L. Lin Wood, Jr. v. Brad Raffensperger, 981 F.3d 1307

L. Lin Wood Jr., a Georgia voter, sued Secretary of State Brad Raffensperger and members of the State Election Board on November 13, 2020, challenging a March 2020 settlement that produced an Official Election Bulletin governing review of absentee-ballot signatures and related recount procedures.
Wood alleged the settlement and recount practices violated Georgia law and the U.S. Constitution (Election Clause, Electors Clause, and Equal Protection/Due Process) and sought emergency relief to bar certification, order a new recount, and change procedures for a January 2021 runoff.
The district court held a hearing on November 19 and denied Wood’s emergency motion orally; it later issued a written order finding Wood lacked standing, that laches barred his claim, and that he would not prevail on a TRO.
Georgia’s Secretary certified the November 2020 election results on November 20 and the Governor certified the state’s presidential electors the same day; the Eleventh Circuit reviewed whether it had jurisdiction to hear Wood’s appeal from the denial of emergency relief.
The Eleventh Circuit affirmed, holding Wood lacked a particularized injury (standing) and that requests to delay or undo certification and to order a new recount for the 2020 election were moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing — injury in fact	Wood: inclusion of unlawfully processed absentee ballots diluted his vote and treated absentee voters preferentially, harming him individually.	Raffensperger/Board: Wood alleges only a generalized grievance shared by all voters, not a particularized personal injury.	Held: No standing; injury is a generalized grievance, not particularized.
Mootness of relief concerning 2020 election	Wood: ongoing litigation and alleged injury mean certification does not moot his requests.	Officials: Certification and elector certification rendered requests to delay/undo certification and order a new recount moot.	Held: Requests to delay or rerun the 2020 recount/certification are moot.
Laches (delay in bringing suit)	Wood: challenge to settlement was timely as problems manifested in 2020 recount.	Officials: Wood could have sued months earlier; his two-week post-election filing was untimely.	District court found laches; appellate decision affirmed on jurisdictional grounds (standing/mootness) without relying on merits.
Emergency relief / TRO	Wood: extraordinary relief needed to prevent certification and secure proper observation/access for monitors.	Officials: Wood failed to show irreparable harm, particularized injury, or likelihood of success.	Held: TRO denied; appeal fails for lack of jurisdiction (standing) and mootness for 2020 relief.

Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires concrete, particularized injury)
Spokeo, Inc. v. Robins, 578 U.S. 330 (2016) (injury must be particularized and concrete)
Hollingsworth v. Perry, 570 U.S. 693 (2013) (generalized grievance cannot confer standing)
Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (1998) (federal courts have limited jurisdiction; must have a case or controversy)
Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (party asserting federal jurisdiction bears burden of proof)
Jacobson v. Fla. Sec’y of State, 974 F.3d 1236 (11th Cir. 2020) (vote-dilution standing discussion in election context)
Fleming v. Gutierrez, 785 F.3d 442 (10th Cir. 2015) (certification can moot election-relief requests)
Tropicana Prods. Sales, Inc. v. Phillips Brokerage Co., 874 F.2d 1581 (11th Cir. 1989) (appeal from denial of preliminary injunction may be mooted when requested effective end-date passes)
Weinstein v. Bradford, 423 U.S. 147 (1975) (capable-of-repetition-yet-evading-review doctrine elements)
Warth v. Seldin, 422 U.S. 490 (1975) (harm shared equally by a large class is not a particularized injury)