Rohr v. State of Utah

CourtDistrict Court, D. Utah
DecidedMay 16, 2025
Docket2:24-cv-00659
StatusUnknown

This text of Rohr v. State of Utah (Rohr v. State of Utah) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rohr v. State of Utah, (D. Utah 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF UTAH

ANGELA ROHR, et al., MEMORANDUM DECISION AND ORDER DISMISSING PLAINTIFFS’ Plaintiffs, VERIFIED COMPLAINT

v. Case No. 2:24-cv-00659-AMA-DBP

STATE OF UTAH, et al., District Judge Ann Marie McIff Allen

Defendants. Magistrate Judge Dustin B. Pead

On September 9, 2024, pro se Plaintiffs filed their Emergency Motion for Temporary Restraining Order and Preliminary Injunction.1 This Court denied the motion because Plaintiffs lacked Article III injury in fact and redressability for a preliminary injunction.2 Later, the Court issued an order to show why this case should not be dismissed for lack of Article III standing.3 The parties have briefed the issue.4 For the reasons included in its prior Order,5 and as further explained below, the Court will DISMISS Plaintiffs’ Verified Complaint for lack of Article III standing.

1 Docket No. 2:24-cv-659, ECF No. 3. 2 Memorandum Decision and Order on Plaintiffs’ Emergency Motion for Temporary Restraining Order and Preliminary Injunction (“Order Denying Preliminary Injunction”), ECF No. 23. 3 Order to Show Cause, ECF No. 28. 4 Plaintiffs’ Brief, ECF No. 29; Defendants’ Response to Order to Show Cause RE: Standing (“Opp’n”), ECF No. 30; Plaintiffs’ Response to Defendants’ Response to Order to Show Cause RE: Standing (“Reply”), ECF No. 31. 5 Order Denying Preliminary Injunction, ECF No. 23. I. BACKGROUND In preparation for the 2024 General Election, Plaintiffs filed Certificates of

Nomination with the Utah Office of Lieutenant Governor seeking to be listed as presidential electors for the State of Utah, designated and pledged for the candidacy of Dr. Shiva Ayyarudai (“Dr. Shiva”) for President of the United States.6 Dr. Shiva submitted a Declaration of Candidacy to be placed on the ballot in Utah as a candidate for the office of President of the United States.7 In a letter dated July 17, 2024, the Lieutenant Governor’s Office informed Dr.

Shiva that he was disqualified from the Utah ballot because he was not a “natural born citizen” and was thus constitutionally ineligible to run for the office of President of the United States,8 which resulted in Plaintiffs’ non-selection as presidential electors. On September 9, 2024, Plaintiffs brought this suit against relevant Utah state actors under 42 U.S.C. § 1983 alleging First and Fourteenth Amendment and Due Process violations for deprivation of the right to vote as presidential electors.9

Plaintiffs seek injunctive, monetary, and declaratory relief.10 Dr. Shiva is not a party to this suit.

6 Verified Compl., ECF No. 1, at 2 ¶ 1. 7 See id. at 13 (letter sent from the Office of the Lieutenant Governor to Dr. Shiva rejecting his declaration of candidacy). 8 Id. 9 See id. at 2 ¶ 1, 7 ¶¶ 17-18, 22 ¶ 48, 29 ¶ 77 (Plaintiffs alleging that their First and Fourteenth Amendment and Due Process rights were violated because they were removed from the Utah ballot resulting in deprivation of the opportunity to vote as presidential electors in the 2024 General Election.). 10 Id. II. LEGAL STANDARD “The law of Art. III standing is built on a single basic idea – the idea of

separation of powers.” TransUnion LLC v. Ramirez, 594 U.S. 413, 422 (2021) (cleaned up, citation and quotation marks omitted). To have Article III standing to bring a claim, a plaintiff must have (1) suffered an injury in fact, (2) a traceable connection between the injury and alleged conduct, and (3) an injury that will be redressed by a favorable court decision. Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 (1992) (internal citations omitted). Plaintiffs “bear[] the burden of establishing standing as

of the time [they] brought the lawsuit and maintaining it thereafter.” Murthy v. Missouri, 603 U.S. 43, 58 (2024) (cleaned up). III. ANALYSIS A. Injury in Fact The U.S. Constitution commands that “[e]ach State shall appoint, in such

Manner as the Legislature thereof may direct, a Number of Electors . . . .” U.S. CONST. art. II, § 1, cl. 2. Relevant Utah law requires that presidential electors be “selected by” an “unaffiliated or write-in candidate for the office of President of the United States . . . .” Utah Code Ann. § 20A-13-301(1)(c). Dr. Shiva was disqualified as a candidate for the office of President of the United States. Plaintiffs were thus not selected as presidential electors. “[R]aising only a generally available grievance about

government . . . does not state an Article III case or controversy.” Lujan, 504 U.S. at 573-74. No citizen has an unfettered right to be selected as a presidential elector, therefore Plaintiffs’ grievance creates no Article III injury. Plaintiffs also allege that they were entitled to notice of removal when Dr. Shiva was disqualified from the Utah ballot.11 However, Plaintiffs’ cited statutory language refers only to notice to a candidate. Utah Code § 20A-9-202(5)(a)-(c). The

relevant candidate here, Dr. Shiva, is not a party and has not challenged his disqualification or ensuing notice. Plaintiffs may not do so for him. B. Redressability As to redressability, Plaintiffs claim that the Court may (1) enjoin Plaintiffs’ removal from the Utah ballot and the printing of ballots for the election; (2) award monetary damages; and, (3) declare that the state erroneously removed Plaintiffs

from the Utah ballot because they could have become electors to vote for whomever they chose, and that the state prematurely adjudicated the matter.12 1. Injunctive Relief As explained in the Court’s previous Order, Utah’s legislature elected to have the candidate running for the office of President of the United States appoint presidential electors. Utah Code Ann. § 20A-13-301(1)(c). That Plaintiffs have

expended time, effort, and resources to qualify for this appointment is unfortunate, but it cannot change the Constitution’s delegated authority to the state legislature to facilitate elector appointments. As the Court stated in its previous decision, “[n]o command from this Court can confer presidential electorship on the Plaintiffs.”13

11 Verified Compl., ECF No. 1, at 28. 12 Verified Compl., ECF No. 1, at 3; Reply, ECF No. 31, at 5-6. 13 Order Denying Preliminary Injunction, ECF No. 23, at 7. 2. Monetary Damages Plaintiffs do not specify the type of monetary damages they seek, so the Court

will read the request broadly, consistent with its duty to construe pro se filings liberally. Lundahl v. Halabi, 600 Fed. Appx. 596, 600-01 (10th Cir. 2014) (internal citations omitted). Plaintiffs may mean nominal, compensatory, or punitive damages. Plaintiffs may also refer to their request for attorney’s fees and costs. Plaintiffs’ allegations are not redressable by nominal, compensatory, or punitive damages because they do not sufficiently allege an actual injury or violation of a federally-protected legal right. Uzuegbunam v. Preczewski, 592 U.S. 279, 292

(2021) (“[A] request for nominal damages satisfies the redressability element of standing where a plaintiff’s claim is based on a completed violation of a legal right.”); Memphis Cmty. Sch. Dist. v. Stachura, 477 U.S. 299, 308 (1986) (“no compensatory damages c[an] be awarded for violation of [a constitutional] right absent proof of actual injury.”); Evans v.

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