Since the 2000 Bush v. Gore decision, Florida’s voting regulations and uniformity problems have received national attention. In an effort to improve voting mechanisms at the local level, a political action committee called Sarasota Alliance for Fair Elections (SAFE) promoted an amendment to Sarasota County’s voting regulation, intending to improve the casting, counting, and canvassing of citizens’ votes. In 2006, Sarasota County voters approved the changes, but the amendment’s validity remained questionable. On appeal, the court found that the Florida Election Code regulates all of the areas that the SAFE amendment sought to regulate, and although no explicit language preempted the changes, the code implied the Legislative intent to reserve voting regulations to the state, not the individual counties. The Florida Supreme Court reversed the decision in part, refusing to recognize preemption absent explicit language in the Election Code. This Article points out the flaws and omissions that led the Court to uphold the SAFE amendment. In its analysis, the Court diminished the value of implied preemption and set aside precedent that may eventually lead to the eradication of implied preemption in Florida. If the Court continues to give less weight to the significance of implied preemption, then the Legislature must learn that adding explicit language to future statutes may be the only way to achieve uniformity in Florida law.