Segovia v. United States, 880 F.3d 384

Plaintiffs are former Illinois residents who now live in Guam, Puerto Rico, and the U.S. Virgin Islands and seek absentee ballots for federal elections in Illinois.
UOCAVA requires states to provide absentee ballots to former residents who "reside outside the United States." Illinois law defines "outside the territorial limits of the United States" in a way that treats Puerto Rico, Guam, and the Virgin Islands as "United States" territory (ineligible for UOCAVA treatment) but treats some territories differently (e.g., Northern Mariana Islands treated as overseas historically).
As a result, plaintiffs are ineligible under Illinois law to receive federal absentee ballots, while certain other former Illinois residents who moved to different territories could be eligible.
Plaintiffs sued federal and state officials alleging violations of Equal Protection and the Due Process right to travel; district court granted summary judgment for defendants; plaintiffs appealed.
Seventh Circuit: affirmed state-law ruling (Illinois law constitutional), but held plaintiffs lack Article III standing to challenge the federal UOCAVA because their injury is caused by Illinois law, not the federal statute; remanded to dismiss federal claims for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to challenge UOCAVA	UOCAVA’s territorial distinctions deny plaintiffs ballots; federal law causes injury	Injury flows from Illinois law; federal statute does not prevent Illinois from granting ballots	No standing: injury not fairly traceable to UOCAVA; dismiss federal claims for lack of jurisdiction
Equal protection (Illinois law)	Distinction among territories arbitrarily treats similar territory residents differently	Classification is rationally related to legitimate state interests and historical/territorial differences justify it	Rational-basis review applies; Illinois law rationally related to legitimate purposes; claim fails
Right to travel / Due Process	Moving from Illinois to a territory cannot lawfully deprive plaintiffs of ability to vote in Illinois federal elections	Right to travel does not guarantee continued voting rights after relocation; residents gain territorial voting instead	Claim fails: losses from moving do not violate right to travel; summary judgment for state defendants affirmed
Appropriate remedy for federal equal-protection claim	If UOCAVA unconstitutional, extend overseas voting rights to plaintiffs	Remedy would likely be (per precedent) to preserve congressional scheme; extending rights could create larger complications	Even if UOCAVA were invalidated, remedy would not necessarily redress plaintiffs’ injury; reinforces lack of standing to federal defendants

Hollingsworth v. Perry, 570 U.S. 693 (2013) (Article III causation/traceability requirement)
Simon v. Eastern Kentucky Welfare Rights Org., 426 U.S. 26 (1976) (injury must be traceable to challenged defendant, not independent third parties)
DH2, Inc. v. S.E.C., 422 F.3d 591 (7th Cir. 2005) (no standing where injury depends on discretionary decisions of independent actors)
Mass. Bd. of Retirement v. Murgia, 427 U.S. 307 (1976) (strict scrutiny applies only to suspect classes or interference with fundamental rights)
Reynolds v. Sims, 377 U.S. 533 (1964) (voting is a fundamental political right)
Armour v. City of Indianapolis, 566 U.S. 673 (2012) (rational-basis review standard)
Sessions v. Morales-Santana, 137 S.Ct. 1678 (2017) (consideration of appropriate remedial course where congressional scheme is constitutionally infirm)
Igartua v. United States, 626 F.3d 592 (1st Cir. 2010) (territorial residents lack certain federal voting rights)