Butler v. Obama, 2011 U.S. Dist. LEXIS 112814

Butler challenges ACA §1501 and 26 U.S.C. §5000A as unconstitutional, seeking injunctive and declaratory relief.
Defendants move to dismiss for lack of Article III standing and ripeness.
Court treats Butler as pro se and liberally analyzes standing requirements.
Court finds no injury-in-fact: future 2014 mandate injury is conjectural and not imminent.
No current injury from premiums: plaintiff does not pay premiums and alleged premium increases lack causation to the mandate, making standing inadequate.
Court notes leave-to-plead would be futile but offers opportunity to respond on whether to amend.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Butler has standing to challenge the individual mandate.	Butler will be forced to obtain coverage or pay a penalty in 2014.	Future injury is speculative and not imminent; no current injury.	No standing; injury not concrete or imminent.
Whether alleged premium increases confer standing.	Premium increases caused by the Act prevent him from purchasing insurance.	No direct causation or current injury; premiums unconstrained by mandate now.	No standing based on premium increases.
Whether the claim is ripe for review.	Immediate challenge to constitutionality.	Ripeness tied to standing; injury not imminent.	Not ripe; standing defective.

Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (standing requires concrete and imminent injury)
Simon v. Eastern Ky. Welfare Rights Org., 426 U.S. 26 (U.S. 1976) (injury depends on causal link and redressability)
Garelick v. Sullivan, 987 F.2d 913 (2d Cir. 1993) (injury must be fairly traceable to challenged scheme)