Greenbaum v. Bailey, 781 F.3d 1240

Intervenor-appellant Committee appeals district court ruling striking § 4(f) of Article XIII, § 4 as unconstitutional.
Giant Cab moved to dismiss for lack of standing; committee argues it can enforce § 4(f), giving it a stake.
District court held § 4(f) violates First Amendment; judgment limited to the specific prohibition on corporate and entity contributions.
Board and Bailey initially defendants; they did not appeal; committee later sought declaratory relief and enforcement rights.
On appeal, the committee lacked independent standing after Bailey and Board failed to appeal; the case proceeded only with Giant Cab.
Issue presented: whether the committee has Article III standing to appeal given its role and the enforcement structure of the Albuquerque Election Code.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the Committee have independent standing to appeal?	Committee: has enforcement power, direct stake.	Giant Cab: no personal stake; committee lacks enforcement power.	Committee lacks standing; appeal dismissed.
Is the Committee’s appeal moot or barred by lack of enforcement rights?	Committee seeks to vindicate constitutional validity and enforce § 4(f).	Board enforces Election Code; committee cannot compel enforcement.	Appeal dismissed for lack of standing; mootness not reached.

Hollingsworth v. Perry, 133 S. Ct. 2652 (2013) (private petitioners lacked standing to defend constitutionality when state officials did not appeal)
City of Colorado Springs v. Climax Molybdenum Co., 587 F.3d 1071 (10th Cir. 2009) (intervenor standing may piggyback or show independent standing)
San Juan County v. United States, 503 F.3d 1163 (10th Cir. 2007) (en banc: intervenor may piggyback when party with standing remains)
Bishop v. Smith, 760 F.3d 1070 (10th Cir. 2014) (standing analysis remains; declaratory judgment does not confer standing)
Utah Animal Rights Coalition v. Salt Lake County, 566 F.3d 1236 (10th Cir. 2009) (actual injury traceable to defendant required for standing)