Page:Wood v. Raffensperger (1 20-cv-04651-SDG) (2020) Opinion and Order.pdf/13

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that is sought”—Town of Chester, N.Y. v. Laroe Estates, Inc., 137 S. Ct. 1645, 1650 (2017)—and shoulders “the burden of establishing [each] element[].” Lujan, 504 U.S. at 561.

Injury in fact is “the first and foremost of standing’s three elements” and requires Wood to show that he suffered “an invasion of a legally protected interest that is concrete and particularized and actual or imminent, not conjectural or hypothetical.” Spokeo, 136 S. Ct. at 1547–48. To be “particularized,” the alleged injury “must affect the plaintiff in a personal and individual way.” Lujan, 504 U.S. at 561 n.1. Wood must demonstrate “a personal stake in the outcome of the controversy,” as a federal court “is not a forum for generalized grievances.” Gill v. Whitford, 138 S. Ct. 1916, 1929 (2018). This requires more than a mere “keen interest in the issue.” Trump v. Hawaii, 138 S. Ct. 2392, 2416 (2018). The alleged injury must be “distinct from a generally available grievance about government.” Gill, 138 S. Ct. at 1923. See also id. at 1929 (explaining that a person’s “right to vote is individual and personal in nature… [t]hus [only] voters who allege facts showing disadvantage to themselves as individuals have standing to sue to remedy that disadvantage”) (quoting Reynolds v. Sims, 377 U.S. 533, 561 (1964); Baker v. Carr, 369 U.S. 186, 206 (1962)). Claims premised on allegations that “the law… has not been followed… [are] precisely the kind of undifferentiated,