two hours remaining until the December 12 deadline, the Supreme Court's order effectively ended the recount. The decision was extremely controversial due to its partisan split and the majority's unusual instruction that its judgment in Bush v. Gore should not set precedent but should be "limited to the present circumstances". Gore said he disagreed with the Court's decision, but conceded the election. Florida Secretary of State Katherine Harris's certification of the election results was thus upheld, allowing Florida's electoral votes to be cast for Bush, making him president-elect. Florida counties' recount decisions Florida Attorney General Robert Butterworth in his advisory opinion to county canvassing boards wrote: Conservative writer Andrew Sullivan in a contemporaneous article: Florida Code Section 101.5614[5] states that no vote "shall be declared invalid or void if there is a clear indication of the intent of the voter." A physical mark on a ballot, at or near a designated target, is such an indication. Post-election studies According to factcheck.org, "Nobody can say for sure who might have won. A full, official recount of all votes statewide could have gone either way, but one was never conducted." CNN and PBS reported that, had the recount continued with its existing standards, Bush would likely have still tallied more votes, but variations of those standards (and/or of which precincts were recounted) could have swung the election either way. NORC-sponsored Florida Ballot Project recount The National Opinion Research Center at the University of Chicago, sponsored by a consortium of major U.S. news organizations, conducted the Florida Ballot Project, a comprehensive review of ballots collected from the entire state, not just the disputed counties that were recounted. NORC investigators were able to examine 175,010 ballots, 99.2% of Florida's total, but county officials were unable to deliver "as many as 2,200 problem ballots" to NORC. Some counties produced their rejected ballots by rerunning all ballots through tabulation machines but were unable to deliver all problem ballots because machines accepted more ballots than previously certified and rejected fewer. The project ended up using a sample that was 1,333 votes fewer than the expected total of votes, with most of the variation in Votomatic overvotes, the ballots least likely to yield votes in a recount. The 175,010 ballots examined contained undervotes (votes with no choice made for president) and overvotes (votes made with more than one choice marked). The organization analyzed 61,190 undervotes and 113,820 overvotes.