Williams v. Lew, 2015 U.S. Dist. LEXIS 948

Plaintiff Victor K. Williams, a law professor and holder of various U.S. Treasury securities, sued the Treasury and Treasury Secretary Jacob J. Lew seeking a declaratory judgment that 31 U.S.C. § 3101 (the federal debt ceiling statute) is unconstitutional and void.
Williams alleged the debt limit threatens future nonpayment of his Treasury securities and asserted violations of the Fourteenth and Fifth Amendments and separation-of-powers principles.
He sought a declaration the statute is void, a permanent injunction preventing its enforcement, or mandamus compelling defendants to treat it as null.
Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(1) for lack of Article III standing.
The court found Williams’ alleged injury speculative and contingent on multiple hypothetical future events (e.g., debt limit being reached, exhaustion of Treasury’s extraordinary measures, cash flow on a given day, and the timing of payments on plaintiff’s holdings).
The court also held Williams’s claim amounted to a generalized grievance shared by the public and therefore insufficient to confer standing, and dismissed the case for lack of subject-matter jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing: whether Williams has Article III standing to challenge § 3101	Williams: holding Treasury securities gives him a concrete, imminent injury from the debt limit’s risk of causing default on his holdings	Defendants: alleged injury is speculative, contingent, and not certainly impending; claim is a generalized grievance	No standing — injury is conjectural and generalized, so case dismissed

Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing requires concrete, particularized, actual or imminent injury)
Allen v. Wright, 468 U.S. 737 (injury must be fairly traceable and redressable)
Clapper v. Amnesty Int'l USA, 133 S. Ct. 1138 (threatened injury must be certainly impending; speculative future injury insufficient)
Whitmore v. Arkansas, 495 U.S. 149 (plaintiff must show injury that is actual or imminent)
Spencer v. Kemna, 523 U.S. 1 (plaintiff must have suffered or be threatened with actual injury traceable to defendant)
Warth v. Seldin, 422 U.S. 490 (generalized grievances shared by the public do not confer standing)
Navegar, Inc. v. United States, 103 F.3d 994 (D.C. Cir.) (standing requires injury in fact)
Worth v. Jackson, 451 F.3d 854 (D.C. Cir.) (standing, ripeness, and mootness ensure case-or-controversy)
La. Envtl. Action Network v. Browner, 87 F.3d 1379 (D.C. Cir.) (speculative chains of contingencies defeat standing)
Reuss v. Balles, 584 F.2d 461 (D.C. Cir.) (rejecting bondholder theory of standing)