 The case was first heard in the United States District Court for the Eastern District of Pennsylvania , where , following oral arguments , the judge dismissed both Trinsey 's motion to remove Wofford and the Commonwealth 's motion to dismiss . On June 10 , 1991 , however , the District Court declared the statute unconstitutional , stating that it violated both the Fourteenth and Seventeenth Amendments due to the failure to ensure " popular participation " through the use of primary elections . This decision was reached following an analysis of the legislative history of the Seventeenth Amendment and electoral processes ; based on this analysis , the court concluded that the Pennsylvanian use of a nomination process before a special election implied a right to vote , which was violated by the lack of a primary and necessitated a strict <unk> of the legislation . After considering the evidence , the court concluded that " the interests the Commonwealth put forth in support of the statute could not <unk> the infringement of the right to vote " , leading to the conclusion that the statute governing special elections was unconstitutional . 
