Hafner v. Lujan Grisham, 741 F.Supp.3d 1027

Eric Hafner, a federal prisoner proceeding pro se, filed suit under 42 U.S.C. § 1983 against New Mexico officials, challenging state ballot access requirements for congressional candidates.
Hafner alleged that New Mexico's requirements (signatures, fees, in-person document delivery) violated his constitutional rights by making it impossible for prisoners to appear on the ballot.
He sought a court order to have himself declared the Democratic candidate for New Mexico’s 2nd Congressional District and his name placed on the ballot for the 2024 election.
The district court screened and dismissed Hafner’s original complaint for failure to state a valid claim and lack of standing, giving him 30 days to file an amended complaint.
Hafner failed to amend or respond by the deadline, leading to dismissal of the case for lack of subject matter jurisdiction and failure to state a claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of NM's Ballot Requirements	NM’s requirements unlawfully bar him and prisoners	Requirements are constitutional	Not enough for relief—failure to state a claim
Article I, § 2 Qualification	He has a right to run for the House from New Mexico	Not an NM inhabitant, disqualified	Not an “inhabitant”, claim is frivolous
Injury-in-fact for Standing	Denied ballot access is a concrete injury	No actual candidacy or injury	No concrete or particularized injury—no standing
Redressability	Court can order placement on ballot	Not eligible, so no redress	Not reasonably able to be placed on ballot

Cnty. Court of Ulster Cnty., N.Y. v. Allen, 442 U.S. 140 (standing limited to personal rights)
Steel Co. v. Citizens for a Better Env't, 523 U.S. 83 (standing is jurisdictional, must be satisfied)
Spokeo, Inc. v. Robins, 578 U.S. 330 (injury-in-fact requires concreteness and particularization)
Carney v. Adams, 592 U.S. 53 (plaintiff must be “able and ready” to apply to establish standing)