Page:Wood v. Raffensperger (1 20-cv-04651-SDG) (2020) Opinion and Order.pdf/16

harm felt in precisely the same manner by every Georgia voter. As Wood conceded during oral argument, under his theory any one of Georgia’s more than seven million registered voters would have standing to assert these claims. This is a textbook generalized grievance. Bognet, 2020 WL 6686120, at *12 (“Voter Plaintiffs’ dilution claim is a paradigmatic generalized grievance that cannot support standing…. Put another way, a vote cast by fraud or mailed in by the wrong person through mistake, or otherwise counted illegally, has a mathematical impact on the final tally and thus on the proportional effect of every vote, but no single voter is specifically disadvantaged. Such an alleged dilution is suffered equally by all voters and is not particularized for standing purposes.”) (internal punctuation omitted) (collecting cases); Moore v. Circosta, No. 1:20-cv-911, 2020 WL 6063332, a *14 (M.D.N.C. Oct. 14, 2020) (“[T]he notion that a single person’s vote will be less valuable as a result of unlawful or invalid ballots being cast is not a concrete and particularized injury in fact necessary for Article III standing.”). See also Citizens for Fair Representation v. Padilla, 815 F. App’x 120, 123 (9th Cir. 2020) (dismissing equal protection claim for lack of standing and stating “the Supreme Court has consistently held that a plaintiff raising only a generally available grievance… does not state an Article III case or controversy.”).