Conn. Citizens Def. League, Inc. v. Lamont, 6 F.4th 439

In March 2020 Governor Lamont issued Executive Order 7E permitting DESPP and municipal police to limit or suspend fingerprint collection for criminal-history checks to limit COVID-19 spread; the DESPP Commissioner suspended DESPP fingerprinting and several municipal departments followed.
Connecticut law requires fingerprints for pistol permits (local police take prints for temporary permits; DESPP may later issue state permits) and for handgun/long-gun eligibility certificates (DESPP takes prints).
Plaintiffs: five individuals were turned away by local police when seeking fingerprints and temporary pistol permits (those departments later resumed fingerprinting); one individual (Gervais) obtained a local temporary permit but alleged DESPP refused to process his state permit.
Organizational plaintiff CCDL sent advocacy letters and collected complaints; it sued alongside the individuals under 42 U.S.C. § 1983 seeking a preliminary injunction (PI) ordering repeal of EO 7E § 2 and resumption of fingerprinting.
Before the district court issued the PI, local departments resumed fingerprinting, DESPP resumed processing applications, and the Governor/Commissioner stated they would repeal § 2 / resume fingerprinting by June 15; nonetheless the district court granted a PI on June 8. The Second Circuit vacated the PI for lack of jurisdiction (mootness and lack of organizational standing).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing/mootness — Gervais	Gervais alleged DESPP refused to process his state permit despite his local temporary permit.	DESPP resumed processing before the PI, so no live injury remained.	Moot — no effectual relief available; claim dismissed as moot.
Mootness — other individual plaintiffs	Plaintiffs argued EO 7E prevented them from obtaining temporary pistol permits by blocking local fingerprinting.	Local police resumed fingerprinting and plaintiffs withdrew PI claims vs. police chiefs; defendants’ later representations to repeal/suspend do not revive a live controversy.	Moot — plaintiffs’ withdrawal of claims against police chiefs mooted their requests; voluntary-cessation exception inapplicable.
Organizational standing — CCDL	CCDL claimed it diverted resources (advocacy, letters, investigation) and was injured by EO 7E.	CCDL cannot assert members’ rights under § 1983 and did not show diversion of resources away from its ordinary activities or a likely future injury warranting injunctive relief.	No standing — CCDL failed to show perceptible impairment or likelihood of future injury; cannot pursue injunctive relief.

Janakievski v. Exec. Dir., Rochester Psychiatric Ctr., 955 F.3d 314 (2d Cir. 2020) (mootness requires that a court be able to grant effectual relief)
Knox v. Serv. Emps. Int’l Union, Loc. 1000, 567 U.S. 298 (2012) (a case is moot when no effectual relief can be granted)
City of Mesquite v. Aladdin’s Castle, Inc., 455 U.S. 283 (1982) (voluntary cessation exception to mootness)
City News & Novelty, Inc. v. City of Waukesha, 531 U.S. 278 (2001) (speculative future harm does not defeat mootness)
Friends of the Earth, Inc. v. Laidlaw Env’t Servs., 528 U.S. 167 (2000) (no license to retain jurisdiction when parties lack a continuing interest)
Mhany Mgmt., Inc. v. County of Nassau, 819 F.3d 581 (2d Cir. 2016) (showing no reasonable expectation of recurrence for voluntary cessation)
Granite State Outdoor Advert., Inc. v. Town of Orange, 303 F.3d 450 (2d Cir. 2002) (standards for voluntary cessation)
Irish Lesbian & Gay Org. v. Giuliani, 143 F.3d 638 (2d Cir. 1998) (standard of review for recurrence determinations)
Nnebe v. Daus, 644 F.3d 147 (2d Cir. 2011) (organizations cannot assert members’ rights under § 1983)
Centro de la Comunidad Hispana de Locust Valley v. Town of Oyster Bay, 868 F.3d 104 (2d Cir. 2017) (organizational standing requires perceptible impairment via diversion of resources)
Havens Realty Corp. v. Coleman, 455 U.S. 363 (1982) (diversion of resources can constitute injury for organizational standing)