The 10th Circuit's decision conflicted with an earlier May 2019 decision by the Washington Supreme Court "In re Guerra", in which three electors who had $1000 fines imposed on them for violating their pledges appealed the fines, which were upheld. In contrast to the Colorado case, the Washington court held that presidential electors are state officials under the control of state law and can be criminally punished by a state if they do not vote as they pledged. On October 7, 2019, these electors also appealed their case to the U.S. Supreme Court.