## Facts

- After the 2000 Census, Colorado gained a congressional seat, but the Colorado General Assembly did not enact a new congressional map; a state court implemented a plan.
- In 2003, the General Assembly enacted, and the Governor signed, a new congressional redistricting plan.
- The Colorado Supreme Court enjoined the 2003 plan under the Colorado Constitution (as interpreted to limit redistricting to once per census), concluding that the earlier court-drawn map remained effective until the next census and that this did not violate the federal Elections Clause.
- Four Colorado citizens who had not participated in the state-court case filed suit in federal district court against the Secretary of State, alleging that the state constitutional rule (as interpreted) violated the Elections Clause by preventing the legislature from exercising its role in congressional redistricting.
- The federal district court initially dismissed under Rooker–Feldman; the Supreme Court vacated and remanded, holding Rooker–Feldman did not apply.
- On remand, the district court found standing but dismissed the Elections Clause claim on issue preclusion grounds; it also dismissed a First Amendment Petition Clause claim.
- The plaintiffs took a direct appeal to the Supreme Court under 28 U.S.C. § 1253.

## Issues

1. Whether individual voters and political activists have Article III standing to bring an Elections Clause claim alleging only that the State is not complying with the Clause.
2. Whether the dismissal of the plaintiffs’ First Amendment Petition Clause claim should be disturbed on appeal.
3. Whether a federal court may dismiss on issue preclusion grounds when Article III standing is absent.

## Decision

- The Court held the plaintiffs lacked Article III standing on the Elections Clause claim because they alleged only a generalized grievance about governmental compliance with law, not a concrete and particularized injury.
- The Court vacated the judgment to the extent it dismissed the Elections Clause claim on issue preclusion grounds and remanded with instructions to dismiss that claim for lack of jurisdiction.
- The Court affirmed the dismissal of the Petition Clause claim.

## Legal Principles

- Article III standing requires an injury in fact that is concrete and particularized and actual or imminent, fairly traceable to the defendant, and likely redressable by a favorable decision.
- A plaintiff asserting only a generally available grievance about government’s alleged failure to follow the law does not present an Article III case or controversy.
- The mere assertion of an Elections Clause violation does not itself establish standing for private citizens absent a distinct, individualized injury.
- Federal courts must address jurisdictional defects (including standing) before resolving merits-adjacent defenses such as preclusion.

## Conclusion

The Court required dismissal of the Elections Clause challenge because the plaintiffs’ claim amounted to a generalized objection to the State’s redistricting process rather than a concrete, individualized injury, and it directed dismissal for lack of jurisdiction while leaving intact the dismissal of the Petition Clause claim.


Lance v. Coffman, 549 U.S. 437 (2007)