ACLU v. Lomax
In ACLU v. Lomax, the United States Court of Appeals for the Ninth Circuit found that Nevada's petition law known as the "13 counties rule" was unconstitutional. The case was decided on December 8, 2006.
The unconstitutional "13 counties rule" required that initiative petitions be signed by a number of registered voters equal to 10 percent or more of number of voters who voted at the last preceding general election in not less 13 of the 17 counties in Nevada. The court found that it was unconstitutional because it diluted the preferences of residents of densely populated counties.
In 2007, the Nevada State Legislature passed Nevada Senate Bill 549 (2007), which also has a distribution requirement. The American Civil Liberties Union filed a lawsuit against the new law in February 2008.