On August 27, U.S. District Court Judge Robert Holmes Bell, a Reagan appointee, issued an injunction against a Michigan law that makes it illegal for out-of-district people to circulate a recall petition. The Michigan law also says circulators of recall petitions must be registered voters, and the injunction suspends that law also. Bogaert v Dillon, 1:08-cv-687, western district, Grand Rapids.

The Michigan state courts had upheld the challenged laws in June 2008. Thanks to Bill Hall for the news.