extensive project of examining almost every case cited to by Plaintiffs to piece
together the theory of standing as to this Plaintiff – the Trump Campaign.
The Trump Campaign first posits that “as a political committee for a federal
candidate,” it has “Article III standing to bring this action.”60 On its face, this
claim is incorrect. Simply being a political committee does not obviate the need
for an injury-in-fact, nor does it automatically satisfy the other two elements of
standing.
For this proposition, the Trump Campaign relies on two federal cases where
courts found associational standing by a political party’s state committee.
Therefore, the Court considers whether the Trump Campaign can raise
associational standing, but finds that those cases are inapposite.61 First, a
candidate’s political committee and a political party’s state committee are not the
same thing. Second, while the doctrine of associational standing is well
established, the Trump Campaign overlooks a particularly relevant, very recent
decision from another federal court – one where the Trump Campaign itself argued
that it had associational standing. In Donald J. Trump for President, Inc. v.
Cegavske,62 the Trump Campaign asserted associational standing, and that court
rejected this theory.
60
61
62
Doc. 170 at 11.
Texas Democratic Party v. Benkiser, 459 F.3d 582 (5th Cir. 2006); Orloski v. Davis, 564 F.
Supp. 526 (M.D. Pa. 1983).
No. 2:20-CV-1445, 2020 WL 5626974 (D. Nev. Sept. 18, 2020).
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