Page:Wood v. Raffensperger (1 20-cv-04651-SDG) (2020) Opinion and Order.pdf/14

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generalized grievance about the conduct of government… [and] quite different from the sorts of injuries alleged by plaintiffs in voting rights cases where we have found standing.” Dillard v. Chilton Cnty. Comm’n, 495 F.3d 1324, 1332–33 (11th Cir. 2007) (citing Baker, 369 U.S. at 207–08). See also Lance v. Coffman, 549 U.S. 437, 440–41 (2007) (“Our refusal to serve as a forum for generalized grievances has a lengthy pedigree…. [A] generalized grievance that is plainly undifferentiated and common to all members of the public” is not sufficient for standing).

Wood alleges he has standing because he is “a qualified registered elector residing in Fulton County, Georgia” who has “made donations to various Republican candidates on the ballot for the November 3, 2020 elections, and his interests are aligned with those of the Georgia Republican Party for the purposes of the instant lawsuit.”[1] These allegations fall far short of demonstrating that Wood has standing to assert these claims.

i. The Elections and Electors Clause

Starting with his claim asserted under the Elections and Electors Clause, Wood lacks standing as a matter of law. The law is clear: A generalized grievance regarding a state government’s failure to properly follow the Elections Clause of


  1. ECF 5, ¶ 8.