International Alliance of Theater Stage Employees Local 927 v. Mashburn, 1:23-cv-04929

The International Alliance of Theater Stage Employees Local 927 challenged Georgia’s 2021 change to absentee ballot application deadlines, specifically the shift to eleven days before an election, arguing it violated federal Voting Rights Act provisions.
Plaintiff’s members often travel for work and may only learn shortly before election day that they need to vote absentee, potentially after Georgia’s new deadline.
The suit was filed against members of the Georgia State Election Board (State Defendants), in their official capacities, seeking injunctive and declaratory relief.
State Defendants moved to dismiss, arguing Plaintiff lacked standing because any injury from absentee ballot application rejection is not traceable to them, as county officials process absentee applications.
The Court evaluated standing as a facial challenge, reviewing only the facts alleged in the amended complaint, ultimately deciding on traceability and redressability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Traceability	State Defendants oversee/enforce election law, so injury is traceable to them.	County officials, not State Defendants, process/reject applications.	Not traceable; State Defendants too removed.
General Rulemaking Authority	Their broad authority over election rules creates traceability.	Rulemaking is limited; does not include absentee applications.	General authority insufficient for standing.
Enforcement Authority	State Defendants can direct county officials through penalties or rules.	Enforcement limited to compliance with current state law.	Authority too limited; no control over process.
Redressability	Injunction would prevent State Defendants from enforcing deadline or allow them to issue contrary rules.	Court order cannot bind non-party county officials; regulations must align with state law.	Not redressable; relief would not redress injury.

Lujan v. Defs. of Wildlife, 504 U.S. 555 (standing—three element test for federal courts)
Jacobson v. Florida Secretary of State, 974 F.3d 1236 (rulemaking/enforcement authority insufficient for standing if statute tasks local officials)
Simon v. E. Ky. Welfare Rights Org., 426 U.S. 26 (redressability must be likely, not speculative)
Cone Corp. v. Fla. Dep't of Transp., 921 F.2d 1190 (standing is jurisdictional for subject-matter)
Morrison v. Amway Corp., 323 F.3d 920 (standard for facial challenge to standing arguments)