Background
Two Georgia voters, William T. Quinn and David Cross, sued the Secretary of State alleging violations of the National Voter Registration Act and Georgia state law regarding voter list maintenance. The plaintiffs conducted their own analysis comparing voter registration data to the United States Postal Service database and identified voters who appeared to have moved. They sent a notice to the Secretary requesting action but received no response. The district court dismissed the suit for lack of standing, finding the plaintiffs’ injuries were speculative and not particularized.
The court’s reasoning
The court affirmed the dismissal, holding that the plaintiffs failed to allege a particularized injury in fact. The plaintiffs argued that their personal discovery of alleged discrepancies and their resulting undermined confidence in the electoral process constituted a unique injury. The court rejected this, stating that any voter could claim equally undermined confidence based on the Secretary’s alleged failure to comply with the law. The court cited Wood v. Raffensperger, noting that an interest in ensuring that only lawful ballots are counted is a generalized grievance common to all members of the public. The court clarified that discovering potential government error by itself does not grant standing to sue.
Discovering potential government error by itself does not grant standing to sue.
Opinion of the Court, Page 10
What it means going forward
The ruling reinforces that individual voters cannot sue to enforce voter list maintenance laws based solely on a generalized interest in the state obeying the law. Plaintiffs must demonstrate a personal and individualized injury distinct from the public at large to proceed with such claims.