Voting was doubtless at first _viva voce_. In some States, particularly in the South, elections were so conducted for many years, and in Kentucky this was in accordance with a constitutional provision. For a number of reasons, however, voting by ballot was adopted in all the States, either originally, or superseding the _viva voce_ method. The written or printed ballot was gradually perverted to such degree that in 1857 the legislature of South Australia adopted an official secret ballot, printed and paid for by the public, and wholly controlled and handled by public officers. The idea was speedily carried to England, spread over Continental Europe, and at a somewhat later date reached the United States, where in some form, almost everywhere modified, it has become part of the electoral machinery in every State, under the name of Australian ballot. On first test in American courts, the system was held to be unconstitutional, but it has later been sustained almost everywhere as being merely regulative. The tendency of these laws has been to make elections more formal, and less flexible. Changes on the ballot and “scratching” are no longer possible with the ease of the old private ballot system. But in general the voter’s choice is not restricted to the names printed on the ballot. Constitutional guarantees of secrecy are not impaired by those clauses which permit aid by election officers, to the disabled or illiterate, in marking the ballot. In some States, as Tennessee and Maryland, illiterates are indirectly or partially disfranchised by laws which permit aid only to persons “that by reason of blindness or other physical disability” are unable to mark their ballots. These laws have been sustained in the highest courts. Regulations, if not too difficult in the opinion of the court, are upheld, and likewise provisions that require a party to have cast a certain percentage of the vote at the last preceding election, before it may be entitled to an official ballot. Even forcing a citizen to choose between voting under an obnoxious party heading, or not at all, is, at least in New Jersey, viewed as no deprivation of his rights. In a number of States, voting machines which automatically register the voter’s choice have been authorized, and to some extent used. At this point mention may be made of compulsory voting, which has been seriously discussed as advisable to bring out otherwise good citizens who are apathetic as to their civic responsibilities. In 1898 the people of North Dakota adopted a constitutional amendment, permitting the Legislature to impose a penalty for failure to vote.