Lance v. Coffman
The Supreme Court ruled that four Colorado voters could not sue over the state's congressional redistricting process because their only claimed injury was that the Constitution had not been followed correctly — a grievance shared by every citizen, not a harm specific to them.
The decision reinforces a long-standing rule that federal courts are not open to lawsuits based purely on a general interest in seeing the government obey the law, even when the underlying constitutional question is a real one.
“Because plaintiffs assert no particularized stake in the litigation, we hold that they lack standing to bring their Elections Clause claim.”
The Court's core holding that the voters lacked standing to pursue their claim.
How it got here: A federal district court found standing but dismissed on issue-preclusion grounds after this Court earlier reversed a jurisdictional dismissal; the voters appealed again to the Supreme Court.
The Case in Depth
What happened
After the 2000 census, Colorado's legislature could not agree on new congressional districts, so a state court drew them instead; the legislature later passed its own redistricting plan, but the Colorado Supreme Court blocked it, ruling that court-drawn maps last until the next census under the state constitution. Four Colorado voters who had not been part of that state case then sued in federal court, arguing the state court's ruling violated the U.S. Constitution's Elections Clause by taking map-drawing power away from the legislature.
The question before the Court
Could four Colorado voters sue in federal court just because they believed the state's redistricting process violated the U.S. Constitution's Elections Clause?
Why it matters
The ruling makes clear that voters cannot go to federal court simply because they think a state misapplied a constitutional rule about redistricting; they need to show a harm specific to themselves. This keeps a recurring category of election-law disputes about how legislatures versus courts draw congressional maps out of federal court unless a plaintiff can show a concrete, individual stake.
What changes now
The Elections Clause claim is dismissed for lack of standing rather than decided on the merits, so the underlying question of whether Colorado's redistricting process actually violated the Elections Clause remains unresolved. The district court's separate dismissal of a Petition Clause claim is left in place. Because this is a jurisdictional ruling, any future challenge to similar redistricting disputes would need a plaintiff who can show a more specific, individualized harm.
What this does not decide
The Court did not decide whether Colorado's redistricting process actually violates the Elections Clause, nor did it disturb its earlier rulings interpreting the word 'Legislature' in that Clause, which involved suits brought on the State's behalf rather than by private citizens.
How the Court got there
The legal reasoning, step by step
- The Court began with the basic rule that federal courts must confirm they have jurisdiction under Article III before reaching the merits, and that standing to sue is one part of that jurisdictional requirement.
- To have standing, a plaintiff must show a concrete, particularized injury caused by the challenged conduct that a favorable ruling could fix — not simply a generalized complaint that the government failed to follow the law.
- The Court traced this rule through a line of its own precedents rejecting lawsuits by citizens or taxpayers whose only claimed harm was an interest, shared equally by everyone, in seeing the Constitution properly applied.
- Applying that rule here, the Court found the voters' only alleged injury was that the Elections Clause had not been followed in how Colorado's congressional map was set — an injury identical to that of every other Colorado citizen, not one specific to them.
- The Court distinguished its past decisions interpreting the word 'Legislature' in the Elections Clause, noting those cases were brought by a state relator on the State's behalf, not by private citizens suing for themselves, so they did not address this standing question.
- Because the voters could point to no particularized stake distinct from the general public's interest, the Court concluded they lacked standing to pursue the Elections Clause claim.
Doctrinal impact
Cases affected by this decision
Reaffirms Ex parte Lévitt (302 U. S. 633)
Reaffirmed that a citizen suing only as a citizen, with no distinct interest, lacks standing.
Reaffirms United States v. Richardson (418 U. S. 166)
Reaffirmed that a generalized grievance shared by all taxpayers does not create standing.
Reaffirms Schlesinger v. Reservists Comm. to Stop the War (418 U. S. 208)
Reaffirmed that widely shared abstract injuries cannot support a citizen's lawsuit.