ruling that had extended the certification date. On December 9, the Court suspended the manual recount, in progress for only several hours, on the grounds that irreparable harm could befall Bush, according to a concurring opinion by Justice Antonin Scalia. Meanwhile, on December 6 the Republican-controlled Florida legislature convened a special session to appoint a slate of electors pledged to Bush, as the U.S. Constitution bestows upon state legislatures the duty to determine how its state's electors are appointed. On December 12, the same day as the U.S. Supreme Court ruling, the Florida House approved awarding the state's electoral votes to Bush, but the matter was moot after the Court's ruling. Some have argued that awarding the electors in this manner would be illegal. On December 13, Gore conceded the election to Bush in a nationally televised address. During the recount, controversy ensued with the discovery of various irregularities that had occurred in the voting process in several counties. Among these was the Palm Beach "butterfly ballot", which resulted in an unusually high number of votes for Reform Party candidate Pat Buchanan. Conservatives claimed that the same ballot had been successfully used in the 1996 election; in fact, it had never been used in a Palm Beach County election among rival candidates for office. Also, before the election, the Secretary of State's office had expunged tens of thousands of citizens identified as felons from the Florida voting rolls, with African-Americans identified on some counties' lists at up to five times their share of the population. Democrats claimed that many of these were not felons and should have been eligible to vote under Florida law. It was expected that had they been able to vote, most would have chosen the Democratic candidate. Additionally, this Florida election produced many more "overvotes" than usual, especially in predominantly African-American precincts in Duval County (Jacksonville), where some 21,000 ballots had multiple markings, such as two or more choices for president. Unlike the much-discussed Palm Beach County butterfly ballot, the Duval County ballot spread choices for president over two non-facing pages. At the same time that the Bush campaign was contesting hand recounts in Democratic counties, it accepted hand recounts in Republican counties that gained them 185 votes, including where Republican Party workers had been permitted to correct errors on thousands of applications for absentee ballots for Republicans. Political commentator and author Jeff Greenfield observed that