574, 579 (11th Cir. 1995). But Wood bases his standing on his interest in “ensur[ing that]… only lawful ballots are counted.” An injury to the right “to require that the government be administered according to the law” is a generalized grievance. Chiles v. Thornburgh, 865 F.2d 1197, 1205–06 (11th Cir. 1989) (alteration adopted) (internal quotation marks omitted). And the Supreme Court has made clear that a generalized grievance, “no matter how sincere,” cannot support standing. Hollingsworth v. Perry, 570 U.S. 693, 706 (2013).
A generalized grievance is “undifferentiated and common to all members of the public.” Lujan, 504 U.S. at 575 (internal quotation marks omitted). Wood cannot explain how his interest in compliance with state election laws is different from that of any other person. Indeed, he admits that any Georgia voter could bring an identical suit. But the logic of his argument sweeps past even that boundary. All Americans, whether they voted in this election or whether they reside in Georgia, could be said to share Wood’s interest in “ensur[ing] that [a presidential election] is properly administered.”
Wood argues that he has two bases for standing, but neither satisfies the requirement of a distinct, personal injury. He first asserts that the inclusion of unlawfully processed absentee ballots diluted the weight of his vote. To be sure, vote dilution can be a basis for standing. Cf. Jacobson, 974 F.3d at 1247–48. But it requires a point of comparison. For example, in the racial gerrymandering and
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