votes. (According to a report by The New York Times, 680 of the accepted overseas ballots were received after the legal deadline, lacked required postmarks or a witness signature or address, or were unsigned or undated, cast after election day, from unregistered voters or voters not requesting ballots, or double-counted.) Most of the post-electoral controversy revolved around Gore's request for hand recounts in four counties (Broward, Miami-Dade, Palm Beach, and Volusia), as provided under Florida state law. Harris, who also co-chaired Bush's Florida campaign, announced she would reject any revised totals from those counties if they were not turned in by 5 p.m. on November 14, the statutory deadline for amended returns. The Florida Supreme Court extended the deadline to November 26, a decision later vacated by the U.S. Supreme Court. Miami-Dade eventually halted its recount and resubmitted its original total to the state canvassing board, while Palm Beach County failed to meet the extended deadline, turning in its completed recount results at 7 p.m., which Harris rejected. On November 26, the state canvassing board certified Bush as the winner of Florida's electors by 537 votes. Gore formally contested the certified results. A state court decision overruling Gore was reversed by the Florida Supreme Court, which ordered a recount of over 70,000 ballots previously rejected as undervotes by machine counters. The U.S. Supreme Court halted that order the next day, with Justice Scalia issuing a concurring opinion that "the counting of votes that are of questionable legality does in my view threaten irreparable harm to petitioner" (Bush). On December 12, the Supreme Court ruled in a per curiam decision (asserted as a 7–2 vote) that the Florida Supreme Court's ruling requiring a statewide recount of ballots was unconstitutional on equal protection grounds, and in a 5–4 vote reversed and remanded the case to the Florida Supreme Court for modification before the optional "safe harbor" deadline, which the Supreme Court decided the Florida court had said the state intended to meet. With only two hours remaining until the December 12 deadline, the Supreme Court's order effectively ended the recount, and the previously certified total held. Even if the Supreme Court had decided differently in Bush v. Gore, the Florida Legislature had been meeting in Special Session since December 8 with the purpose of selecting of a slate of electors on December 12 should the dispute still be ongoing. Had the recount