Will DRE Paper Trail Controversy Lead to Lawsuits?

Fallout from California Secretary of State Kevin Shelley’s decision to require a paper trail for DREs. See this Los Angeles Times report. See also reports in the Oakland Tribune; San Francisco Chronicle; San Jose Mercury News; A.P.; and Wired News.
The Mercury News article suggested possible litigation from the disability community. Although I’m not entirely clear on the theory, it appears to be that the requirement will encourage counties to buy cheaper optical scan machines, which are harder for some disabled voters to use. If there are other potential legal theories, I would like to hear about them.

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