135 S.Ct. 42, 2014 WL 4809069. In Frank v. Walker, on September 12, the Court of Appeals for the Seventh Circuit issued a stay of a district court injunction imposed in April of 2014 that prevented the enforcement of Wisconsin's voter identification laws. 766 F.3d 755 (7th Cir.2014), reconsideration denied, 14–2058, 769 F.3d 494, 2014 WL 4827118 (7th Cir. Sept. 26, 2014). Five judges dissented from the denial of rehearing en banc, arguing that changing the rules of the election at that late date was unreasonable, whatever the merits of Wisconsin's voter identification laws. 769 F.3d at 497–501, 2014 WL 4827118, at *3–6 (Williams, J., dissenting from denial of rehearing en banc). The Supreme Court vacated the Court of Appeals' stay of the injunction, pending the outcome of Supreme Court proceedings.
Thus, in two very recent cases, courts granted injunctive relief to plaintiffs with vote-denial claims where state election laws less sweeping than North Carolina's had recently been passed. Ohio State Conference of N.A.A.C.P. v. Husted, ––– F.Supp.3d ––––, 2014 WL 4377869 (S.D.Ohio 2014), aff'd, No. 14–3877, 768 F.3d 524, 2014 WL 4724703 (6th Cir. Sept. 24, 2014), stayed, No. 14A336, Order List 573 U.S. ––––, 135 S.Ct. 42, 189 L.Ed.2d 894, 2014 WL 4809069 (U.S. Sept. 29, 2014) ; Frank v. Walker, 17 F.Supp.3d. 837, 2014 WL 1775432 (E.D.Wis.2014), stayed, 766 F.3d 755, 2014 WL 4494153 (7th Cir. Sept. 12, 2014). Under Section 2 as it exists today, showing intentional discrimination is unnecessary.