916 F. Supp. 2d 58
D.D.C.2013Background
- Sibley filed a challenge to Obama’s eligibility to hold office in DC Superior Court; action was removed to this court after a preliminary injunction hearing was held there.
- Sibley seeks to enjoin electors in DC from casting votes for Obama and to obtain a declaratory judgment that Obama is not a natural-born citizen.
- Court previously addressed similar challenges in 2012 and 2010-2012 cases, ruling against Sibley on similar grounds.
- Defendants moved to dismiss for standing and mootness, and to stay or quash discovery; courts considered remand and sanctions.
- Court concludes lack of standing and mootness require dismissal and remand to the DC Superior Court.
- Votes have already been cast and counted, leaving the requested relief moot and not redressable by this court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Sibley has standing to challenge electoral votes | Sibley argues injury as a registered voter/write-in candidate. | Lack of particularized injury; generalized grievance. | Lack of standing; dismissed. |
| Whether the case is moot | Injury could recur and be redressable in future elections. | Electoral votes already cast; moot. | Moot; claims none are capable of redress. |
| Whether the court should grant a preliminary injunction | Injunction to prevent DC electors from voting for Obama. | No standing, mootness, and public interest against injunction. | Denied; no standing and moot claims. |
| Whether the case should be remanded for lack of subject-matter jurisdiction | District court should adjudicate the challenge. | Lack of jurisdiction requires remand. | Remanded to Superior Court; dismissal for lack of jurisdiction. |
Key Cases Cited
- Grand Lodge of Fraternal Order of Police v. Ashcroft, 185 F. Supp. 2d 9 (D.D.C. 2001) (court requires jurisdictional inquiry; standing analysis emphasized)
- Randolph v. ING Life Ins. & Annuity Co., 486 F. Supp. 2d 1 (D.D.C. 2007) (remand and subject-matter jurisdiction principles under §1447(c))
- In re Navy Chaplaincy, 697 F.3d 1171 (D.C. Cir. 2012) (standing and injury-in-fact standards; imminence of injury)
- Newdow v. Roberts, 603 F.3d 1002 (D.C. Cir. 2010) (redressability considerations in election-related challenges)
- Herron for Congress v. FEC, --- F. Supp. 2d ---- (D.D.C. 2012) (mootness and lack of standing analysis applied to election context)