Darrell Prince v. United States Government, 697 F. App'x 134

Pro se plaintiff Darrell Prince filed a complaint in December 2016 challenging the 2016 presidential election results and alleging flawed apportionment of Electoral College voters and federal representatives and potential Emoluments Clause violations by President-elect Trump.
Prince sought an immediate delay of Electoral College proceedings pending resolution of these claims.
The District Court dismissed the complaint sua sponte for lack of Article III standing and denied leave to amend.
Prince appealed; the Third Circuit reviewed the dismissal de novo (plenary review).
The Third Circuit found the case governed by standing principles requiring a concrete, particularized, and actual or imminent injury and concluded Prince lacked any injury unique to him.
The court affirmed the dismissal and denied oral argument; it noted some claims might be moot but resolved the appeal on standing grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to challenge presidential election/apportionment	Prince asserted injury from flawed apportionment and electoral process affecting election outcome	No individualized, concrete injury; complaint raises only generalized public grievance	Dismissed for lack of standing; plaintiff’s harm was generalized, not particularized
Ability of private citizen to seek injunctive relief delaying Electoral College	Requested immediate delay of Electoral College to resolve alleged defects	Relief sought would benefit public broadly, not provide direct, tangible benefit to Prince	Denied — no Article III case or controversy because remedy would not redress a particularized injury
Challenge to President’s eligibility / Emoluments concerns	Claimed President’s financial holdings created unprecedented emoluments risk and constitutional violations	Such allegations do not create a distinct injury to Prince as an individual	Dismissed for lack of standing; similar claims previously held non-justiciable by private parties
Leave to amend after sua sponte dismissal	Implied request to amend to cure defects	District Court declined to grant leave; argued lack of particularized injury could not be cured	Third Circuit held District Court did not abuse discretion in denying leave to amend

N. Jersey Brain & Spine Ctr. v. Aetna, Inc., 801 F.3d 369 (3d Cir. 2015) (plenary review of standing dismissals)
Susan B. Anthony List v. Driehaus, 134 S. Ct. 2334 (2014) (standing requires injury-in-fact, causation, redressability)
Finkelman v. Nat'l Football League, 810 F.3d 187 (3d Cir. 2016) (standing principles)
Toll Bros., Inc. v. Twp. of Readington, 555 F.3d 131 (3d Cir. 2009) (injury-in-fact often dispositive)
Blunt v. Lower Merion Sch. Dist., 767 F.3d 247 (3d Cir. 2014) (concrete and particularized injury requirement)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (foundational standing doctrine)
Lance v. Coffman, 549 U.S. 437 (2007) (generalized grievances do not confer standing)
Warth v. Seldin, 422 U.S. 490 (1975) (generalized grievance rule)
Berg v. Obama, 586 F.3d 234 (3d Cir. 2009) (private plaintiffs lack standing to challenge president's eligibility)
Grayson v. Mayview State Hosp., 293 F.3d 103 (3d Cir. 2002) (denial of leave to amend reviewed for abuse of discretion)