In his dissent, Justice Thomas argued mass mail-in voting, which was conducted in Pennsylvania for the first time ahead of the 2020 presidential election in November, combined with election rules being rewritten last minute, makes the process prone to fraud and mistrust.

"The Constitution gives to each state legislature authority to determine the 'Manner' of federal elections…Yet both before and after the 2020 election, nonlegislative officials in various States took it upon themselves to set the rules instead. As a result, we received an unusually high number of petitions and emergency applications contesting those changes. The petitions here present a clear example. The Pennsylvania Legislature established an unambiguous deadline for receiving mail-in ballots: 8 p.m. on election day," Thomas wrote.