until after referendum election violated their right to fair election did not allege particularized injury).
- iv. Alignment with Non-Parties
Wood further points to his status as a donor to the Republican Party whose interests are aligned with that party and its political candidates to support his standing argument. But this does not sufficiently differentiate his alleged injury from that which any voter might have suffered—no matter the party affiliation. Ostensibly, Wood believes he suffered a particularized injury because his preferred candidates—to whom he has contributed money—did not prevail in the General Election. This argument has been squarely rejected by the Eleventh Circuit. Jacobson, 974 F.3d at 1247 (“A candidate’s electoral loss does not, by itself, injure those who voted for the candidate. Voters have no judicially enforceable interest in the outcome of an election. Instead, they have an interest in their ability to vote and in their vote being given the same weight as any other.”) (internal citation omitted).
- v. Lack of Relevant Authorities
Finally, the Court notes the futility of Wood’s standing argument is particularly evident in that his sole relied-on authority—Meek v. Metropolitan Dade County, Florida, 985 F.2d 1471 (11th Cir. 1993)—is no longer good law. The Eleventh
