Governor Newsom's California mail-in order is struck down as unconstitutional. Implication: California cannot certify its election before 12 December. From the ruling:

"Based on the history of special elections since 2008, it is very likely a Special Election

will become necessary in early 2021."

https://www.theepochtimes.com/california-governor-violated-the-constitution-with-mail-ballot-order-judge_3579483.html

https://beta.documentcloud.org/documents/20406790-final-ruling-in-newsom-case