In the election of 1960 Hawaii Republicans tried to use the December 12 “safe harbor” provision to stop a recount that eventually gave the state to Kennedy. They failed. It didn't come anywhere *near* the Supreme Court.

The Hawaii election was certified for Nixon in mid-November, but the Democrats immediately demanded a recount. A partial recount dramatically shrunk Nixon’s slight lead, and a complete recount eventually gave the election to Kennedy--but not until after the Electoral College voted on December 19, well after the “safe harbor” deadline which the Supreme Court used in its cover story as it shut down democracy in Florida.

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For the complete story by historian David Greenbergin Salon, click on the link below.