Wading into the definition of “willful” in the context of election law, the U.S. Court of Appeals for the Third Circuit has vacated two criminal counts that Kenneth Smukler, an election lawyer and former aide to Rep. Bob Brady, D-Pennsylvania, was convicted on in connection with work he did during the 2012 and 2014 congressional races.

The unanimous three-judge panel, however, left in place seven of the nine counts that Smukler was convicted on.

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