Mary Basile Logan v. Merrick Garland
24-3265
3rd Cir.Mar 21, 2025Background
- Mary Basile Logan, acting pro se, filed a civil lawsuit against various federal/state officials and non-government entities alleging broad constitutional and statutory violations.
- Her amended complaint exceeded 900 pages and covered allegations ranging from federal criminal violations to grievances about major U.S. events and political developments.
- Requested relief included $8 billion in damages, removal of President Biden, reinstatement of Donald Trump on the ballot, and specific voting process changes.
- All served defendants moved to dismiss for reasons including lack of standing, failure to state a claim, and lack of jurisdiction.
- The District Court dismissed all claims with prejudice, finding Logan failed to allege a concrete, particularized injury necessary for Article III standing.
- Logan appealed; appellees moved for summary affirmance, which is considered when the appeal does not present a substantial question.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Article III Standing | Logan claimed injury from broad constitutional/governmental harms | No concrete or particularized injury alleged | No standing; claims dismissed |
| Sufficiency of Pleadings | Logan asserted multiple grievances and conspiracies | Complaint lacked specific allegations of harm | Pleadings insufficient for standing or claim |
| Generalized Grievances | Claimed harm from government actions affecting all citizens | Generalized grievances do not establish standing | Generalized claims do not meet injury-in-fact requirement |
| Preliminary Injunction | Sought immediate injunctive relief related to election/voting | No likelihood of success; no injury-in-fact shown | Denial of preliminary injunctions affirmed |
Key Cases Cited
- Susan B. Anthony List v. Driehaus, 573 U.S. 149 (standard for injury-in-fact in standing requirement)
- Freedom From Religion Found. Inc. v. New Kensington Arnold Sch. Dist., 832 F.3d 469 (distinguishing generalized grievances from particularized injuries)
- Valley Forge Christian Coll. v. Ams. United for Separation of Church & State, Inc., 454 U.S. 464 (all citizens' interest in governance is not enough for standing)
- Lujan v. Defs. of Wildlife, 504 U.S. 555 (party invoking federal jurisdiction bears burden of establishing standing)
- Ariz. Christian Sch. Tuition Org. v. Winn, 563 U.S. 125 (generalized grievances about government conduct don't establish standing)