The primary functions of elections are to produce winners, decide who forms governments, and make the determination of winners and governments legitimate. Legitimacy requires that governments conduct elections in a way that is objectively fair and widely perceived as fair. Therefore, a central motivation for non-partisan and uniform system of election administration is "that every citizen, every voter, be treated equally and have an equal opportunity to participate." The United States frequently appears to fall short of these goals. The highest profile example of this failure is the Florida vote in the 2000 presidential election. Michigan Representative John Conyers stated, "[o]ur broken electoral system was an accomplice to a magic trick that would make David Copperfield proud: millions of Americans went to vote on November 7, 2000, only to have their voice in our democracy disappear."