522 U. S., at 69. As Alex- ander Hamilton put it, the Constitution lodges power over congressional elections in state legislatures “primarily” and 2 WATSON v. REPUBLICAN NATIONAL COMMITTEE Opinion of the Court in Congress “ultimately.” The Federalist No. 59, p. 362 (C. Rossiter ed. 1961). The Constitution’s system for Presidential elections is similar. State legislatures may “direct” the “Manner” of ap- pointing “Electors” to vote for President and Vice President. Art. II, §1, cl. 2. But “Congress may determine the Time of chusing the Electors, and the Day on which they shall give their Votes.” Art. II, §1, cl. 4. Initially, Congress allowed States significant leeway with respect to the timing of elections. States had a 34-day win- dow to appoint Presidential electors and exercised total con- trol over the timing of other federal elections. See Act of Mar. 1, 1792, ch. 8, §1, 1 Stat. 239; J. Stonecash, J. Bos- carino, & R. Kersh, Congressional Intrusion To Specify State Voting Dates for National Offices, 38 Publius: J. Fed- eralism 137, 141–142 (2008). As soon became clear, this scheme was not the founding generation’s finest. Fraud, or at least allegations of it, ran rampant—because States could hold elections on different days, voters could travel across the country, casting ballots in multiple States. See Cong. Globe, 28th Cong., 1st Sess., 679 (1844); J. Silbey, The American Political Nation, 1838–1893, pp. 147–148 (1991) (Silbey). So in 1845, Congress enacted the first elec- tion-day statute, setting Presidential elections for the Tues- day after the first Monday in November. Act of Jan. 23, 1845, ch. 1, 5 Stat. 721. Allegations of fraud continued to plague the election of Representatives, which still took place on different days in different States. See Cong. Globe, 42d Cong., 2d Sess., 618 (1872); H. R. Rep. No. 31, 40th Cong., 3d Sess., pt. 2, pp. 77– 78 (1869). Having one election day for the President and another for Representatives was also burdensome, because citizens were “forced to turn out” to the polls on “two differ- ent election days.” Foster, 522 U. S., at 73–74. Plus, the results in States with early elections could influence voting in States that lagged behind. Ibid. So in 1872, Congress  Cite as: 609 U. S. ____ (2026) 3 Opinion of the Court intervened again, mandating that the election of Represent- atives also take place on a single day—the same Tuesday specified in the Presidential election-day statute. Act of Feb. 2, 1872, ch. 11, §3, 17 Stat. 28. After the ratification of the Seventeenth Amendment, Congress required Sena- tors to be elected on the same day as Representatives. Act of June 4, 1914, ch. 103, §1, 38 Stat. 384. Today, each of the three election-day statutes sets the day for the “election” on a Tuesday in November. B In our Nation’s early years, voters had to cast their bal- lots in person in the district where they lived. See, e.g., J. Benton, Voting in the Field: A Forgotten Chapter of the Civil War 4–5 (1915) (Benton). Elections were “lively public events,” marked not only by “ ‘continuous electioneering and political arguments’ ” but also by “ ‘picnics, drinking, and boisterous celebration.’ ” T. El-Haj, Changing the Peo- ple: Legal Regulation and American Democracy, 86 N. Y. U. L. Rev. 1, 14 (2011) (quoting Silbey 143). Public assembly was not just a matter of merriment—it also helped ensure that only those qualified to vote did so. See, e.g., E. Evans, A History of the Australian Ballot System in the United States 48 (1917). Ballots were cast “in the company of neighbors and under the watchful eyes of community lead- ers.” D. Collins, Absentee Soldier Voting in Civil War Law and Politics 1–13 (2014) (Ph.D. Dissertation, Wayne State University) (Collins). For instance, under the Pennsylvania constitution, a voter had to vote in “an appropriate election district, in order that his neighbours might be at hand to establish his right to vote if it were challenged, or to chal- lenge if it were doubtful.” Chase v. Miller, 41 Pa. 403, 419 (1862). Things started to change during the Civil War, when some States allowed soldiers to vote from afar by absentee ballot. See Benton 4–14. Access to absentee voting 4 WATSON v. REPUBLICAN NATIONAL COMMITTEE Opinion of the Court expanded throughout the 20th century, and today, every State lets at least some residents vote absentee. In fact, federal law requires States to permit absentee voting in cer- tain circumstances. See 52 U. S. C. §10502(d). Due dates for absentee ballots have shifted over time. During the Civil War, States that allowed absentee voting imposed an election-day deadline for ballot receipt. See in- fra, at 11–12. But during World War I, States began count- ing absentee ballots received after election day. See 1918 Md. Laws p. 130; 1919 Kan. Sess. Laws pp. 252–253; see also Cal. Political Code ch. 14, §§1359(b)–(c), 1360, pp. 363– 364 (1923). Today, roughly 30 States count at least some absentee ballots mailed by election day but received after- ward. See National Conference of State Legislatures, Table 11: Receipt and Postmark Deadlines for Absentee/Mail Bal- lots (May 18, 2026), https://www.ncsl.org/elections-and- campaigns/table-11-receipt-and-postmark-deadlines-for- absentee-mail-ballots. Mississippi is among them. In Mississippi, certain resi- dents, like college students away from home and senior cit- izens, may vote in federal elections by absentee ballot. Miss. Code Ann. §23–15–713 (Cum. Supp. 2025). These vot- ers may dispatch their ballots by mail or common carrier. See §§23–15–637(1)(a), (3). All absentee ballots must be “postmarked on or before the date of the election and re- ceived by the registrar no more than five (5) business days after the election.” Ibid. In 2024, the Republican National Committee, the Missis- sippi Republican Party, and various individuals sued the Mississippi secretary of state and several election officials, contending that federal law prevents Mississippi from counting absentee ballots received after election day. Ac- cording to plaintiffs, the election-day statutes use the word “election” to refer to two acts: ballot casting and ballot re- ceipt. So by setting the day for the “election,” plaintiffs ar- gue, these statutes set the deadline for both. The  Cite as: 609 U. S. ____ (2026) 5 Opinion of the Court Libertarian Party of Mississippi filed a similar suit. The District Court consolidated the cases, then granted sum- mary judgment to Mississippi. Republican National Com- mittee v. Wetzel, 742 F. Supp. 3d 587, 601–602 (SD Miss. 2024). The Fifth Circuit reversed, holding that Mississippi’s statute is preempted because the federal election-day stat- utes require ballots to be received by election day. Repub- lican National Committee v. Wetzel, 120 F. 4th 200, 215 (2024). It denied rehearing and rehearing en banc. Repub- lican National Committee v. Wetzel, 132 F. 4th 775, 777 (2025). We granted certiorari. 607 U. S. 1020 (2025). II A The question before us is a narrow one about timing. Plaintiffs do not challenge the manner in which Mississippi carries out federal elections. They do not, for example, chal- lenge the general practice of absentee voting. Nor do they challenge the use of the Postal Service or a common carrier to transmit ballots. Although the election-day statutes refer to a particular “day” for the election, plaintiffs do not contend that every- thing must occur on that day. For instance, they do not ob- ject to early voting or dispute that officials may count votes and certify a winner after election day. Finally, this is not a case about the Constitution. We do not consider the scope of Congress’s authority to regulate federal elections. The sole question before us is whether counting ballots postmarked by election day, but received up to five days later, violates the federal election-day stat- utes. B The federal election-day statutes do not preempt Missis- sippi’s law. The defining element of an “election”—the term 6 WATSON v. REPUBLICAN NATIONAL COMMITTEE Opinion of the Court used in all three federal statutes—has always been the elec- torate’s choice of candidate. And a related federal statute, the Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA), confirms that while federal law dictates when ballots must be cast, state law dictates when they must be received. As we have said before, the federal election-day statutes “simply regulate the time of the election.” Foster, 522 U. S., at 71–72. The statute governing Presidential elections pro- vides that Presidential electors “shall be appointed, in each State, on election day, in accordance with the laws of the State enacted prior to election day.” 3 U. S. C. §1. “ ‘[E]lec- tion day’ ” is defined as the “Tuesday next after the first Monday in November, in every fourth year succeeding every election of a President and Vice President held in each State.” §21(1). The statute governing House elections “es- tablishe[s]” “the day for the election” of Representatives as the same Tuesday in November in every even-numbered year. 2 U. S. C. §7. The calendar for Senate elections fol- lows suit: Senators are “elected” at the “regular election . . . at which election a Representative to Congress is regularly by law to be chosen.” §1. By setting the day for the “election,” these statutes set the day when the electorate must make its choice. It is a “fundamental canon of statutory construction that words generally should be interpreted as taking their ordinary meaning at the time Congress enacted the statute.” New Prime Inc. v. Oliveira, 586 U. S. 105, 113 (2019) (internal quotation marks and ellipses omitted). The election-day statutes were enacted and amended across almost two cen- turies. At all relevant times, the word “election” was un- derstood to mean “[t]he act of choosing a person to fill an office.” N. Webster, An American Dictionary of the English Language 433 (C. Goodrich & N. Porter eds. 1869) (Webster 1869); see, e.g., N. Webster, An American Dictionary of the English Language 288 (rev. ed. 1844) (“[t]he act of choosing  Cite as: 609 U. S. ____ (2026) 7 Opinion of the Court a person to fill an office”); Webster’s New International Dic- tionary 706 (1914) (“[a]ct of choosing by vote a person to fill an office”); Webster’s Third New International Dictionary 731 (2002) (“the act or process of choosing a person for of- fice”). We have likewise defined “election” as the expression of the electorate’s choice. “From time immemorial,” we have observed, “an election to public office has been in point of substance no more and no less than the expression by qual- ified electors of their choice of candidates.” United States v. Classic, 313 U. S. 299, 318 (1941); see Republican National Committee v. Democratic National Committee, 589 U. S. 423, 424 (2020) (per curiam) (explaining that a “funda- menta[l]” aspect of an election is ballot “cast[ing],” as dis- tinguished from ballot “recei[pt]”). And when we inter- preted the election-day statutes for the first (and until now, the only) time, we again emphasized the voters’ choice. In Foster, we explained that “[w]hen the federal statutes speak of ‘the election’ of a Senator or Representative, they plainly refer to the combined actions of voters and officials meant to make a final selection of an officeholder.” 522 U. S., at 71 (citing Webster 1869, p. 433 (defining “election” as “[t]he act of choosing a person to fill an office”); emphasis added). The electorate’s choice is made when voting is complete, not when ballots are received. The most recent amendment to the Presidential election-day statute bears this out. In 2022, Congress inserted the phrase “election day” into that statute and marked that day as a specific Tuesday. 3 U. S. C. §21(1). It then created an exception: When States “modif[y] the period of voting” in response to certain force majeure events, the term “election day” shall “include the modified period of voting.” Ibid. (emphasis added). That Congress defined “election day” with reference to “voting” indicates that “voting” is the act governed by the statute. A related statute, UOCAVA, reinforces the point. 100 Stat. 924. It is the “most rudimentary rule” of statutory 8 WATSON v. REPUBLICAN NATIONAL COMMITTEE Opinion of the Court interpretation “that courts do not interpret statutes in iso- lation, but in the context of the corpus juris of which they are a part, including later-enacted statutes.” Branch v. Smith, 538 U. S. 254, 281 (2003) (plurality opinion). And UOCAVA confirms that while Congress has set the date by which absentee ballots must be cast, States have the power to set the date by which they must be received. UOCAVA requires States to permit absent military and overseas voters to cast absentee ballots in federal elections. 52 U. S. C. §20302(a)(1). As a backup, it establishes a fed- eral absentee voting system. In detailing this system, UOCAVA repeatedly presupposes that ballot receipt is a matter of state law. For example, it specifies that a federal absentee ballot shall not be valid if the State provides an absentee ballot “at least 60 days before the deadline for re- ceipt of the State ballot under State law.” §20303(e)(2). It also mandates that the ballots of overseas military voters be delivered “to the appropriate election officials” “not later than the date by which an absentee ballot must be received in order to be counted in the election.” §20304(b)(1). Fi- nally, to avoid any double counting, UOCAVA provides that federal absentee ballots “shall not be counted” if a State re- ceives the voter’s state absentee ballot by “the deadline for receipt of [that] ballot under State law.” §20303(b)(3). If the election-day statutes established a nationwide ballot- receipt deadline, these references to state ballot-receipt deadlines would make little sense. Finally, this interpretation of the election-day statutes is consistent with the way the Constitution treats elections. Although most voting in our country’s early days occurred in person—making casting and receipt simultaneous—that was not true of the electoral college. For that, the Consti- tution establishes a system somewhat analogous to absen- tee voting: Presidential electors “shall meet in their respec- tive States, and vote by Ballot,” and then “transmit” their votes to the “Seat of the Government of the United States,  Cite as: 609 U. S. ____ (2026) 9 Opinion of the Court directed to the President of the Senate” for “count[ing].” Art. II, §1, cl. 3. The Constitution requires the “Day on which [the electors] shall give their Votes” to be “the same throughout the United States.” Art. II, §1, cl. 4. But it says nothing about the day for receipt, and, of course, 18th-cen- tury modes of transmission did not offer same-day delivery. The Constitution therefore envisions a system in which re- ceipt is necessarily divorced from voting, and it sets the cru- cial, uniform day as the day of voting, leaving receipt to happen down the line. The federal election-day statutes fol- low the same pattern: They set when the people “shall give their Votes,” ibid., but leave open when those votes must be received.1 In sum, the election-day statutes require the electorate’s choice to be made on election day. That occurs so long as election day is the deadline for individuals to vote—as it is in Mississippi. But the election-day statutes do not set a deadline for ballot receipt, so they do not prevent Missis- sippi from counting ballots postmarked before election day yet received afterward. III Plaintiffs, echoed by the dissent, accept that the ordinary meaning of “election” is “choice.” See Brief for Respondent Libertarian Party of Mississippi 21; Brief for Republican Respondents 17–18; post, at 1–4 (opinion of ALITO, J.). Nonetheless, they argue that statutes speaking only of “choice” set a deadline for “receipt.” Short on textual sup- port for that proposition, they appeal to historical practice, precedent, and policy. But the historical practice they —————— 1 Indeed, a resolution of the Constitutional Convention equated the “Day fixed for the Election of the President” with the day when the elec- tors “should assemble to vote” and “transmit their votes.” 2 Records of the Federal Convention 665–666 (M. Farrand ed. 1911). Only later would the new Congress and President of the Senate convene for “receiv- ing, opening and counting the Votes for President.” Id., at 666. 10 WATSON v. REPUBLICAN NATIONAL COMMITTEE Opinion of the Court identify is not dispositive; they overread our precedent; and policy cannot override the words Congress chose. When it comes to the ordinary usage of the word “elec- tion,” there is no dispute. An “election” is “[t]he act of choos- ing a person to fill an office.” Brief for Respondent Liber- tarian Party of Mississippi 21 (internal quotation marks omitted); accord, post, at 3 (“agree[ing]” that an election is “the expression of the electorate’s choice” (internal quota- tion marks omitted)); Brief for Republican Respondents 17– 18 (similar).2 Still, both the dissent and plaintiffs argue that choice requires more than ballot casting. According to the dissent, ballot receipt is necessary because it renders the electorate’s choice “authoritative.” Post, at 1–2, 4. But the dissent never says what “authoritative” means, much less why ballot receipt carries this transformative power. Plaintiffs, for their part, suggest that ballot receipt is sig- nificant because it marks the point at which we can say “who won.” Tr. of Oral Arg. 72. But plaintiffs fail to explain why the electorate’s choice is not made until we “know” “who won.” Ibid. And in any event, we do not know who won when all ballots are received. Many other acts must occur first: Voter qualifications must be adjudicated, ballots authenticated, and votes counted. See Brief for Local Elec- tion Officials et al. as Amici Curiae 5–12. Plaintiffs have no statutory basis for making ballot receipt the magic mo- ment. Lacking a statutory foothold, plaintiffs (tracked closely by the dissent) pivot quickly to their primary argument: —————— 2 Although the dissent agrees that the word “election” means “choice,” it also selectively quotes from two legal dictionaries to suggest that “elec- tion” was understood to encompass ballot receipt. See post, at 5. But those dictionaries define “election” the same way we do—as “[c]hoice,” 1 J. Bouvier, Law Dictionary and Concise Encyclopedia 979 (8th ed. 1914) (Bouvier), or “[a] choosing,” W. Anderson, Dictionary of Law 394 (1889) (Anderson). The separate language quoted by the dissent—“receiving the ballots,” Bouvier 979, and “taking the votes,” Anderson 394—de- scribes the election practices of particular States.  Cite as: 609 U. S. ____ (2026) 11 Opinion of the Court historical practice. See, e.g., Brief for Respondent Libertar- ian Party of Mississippi 14–28; post, at 6–12. They empha- size that in the mid-to-late 19th century—around the en- actment of the first and second election-day statutes— ballot receipt occurred on election day. See Brief for Re- spondent Libertarian Party of Mississippi 18–19. And while one might dismiss this timing as a byproduct of in- person voting, plaintiffs insist that the advent of absentee voting proves otherwise. When some States authorized sol- diers to vote by mail during the Civil War, ballot casting and ballot receipt were no longer simultaneous—so these States could have allowed a grace period for receipt.3 But none did.4 See id., at 25; Brief for Republican Respond- ents 27. Instead, plaintiffs contend, ballots traveling through the war-torn country were not counted unless they —————— 3 Most States that authorized absentee voting during the Civil War did not permit mail-in voting. See Collins 27. Instead, they erected polling places in the field, with military officers deputized to serve as election officials. See ibid. Under this system, called field voting, soldiers voted in person (though outside their home precincts), and ballot casting and ballot receipt remained simultaneous. So while the dissent lumps all soldier voting together, see post, at 6–7, the practice in most States does not shed light on whether States thought that mail-in ballots had to be received, rather than merely cast, by election day. 4 While we accept it for the sake of argument, plaintiffs’ account of this history is debatable. Two States tasked military officers, who were not deputized as election officials, with collecting soldiers’ ballots on election day and then sending the ballots to state election officials for counting— which meant that ballots were not received into official custody until af- ter election day. 1866 Nev. Stats. p. 215; 1864 R. I. Acts & Resolves p. 4. Plaintiffs insist that these ballots were still “effectively received into of- ficial custody on Election Day” because military officers were tasked with “certify[ing] the legitimacy of the votes” before sending them. Brief for Respondent Libertarian Party of Mississippi 32. But it is not clear why collection and certification by military officers should be treated as “ef- fectiv[e] recei[pt]” by the State. Ibid. And if “effectiv[e] recei[pt]” rather than actual receipt is the standard, then why doesn’t Mississippi’s law— which requires all ballots to be received by the Postal Service or common carrier by election day—pass muster? 12 WATSON v. REPUBLICAN NATIONAL COMMITTEE Opinion of the Court were received by election day. See Brief for Respondent Libertarian Party of Mississippi 25. Why would any State be so exacting, plaintiffs ask, if federal law did not demand it? Notably, plaintiffs admit that they cannot “precisely” tie this historical practice to the text of the election-day stat- utes. Tr. of Oral Arg. 119–120. That is a delicately put understatement. Plaintiffs’ theory is that if the relevant States could have changed the rules, they would have changed the rules. Yet despite a deep dive into the histori- cal record, plaintiffs have found no evidence that any of these States wanted to extend ballot-receipt deadlines, much less that they thought federal law prevented them from doing so.5 Plaintiffs treat this “federal law made me do it” theory as obvious, but state legislatures may have used an election- day deadline for any number of reasons. For instance, they might have shared plaintiffs’ view that an election-day deadline avoids the appearance of fraud from late-arriving ballots. See D. Inbody, The Soldier Vote 41 (2016) (“Con- cern for voter fraud was always at the forefront of legisla- tive action in connection with the soldier vote”). They might have believed it essential to election integrity to open sol- dier ballots in the public’s presence, which was possible only if ballots arrived by the day the community gathered —————— 5 The dissent, which treats the inference from history as dispositive, uncritically accepts plaintiffs’ version of events. It asserts—without ci- tation—that States during the Civil War “wanted to ensure that soldiers had a voice in selecting the officials who would direct the deadly conflict in which they were engaged.” Post, at 10. Abraham Lincoln had a less rosy view: In his annual message to Congress, President Lincoln esti- mated that at least 90,000 soldiers were unable to vote in the 1864 Pres- idential elections because “the laws of [their] States” did not permit them to “vote away from their homes.” Cong. Globe, 38th Cong., 2d Sess., App. 3 (1864). That several States did not allow soldiers to vote absentee at all belies the dissent’s narrative that States did everything in their power to enable the soldier vote.  Cite as: 609 U. S. ____ (2026) 13 Opinion of the Court for in-person voting. See 1864 N. Y. Laws p. 551 (requiring soldier ballots to be “publicly opened”); 1865 Ill. Laws p. 61 (same); see also 1864 Pa. Laws No. 871, §§6, 35, pp. 991, 998 (providing that soldiers’ qualifications to vote “may be challenged” by any other voter as if “he were personally pre- sent”). They might have thought it efficient for election of- ficials to accept absentee ballots when the officials were al- ready assembled for in-person voting. See id., §34, pp. 997– 998 (soldier ballots to be opened “in the presence of the elec- tion board”). Frankly, in this first experiment with absen- tee voting, extending the deadline might not have even oc- curred to them. Habit has force, even in wartime. Plaintiffs assume that state legislatures had a single goal—enabling the soldier vote—and went as far as they could to achieve it.6 But as we have frequently observed, “[n]o statute pur- sues a single policy at all costs.” Bartenwerfer v. Buckley, 598 U. S. 69, 81 (2023). That principle applies to wartime statutes too. At bottom, plaintiffs’ theory is that because we are gov- erned by 19th-century election-day laws, we are also gov- erned by 19th-century voting practices. Carried to its logi- cal conclusion, this theory would call into question the way modern elections work. As plaintiffs acknowledge, States might need to adjudicate voter qualifications by election day, as was done in the 19th century. See Tr. of Oral Arg. 89–91. Election officials suggest that doing so would be dif- ficult, if not impossible. See Brief for Local Election Offi- cials et al. as Amici Curiae 5–12. After all, America’s pop- ulation has grown since then, as has the portion of its population eligible to vote and the practice of absentee vot- ing. The neighborhood-watch approach to election security no longer suffices; States have developed more —————— 6 The dissent dismisses the possibility that States might have had pol- icy reasons for using an election-day receipt deadline, post, at 9–11— then spends approximately six pages extolling the policy reasons for us- ing an election-day receipt deadline, post, at 16–22. 14 WATSON v. REPUBLICAN NATIONAL COMMITTEE Opinion of the Court sophisticated methods of adjudicating voter qualifications. See ibid. Early voting would also be at risk, because in the 19th century, the polls were open only on election day itself. See, e.g., Ill. Rev. Stat., ch. 37, §14 (1845); 1852 Ind. Acts p. 262; see also R. Bensel, The American Ballot Box in the Mid-Nineteenth Century 35–37 (2004). If these results were dictated by ordinary meaning, we would of course be bound to see them through. But historical practice, de- tached from statutory text, is not controlling. Statutes do not “tra[p] in amber” every contemporary practice on the same subject matter. United States v. Rahimi, 602 U. S. 680, 691 (2024). Moreover, even accepting plaintiffs’ interpretive ap- proach, it is not clear why 19th-century election practices are dispositive. Plaintiffs focus on them because the first two election-day statutes were enacted in that period. But shortly after the third statute was enacted in 1914, absen- tee