In Bush v. Gore (2000) 531 U.S. 98, the United States Supreme Court reversed a Florida Supreme Court order to recount votes cast in the 2000 presidential election by applying an "intent of the voter" test. (Bush, supra, 531 U.S. at pp. 102-103.) The Bush court concluded this directive lacked "specific standards to ensure its equal application" and that "formulation of uniform rules to determine intent based on these recurring circumstances is practicable and . . . necessary." (Id. at pp. 105-106.) According to Ferrel, Bush implements a new and important legal principle for protecting our constitutional rights which CALJIC No. 2.90 simply does not satisfy. Bush does not express a "new view" about the equal protection clause nor does the analysis set forth in that case even apply in this very different context. The Bush court expressly limited its analysis to the unique circumstances relating to the 2000 Presidential election process in Florida and the various recount procedures developed to address those circumstances. (Bush, supra, 531 U.S. at p. 109 "Our consideration is limited to the present circumstances, for the problem of equal protection in election processes generally presents many complexities.".) Further, the equal protection problem perceived by the Bush court was that different standards would be applied by various voting precincts in Florida or even within the same precinct because the "intent of the voter" concept was not a clear standard by itself and had not been adequately defined. (Bush, supra, 531 U.S. at pp. 105-108.)