Ninth Circuit: Jeffrey Short v. Edmund G. Brown

No abuse of discretion in denial of injunction against voting-by-mail scheme, as there is no burden placed on the voters, and, under current precedent, a claim of vote dilution would have to allege a discriminatory allocation of votes, not the de minimis individual burden here.

http://cdn.ca9.uscourts.gov/datastore/opinions/2018/06/22/18-15775.pdf