Commentary Though seven states—Pennsylvania, Georgia, Michigan, Wisconsin, Arizona, Nevada, and New Mexico—had Trump-pledged electors attend and cast votes for the Trump–Pence ticket at the Dec. 14 Electoral College sessions, these actions do not give rise to a true set of “dueling electors.” At the Electoral College—held this year on Dec. 14 at the various state capitols—Joe Biden received 306 electoral votes to Donald Trump’s 232. However, those electoral votes must be read into the Congressional record and counted at the joint session of Congress held on Jan. 6 before Biden truly becomes the “president-elect.” The Dec. 8 Safe Harbor May Be Overcome by the Electors’ Clause All 50 states and the District of Columbia qualified for the “safe harbor” set forth in the Electoral Count Act of 1887, other than Wisconsin. By certifying their electors, per their respective popular votes (however fraudulent) by the Dec. 8 “safe-harbor” deadline, the Electoral …