I actually agree with this brief, if it results in the following:
Electoral votes being awarded on a district-by-district basis. One vote per district. The remaining 2 electoral votes in each state being awarded to the winner of the popular vote in the state.
This way, minority-dominated district’s votes count [generally DEM] and, in blue states, GOP-DOMINATED districts have their votes counted too.
That would be the preferred outcome, but the Federal government does not have the authority to tell the states to do that. We just had a Supreme Court ruling saying that the Feddies cannot tell the states what laws to enact or not to enact.