On September 9, the U.S. Court of Appeals refused to disturb the U.S. District Court’s injunctive relief in Bogaert v Land. The case number in the 6th Circuit is 08-2130. The District Court had ruled that it is unconstitutional to tell circulators that they can’t work on a recall petition unless they live in the district of the office-holder who is being recalled. Thanks to Thomas Jones for this news.