Disability Law Center v. Cox, 2:25-cv-00307

Plaintiff Disability Law Center (DLC), Utah’s federally authorized protection and advocacy organization for people with disabilities, challenged Utah Senate Bill 199 (S.B. 199), which establishes a new, more restrictive guardianship process for adults with "severe intellectual disabilities."
S.B. 199 limits rights (jury trial, counsel, external oversight) for those under its guardianship framework and grants sweeping powers to guardians, including restricting association, diet, and activities without further court oversight.
DLC claims the law will hinder its advocacy activities, make it harder to find or assist affected individuals, and increase resource burdens.
DLC sought declaratory and injunctive relief against state officials and agencies, asserting violations of the ADA, Rehabilitation Act, and constitutional due process under the Fourteenth Amendment.
Defendants (Utah Governor, the State, the Judicial Council, and administrative officials) moved to dismiss the suit for lack of subject matter jurisdiction (standing, case or controversy, Eleventh Amendment immunity).
The court stayed enforcement of S.B. 199 during the litigation and ultimately granted all defendants’ motions to dismiss, finding lack of standing and no justiciable controversy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Federal Question Jurisdiction	DLC claims challenges arise under federal law (ADA, etc.).	State: Guardianships are state law; no federal question presented.	Jurisdiction exists (complaint raises federal questions).
Case or Controversy w/ Judicial Defendants	Judicial officials implement/administer S.B. 199, not just adjudicate.	Judicial officers only adjudicate, do not enforce S.B. 199; not proper defendants.	No justiciable controversy; Judicial Defendants dismissed.
Standing (Organizational & Associational)	DLC suffers organizational injury; constituents at risk.	DLC does not identify any specific member injured; organization lacks traditional members.	Organizational injury arguable, but causation lacking; no associational standing.
Eleventh Amendment/Enforcement Connection	Governor Cox has broad authority to enforce Utah laws, sufficient for suit.	S.B. 199 enforced only by private parties; Governor lacks direct enforcement role; immunity applies.	No enforcement connection; Ex parte Young exception inapplicable; state immune.

Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (articulates Article III standing requirements: injury, causation, redressability)
Hunt v. Wash. State Apple Adver. Comm’n, 432 U.S. 333 (1977) (sets associational standing requirements for organizations)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standards for plausibility in federal court)
Whole Woman’s Health v. Jackson, 595 U.S. 30 (2021) (no Ex parte Young exception when statute enforced solely by private parties)
Edelman v. Jordan, 415 U.S. 651 (1974) (state sovereign immunity bars certain suits in federal court)
Tennessee v. Lane, 541 U.S. 509 (2004) (ADA abrogates state sovereign immunity in some Title II cases)
Supreme Ct. of Virginia v. Consumers Union of U. S., Inc., 446 U.S. 719 (1980) (judicial defendants only proper when enforcing, not merely adjudicating, laws)
In re Justices of Supreme Court of Puerto Rico, 695 F.2d 17 (1st Cir. 1982) (judges not proper defendants when merely adjudicating challenged law)