O'Rourke v. Dominion Voting Systems

CourtCourt of Appeals for the Tenth Circuit
DecidedMay 27, 2022
Docket21-1161
StatusUnpublished

This text of O'Rourke v. Dominion Voting Systems (O'Rourke v. Dominion Voting Systems) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'Rourke v. Dominion Voting Systems, (10th Cir. 2022).

Opinion

Appellate Case: 21-1161 Document: 010110689966 Date Filed: 05/27/2022 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT May 27, 2022 _________________________________ Christopher M. Wolpert Clerk of Court KEVIN O’ROURKE; NATHANIEL L. CARTER; LORI CUTUNILLI; LARRY D. COOK; ALVIN CRISWELL; KESHA CRENSHAW; NEIL YARBROUGH; AMIE TRAPP,

Plaintiffs - Appellants,

v. No. 21-1161 (D.C. No. 1:20-CV-03747-NRN) DOMINION VOTING SYSTEMS, INC., a (D. Colo.) Delaware corporation; FACEBOOK, INC., a Delaware corporation; CENTER FOR TECH AND CIVIC LIFE; MARK E. ZUCKERBERG, individually; PRISCILLA CHAN, individually,

Defendants - Appellees. _________________________________

ORDER AND JUDGMENT* _________________________________

Before TYMKOVICH, Chief Judge, HOLMES and ROSSMAN, Circuit Judges. _________________________________

Plaintiffs appeal from the district court’s dismissal of their 42 U.S.C. § 1983

suit for lack of standing. Exercising jurisdiction under 28 U.S.C. § 1291, we affirm.

* After examining the briefs and appellate record, this panel has determined unanimously that oral argument would not materially assist in the determination of this appeal. See Fed. R. App. P. 34(a)(2); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 21-1161 Document: 010110689966 Date Filed: 05/27/2022 Page: 2

BACKGROUND

After the November 3, 2020, election for President of the United States, eight

registered voters from several states filed a class action complaint in the District of

Colorado alleging that Defendants (all private entities and individuals) had

influenced or interfered with the election in violation of various constitutional

provisions. Relying on their status as registered voters for standing, Aplt. App. A

at 98, Plaintiffs alleged that Defendants’ conduct “hurt[] every registered voter in the

country, no matter whose side the voter is on,” id. at 82; “damaged the Plaintiffs, but

more broadly, every registered voter in America, all of whom have an interest in free

and fair elections to determine the President of the United States of America,” id.

at 85; and “violated the rights of Plaintiffs and all registered voters in the United

States,” id. at 88. As recompense, they requested a declaratory judgment, a

permanent injunction enjoining Defendants “from continuing to burden the rights of

the Plaintiffs and all similarly situated registered voters,” id. at 96, and “nominal”

damages of $1,000 per registered voter, totaling approximately $160 billion, id. at 99.

Defendants Dominion Voting Systems, Inc., Facebook, Inc. (now known as

Meta Platforms, Inc.), and Center for Tech and Civic Life moved to dismiss.

Plaintiffs then moved for leave to file an amended complaint. After hearing oral

arguments on the motions, the district court dismissed the suit for lack of Article III

standing. The court held that Plaintiffs asserted a non-justiciable generalized

grievance, because “by their own admission, Plaintiffs’ claimed injuries are no

different than the supposed injuries experienced by all registered voters.” Aplt. App.

2 Appellate Case: 21-1161 Document: 010110689966 Date Filed: 05/27/2022 Page: 3

F at 1528. “Plaintiffs allege no particularized injury traceable to the conduct of

Defendants, other than their general interest in seeing elections conducted fairly and

their votes fairly counted.” Id. at 1530. The court also denied Plaintiffs’ motion to

amend, holding that their proposed amended complaint failed to remedy the lack of

standing.

DISCUSSION

I. Lack of Standing

“[T]he core component of standing is an essential and unchanging part of the

case-or-controversy requirement of Article III.” Lujan v. Defenders of Wildlife,

504 U.S. 555, 560 (1992). We review de novo a decision regarding a plaintiff’s

Article III standing. See Benham v. Ozark Materials River Rock, LLC, 885 F.3d

1267, 1272 (10th Cir. 2018). “When evaluating a plaintiff’s standing at the motion to

dismiss stage, both the trial and reviewing courts must accept as true all material

allegations of the complaint, and must construe the complaint in favor of the

complaining party.” United States v. Sup. Ct. of N.M., 839 F.3d 888, 899 (10th Cir.

2016) (brackets and internal quotation marks omitted).

It is Plaintiffs’ burden to establish their standing. Lujan, 504 U.S. at 561. To

do so, they must show three elements: (1) an injury in fact, that (2) has a causal

connection to Defendants’ action(s), and that (3) is likely to be redressed by a

favorable decision. See id. at 560-61.

This appeal involves the first requirement of injury in fact. To establish injury

in fact, Plaintiffs must show they suffered “an invasion of a legally protected

3 Appellate Case: 21-1161 Document: 010110689966 Date Filed: 05/27/2022 Page: 4

interest” that is “concrete and particularized” and “actual or imminent, not

conjectural or hypothetical.” Id. at 560 (internal quotation marks omitted).

“Particularized” “mean[s] that the injury must affect the plaintiff in a personal and

individual way.” Id. at 560 n.1.

In light of the requirement that injury be particularized, the Supreme Court has

rejected standing based only on “a generalized grievance shared in substantially

equal measure by all or a large class of citizens.” Warth v. Seldin, 422 U.S. 490, 499

(1975) (internal quotation marks omitted). That means that a plaintiff who is

“claiming only harm to his and every citizen’s interest in proper application of the

Constitution and laws, and seeking relief that no more directly and tangibly benefits

him than it does the public at large . . . does not state an Article III case or

controversy.” Lance v. Coffman, 549 U.S. 437, 439 (2007) (per curiam) (rejecting

challenge to Colorado’s state redistricting procedures) (internal quotation marks

omitted).

Plaintiffs aver that Defendants’ conduct with regard to the 2020 Presidential

election violated the constitutional rights of every registered voter in the United

States. That is a generalized grievance. See id. at 442 (holding that the plaintiffs

lacked standing because “[t]he only injury plaintiffs allege is that the law—

specifically the Elections Clause—has not been followed. This injury is precisely the

kind of undifferentiated, generalized grievance about the conduct of government that

we have refused to countenance in the past.”); see also Carney v. Adams, 141 S. Ct.

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Related

Warth v. Seldin
422 U.S. 490 (Supreme Court, 1975)
Diamond v. Charles
476 U.S. 54 (Supreme Court, 1986)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Lance v. Coffman
549 U.S. 437 (Supreme Court, 2007)
Hollingsworth v. Perry
133 S. Ct. 2652 (Supreme Court, 2013)
Benham v. Ozark Materials River Rock, LLC
885 F.3d 1267 (Tenth Circuit, 2018)
Gill v. Whitford
585 U.S. 48 (Supreme Court, 2018)
Castanon v. Cathey
976 F.3d 1136 (Tenth Circuit, 2020)
Jim Bognet v. Secretary Commonwealth of PA
980 F.3d 336 (Third Circuit, 2020)
L. Lin Wood, Jr. v. Brad Raffensperger
981 F.3d 1307 (Eleventh Circuit, 2020)
Carney v. Adams
592 U.S. 53 (Supreme Court, 2020)
Hotze v. Hudspeth
16 F.4th 1121 (Fifth Circuit, 2021)
United States v. Supreme Court of New Mexico
839 F.3d 888 (Tenth Circuit, 2016)

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O'Rourke v. Dominion Voting Systems, Counsel Stack Legal Research, https://law.counselstack.com/opinion/orourke-v-dominion-voting-systems-ca10-2022.