On January 4, 2012, the Libertarian Party filed the final brief in Libertarian Party v District of Columbia Board of Elections, 11-7029. This brief sums up the issue clearly. Does the U.S. Constitution require elections officials to count all valid votes? The D.C. Board of Elections says it costs too much to count write-ins for declared presidential candidates. Bob Barr was the only declared write-in presidential candidate in D.C. in the November 2008 election, and all the sources that print the number of votes received in that election credit him with “zero” votes, because the Board so far has refused to count them.