concurring.
This case was decided on April 8, 2008, by per curiam order, with a notation that an opinion would follow. I write separately primarily to explain my own reasons for supporting our prior order because they differ from the expression and focus of the Opinion in Support of Per Curiam Order (“OIS”); and I write because I respectfully disagree with several aspects of Mr. Justice McCaffery’s expression.
I.
We issue “opinion to follow” mandates very rarely, generally in matters where an immediate decision is required, where there is insufficient time to fashion a precedential expression, and where the issue is important enough, or difficult enough, that the Court realizes that an explanation of the original mandate is a wise course. Election appeals, and other emergency filings where swift action is required, are the most common situations where this practice is employed. I have previously addressed some of the difficulties that are unique to the expedited decisions that issue in election appeals, and have encouraged efficiencies in the courts below to ensure a better prospect for reasoned, timely decisions. See In re Fitzpatrick, *585573 Pa. 514, 827 A.2d 375, 377-84 (2003) (Castille, J., dissenting, joined by Nigro and Eakin, JJ.). Accord In re Stevenson, 12 A.3d 273 (Pa.2010) (per curiam).
There are inherent complications in the “opinion to follow” scenario. First, Justices may agree on the decisional mandate but for different reasons, making it more difficult to fashion a later majority expression in support of the already-rendered order.1 See, e.g., In re Paulmier, 594 Pa. 433, 937 A.2d 364, 377 (2007) (Saylor, J., concurring) (noting that Justice Saylor’s joinder in per curiam order in Paulmier case, which preceded explanatory opinion, was premised on different grounds than outlined in majority opinion and was consistent with reasoned expression in concurrence). Second, further research, intervening cases, and the give and take inherent in the fashioning of a precedential expression may reveal or uncover complications not fully perceived at the time the per curiam mandate issued. Indeed, it is fair to say that the Paulmier opinion reflects an instance where the Court’s deliberation following the per curiam mandate led us in a direction that was not fully perceived when the mandate issued. And finally, in election cases where the ruling below allows the candidate to remain on the ballot and the issue is novel or difficult, there is a natural imperative favoring the least disruptive mandate, which is affirmance in direct appeals or inaction in discretionary appeals. See Fitzpatrick, 827 A.2d at 384 (Castille, J., dissenting, joined by Nigro and Eakin, JJ.). See also id. at 375-77 (Lamb, J., concurring).
With these realities borne of experience in mind, I respectfully cannot join Justice McCaffery’s present explanation of our April 2008 mandate. As noted, I write first to explain the distinct reasons why I supported and continue to support *586affirmance of the Commonwealth Court’s decision in this case, and second, to address briefly specific concerns regarding the OIS reasoning.
II.
On February 11, 2008, objectors Keith Olkowski and Theresa A. Paylor filed an action in the original jurisdiction of the Commonwealth Court to set aside candidate Lawrence M. Farnese, Jr.’s nomination petition pursuant to Section 977 of the Election Code, 25 P.S. § 2937. The objectors claimed “at most 278” of the 1,778 signatures submitted by the candidate were valid and, as a result, the candidate failed to meet the statutory requirement of 500 valid signatures for appearing on the ballot. 25 P.S. § 2872.1(13). According to the objectors, (1) individual signatures had to be stricken because they were invalid on various grounds; (2) pages of signatures had to be stricken because they contained false or invalid circulator affidavits and notarization; and (3) other pages of signatures not suffering from the first two defects had to be stricken because they were gathered by circulators who had submitted invalid affidavits on other pages, or were notarized by a notary who had falsely notarized other pages. The third argument was premised on the trial court accepting a novel “pattern of fraud” or “false-in-one, false-in-all” theory. Finally, in the alternative, the objectors suggested that the entire nomination petition had to be stricken on the ground of “pervasive fraud.”2
After receiving the objectors’ petition, the Commonwealth Court, per the Honorable Rochelle S. Friedman, issued an expedited case management order and set a deadline extended to March 5, 2008, for submitting stipulations, expert reports, and witness lists. On March 5 and 6, 2008, the parties informed the court that the candidate had withdrawn twenty-*587two signature pages (for a total of 934 signatures) and that the objectors had abandoned two full-page challenges. Via the same filings, the parties stipulated to the validity or invalidity of additional signatures. At the same time, the objectors purported to “reserve the right to use” the withdrawn pages as evidence to challenge other individual pages and the entire nomination petition.
To explain the purported reservation of right, the objectors essentially made a “pattern of fraud” or “false-in-one, false-in-all” argument and asked the court to strike as invalid every signature page submitted by any circulator who had a page voluntarily withdrawn by the candidate. Similarly, the objectors argued that all the signature pages notarized by Jonathan J. Oriole had to be stricken because Mr. Oriole had falsely notarized a withdrawn page (page 33). Finally, the objectors expressed their intention to call circulators of withdrawn pages as witnesses at the March 7, 2008, hearing. According to the objectors, the circulators would be examined to reveal whether they “lied under oath” and also regarding “their understanding of the basic criteria of their oath and obligations as a circulator as defined by [Section] 909 of the Election Code[, 25 P.S. § 2869].” The objectors argued that if the circulator did not understand or follow the legal criteria, s/he lied under oath and all of that circulator’s affidavits (and signature pages) had to be stricken as invalid. In response, the candidate filed motions in limine to preclude the objectors from introducing any withdrawn signature pages into evidence, and from calling individual circulators as witnesses to impeach their credibility regarding the circulator affidavit oaths on non-withdrawn signature pages.
During the hearing, the objectors conceded that the success of their challenge to the candidate’s nomination petition depended solely on a favorable ruling by Judge Friedman regarding the candidate’s motions in limine and, implicitly, her acceptance of the objectors’ “pattern of fraud” or “false-in-one, false-in-all” theory. The objectors relied on their pattern of fraud challenge to strike the candidate’s name from the ballot, as they otherwise lacked sufficient individual signature objec*588tions. Judge Friedman entertained argument on the objectors’ theory and then granted the candidate’s motions in limine, thus precluding evidence or questioning relating to the withdrawn pages, whether offered as direct proof or for impeachment purposes. According to the court’s later opinion, the objectors’ evidence relating to the withdrawn pages was “irrelevant to whether the [cjirculator [affidavits or signatures on the non-withdrawn pages were valid” and was, for that reason, inadmissible to prove that the candidate lacked sufficient valid signatures. In re Nomination Petition of Farnese, 945 A.2d 274, 277-79 (Pa.Cmwlth.2008).
The court’s explanation of its ruling was solidly grounded in existing law. The court explained that it rejected the objectors’ evidence proffer because the underlying theory on which it was based — the “pattern of fraud” or “false-in-one, false-in-all” argument — had no support in the Election Code or case-law. Indeed, the court noted that the Election Code required each signature page to be considered individually, while case-law suggested that a circulator affidavit could at the same time be false with respect to one or even a significant percentage (e.g., 20%) of signatures but true with respect to the remaining signatures on the same page. Thus, the court reasoned, “admittedly valid signatures on one page” could not be stricken “based on a defective [circulator [affidavit on another page.” Id. (citing 25 P.S. §§ 2936, 2869, In re Pittsburgh Home Rule Charter, 694 A.2d 1128 (Pa.Cmwlth.1997), and In re Nomination Petition of Flaherty, 564 Pa. 671, 770 A.2d 327 (2001)). In a brief footnote, the court also offered that “[t]o the extent [o]bjectors argue that the circulators of the withdrawn pages appear to have engaged in fraud,” the law is well-established that “allegations of a pattern of fraud” are immaterial in the consideration of whether to strike the candidate’s nomination papers. Farnese, 945 A.2d at 278 n. 10 (citing In re Nomination Paper of Rogers, 908 A.2d 942, 947 (Pa.Cmwlth.2006), in which the court concluded that “[mjere allegations of patterns of fraud are insufficient to strike a nomination paper” and “[tjo the extent that the [ojbjectors *589allege patterns of fraud in the collection of signatures, these allegations are immaterial”).
Further, the court explained that it rejected the objectors’ request to use the withdrawn pages for impeaching the credibility of potential witnesses, i.e., circulators of both withdrawn and non-withdrawn pages, because, inter alia, “it would have been improper for [ojbjectors to use a witness’s alleged bad act with respect to a withdrawn page to prove that the witness acted in the same manner with respect to a non-withdrawn page.” Id. at 278 (citing, inter alia, Pa.R.E. 404(b)(1) (evidence of bad acts is not admissible to prove character of person in order to show action in conformity with those bad acts)). Ultimately, the court denied the petition to set aside the candidate’s nomination petition on the basis of the objectors’ concession that they could not prevail without a favorable ruling by the court on the “false-in-one, false-in-aU” theory and the admissibility of evidence regarding the withdrawn pages in support of that theory. Id. at 278-79.
On appeal to this Court, the objectors posed two questions:3
1. Did Judge Friedman err in not dismissing all Nominating Petition [sic] of circulators and striking the Nomination Petition of Mr. Farnese from the primary election ballot when the circulators had submitted many Nominating Petitions with false and fraudulent Circulators’ Affidavits and false signatures, which when challenged were withdrawn? Did Judge Friedman err in not allowing [objectors’ lawyer] to present any evidence demonstrating a serious pattern of fraud and false Affidavits by the same circulators and not strike all the Nominating Petitions? Should all of the Nominating Petitions have been stricken due to the false notary, the extensive pattern of fraud and the false Affidavits, particularly when done with the knowledge and consent of the candidate and campaign manager?
2. Did Judge Friedman err in not allowing [objectors’ lawyer] to present and question all the circulators on *590the false and withdrawn Nominating Petitions and further question them on their knowledge of the criteria and requirements of a Circulator’s circulation and Affidavit?
Although the questions are argumentative and conflated, they are essentially restatements of the objectors’ position below: ie., the objectors challenge the Commonwealth Court’s specific evidentiary rulings and its rejection of the “pattern of fraud” or “false-in-one, false-in-all” theory upon which their evidentiary proffer was made.
In my view, the objectors’ claims properly failed for several reasons. First, when this appeal was decided, this Court had not embraced any form of the objectors’ “pattern of fraud” or “false-in-one, false-in-all” theory of challenge to nomination petitions. Moreover, the lower court’s decision was supported by existing caselaw and the Election Code, and the objectors’ briefing in this Court was conclusory and largely unresponsive to the lower court’s explanation of the reasons for its decision. Objectors’ argument was long on theory, but short on authority, and marshaled nothing that suggested error in the decision below. Acceptance of the objectors’ evidentiary arguments would have represented a significant departure from existing authority in this area of law, without a sufficiently convincing argument to support that departure.
Second, adoption and retroactive application of the objectors’ novel “pattern of fraud” or “false-in-one, false-in-all” theory to this case would have been extremely disruptive and unfair. Assuming the objectors could make out their case upon remand, the consequence would have been to strike the candidate from the ballot. But, there was nothing in the governing statute or existing caselaw to put political candidates on notice that otherwise valid signatures, and an otherwise valid nomination petition, could be stricken, and the candidate removed from the ballot, premised on the objectors’ extrapolation theory. Candidates for office in Pennsylvania commonly collect signatures well in excess of the minimum required, recognizing that some signatures may be invalid, precisely in the hope of avoiding challenges. See, e.g., In re *591Nomination Petition of Morrison-Wesley, 946 A.2d 789 (Pa.Cmwlth.2008) (candidate filed approximately 2,000 signatures where 1,000 were required); In re Petition to Set Aside Nomination of Fitzpatrick, 822 A.2d 867 (Pa.Cmwlth.2003) (candidate filed approximately 1,500 signatures where 750 were required). Those candidates had no reason to believe their protective action could prove fatal to their candidacies. Even if it is assumed that the objectors’ theory had logical or equitable merit — as the objectors essentially claimed in the absence of authority — and warranted an adjustment to the existing decisional law, there was good reason to apply that new rule or construction prospectively; thus, the appropriate mandate still was affirmance here.
Finally, our time for consideration was constrained, as in all election cases, and the governing presumption is in favor of ballot access. See Flaherty, 770 A.2d at 331 (“Where the court is not convinced that challenged signatures are other than genuine, the challenge is to be resolved in favor of the candidate.”); Petition of Cioppa, 533 Pa. 564, 626 A.2d 146, 148 (1993) (Election Code “liberally construed so as not to deprive a candidate of the right to run for office or the voters of their right to elect a candidate of their choice.”). In view of all these factors, the objectors’ theory, however creative and novel, did not make a strong case for overturning the decision below, and indeed, our affirmance was unanimous.
III.
The OIS goes much farther than the analysis above, appearing to approve a form of the objectors’ “pattern of fraud” theory, but as described in Mr. Justice Saylor’s Concurring Statement in In re Payton, 596 Pa. 469, 945 A.2d 162 (2008), a case decided after our per curiam mandate issued in the case sub judice. According to the OIS, a nomination petition may be stricken if it contains a sufficiently egregious false affidavit, and if the candidate personally affirmed intentional and knowing falsehoods designed to deceive the electorate. But, in the OIS, Justice McCaffery ultimately concludes that the theory it describes is of no avail to the objectors here because Payton is *592distinguishable and the objectors failed to forward the same allegations and offer the same evidence as described in the Payton concurrence.
The excursion into this area is unnecessary. First, the Payton concurrence did not exist when we decided this case, and we did not affirm because we believed we were operating under, but distinguishing, the future and non-binding Payton concurrence. Second, as I further develop below, the parties did not argue this theory to us. And, third, since the OIS ultimately holds that the objectors waived the theory it outlines sua sponte, its excursion is pure obiter dictum. In short, rather than explaining the grounds for our decision in 2008, the OIS would fashion a prospective new rule.
As a jurisprudential matter, I have no fixed objection to the Court attempting to square this pre-Payton decision with the Payton concurrence, or with a more global view of the relevant issues, as the Court comes to a better understanding of their complexities. The value in such an effort is to provide broader guidance. Also, as I have outlined above, as a general matter a prospective rule can be less disruptive in the election arena. (Unfortunately, because the OIS ignores issues raised by the objectors in favor of drawing on the Payton concurrence, the OIS outlines a proposed prospective rule unrelated to the present appeal and through a waiver finding, which also raises the problem that the entire effort is dicta.) But, I believe our decisional explanation should and can be more closely tied to the arguments that were actually presented by the parties.4
IV.
In addition to explaining my own distinct reasons for supporting the Court’s prior mandate, I also write briefly to note *593my disagreement with several aspects of the OIS expression. In my view, the OIS strays significantly from the parties’ arguments, the factual record, and the law.
First, the objectors here presented a single narrow theory: non-withdrawn pages of a certain circulator or notary must be stricken for fraud based solely on evidence that the candidate had withdrawn a page signed by the circulator or notary. The OIS does not pass in any clear fashion upon the validity of the objectors’ theory. Instead, the OIS ventures into issues of candidate impropriety, which was not a basis for the objectors’ appeal to this Court.
Second, the objectors argued their extrapolation theory on the assumption that the withdrawn pages were part of a “pattern of fraud,” that is, they were fraudulent. The OIS fails to correct this assumption, apparently conflating withdrawn signatures with invalid signatures and then making the leap to fraud. But, withdrawn signatures are not of-record. Deeming merely withdrawn signatures to be invalid, as the OIS does, is contrary to the Election Code’s presumption of signature validity and effectively — and impermissibly — shifts the burden of proof from the objectors to the candidate. See 25 P.S. § 2937. Also, the policy of deeming withdrawn signatures invalid will likely have the undesirable effect of discouraging evidentiary stipulations and other efficiencies in election disputes. Election contests take place within narrow time-frames; withdrawing unneeded signatures by stipulation or otherwise, so as to narrow contested issues, is a salutary practice that considerably eases the burden on candidates, objectors, and the courts. See, e.g., In re Nader, 865 A.2d 8, 12-14 (Pa.Cmwlth.2004), aff'd, 580 Pa. 134, 860 A.2d 1 (2004) (per curiam) (describing Commonwealth Court’s administrative difficulties in screening candidate’s individual signatures absent stipulations).
But, even assuming that merely withdrawn signatures can be deemed defective, there is no support in the record for concluding that the withdrawn signatures in this case were fraudulent. See OIS at 9 (“we now hold that allegations and evidence of fraud may be material to the determination of the *594validity of a nomination petition”) (emphasis added).5 The Commonwealth Court made no finding of fact to that effect and, at most, the objectors conceded that the withdrawn signatures were technically defective under a strict application of Flaherty. See Flaherty, 770 A.2d at 386-37 (signature invalid if circulator who affirmed page was not present when elector signed). The sort of technical defect noted in Flaherty, on its own, would not warrant a characterization as “fraud.” Further, it is speculative to assume that the cumulative effect of technically defective signatures equates to fraud with respect to the entire nomination petition. The OIS, nonetheless, accepts the objectors’ description of the withdrawn signatures as fraudulent, with the result of distorting the factual record.
Finally, I respectfully disagree with the OIS that Nader, Payton, and Citizens Committee to Recall Rizzo v. Bd. of Elections, 470 Pa. 1, 367 A.2d 232, 241 (1976) are particularly helpful in explaining our decision of the narrow evidentiary issue that was decided in this case.
. This case, which involved election for a state office, is before the Court on direct appeal from a single-judge order of the Commonwealth Court. 42 Pa.C.S. § 723(a) (Supreme Court has exclusive jurisdiction over appeals from final orders entered by Commonwealth Court in matters commenced in original jurisdiction of that court); 42 Pa.C.S. § 764 (Commonwealth Court has exclusive original jurisdiction of all election matters related to "[s]tatewide office”); In re Vidmer, 65 Pa.Cmwlth. 562, 442 A.2d 1203, 1204 (1982), aff'd, 497 Pa. 642, 444 A.2d 100 (1982) (statewide office includes state senators).
. Although the objectors repeatedly suggested striking the entire nomination petition in the interest of maintaining "the probity and integrity” of the electoral process, they failed to develop any relevant issues of law on this point. Instead, the objectors focused primarily on the pattern of fraud claim with respect to the candidate's circulators and notary.
. The objectors also raised a third question concerning an award of costs, which is not relevant to this appeal.
. In a separate concurrence, Mr. Justice Eakin questions the necessity of the exchange between the authors of the different expressions in this case, suggesting that it is for the General Assembly to legitimize the "false-in-one, false-in-all” theory as a ground for striking the nomination petitions of electoral candidates. But, as posed, the objectors’ claim is a theory of evidence fully within this Court’s bailiwick. In my view, a proper explanation for our decision requires close attention to the parties’ actual arguments and the evidentiary theory as posed.
. It is unclear whether this prospective rule fashioned by the OIS means that "allegations and evidence of fraud,” presumably with respect to the withdrawn signatures, alone prove that otherwise unchallenged signatures are fraudulent, as the objectors claim. If, indeed, that is the prospective rule that the OIS would adopt, I note that it deeply discounts the value of those otherwise unchallenged signatures and of those respective "voters' right to elect the candidate of their choice.” In re Nomination Petition of Driscoll, 577 Pa. 501, 847 A.2d 44, 49 (2004); In re Nomination Petition of Flaherty, 564 Pa. 671, 770 A.2d 327, 331 (2001); see also Lubin v. Panish, 415 U.S. 709, 715-16, 94 S.Ct. 1315, 39 L.Ed.2d 702 (1974).