Yes, the statute is “received.” Philly and the other counties were supposed to have a hard break at 8 pm and anything “received” (that’s a word whose interpretation might become critical) after then was supposed to be set aside from the ballots already received. The SOS issued an order to the counties to do that and she had to do that because she told the Supremes she would.
Doubts that there was such a hard break, at such a relatively early time, are certainly proper here.
And reportedly not all of the counties got back to the SOS. Sounds like some blew her off.
If that’s the case, I don’t think the Supremes will take too kindly to that, either.