I don’t think I ever heard of this case before the 11th Circuit Court of Appeals. The plaintiff filed suit against the government for “the removal of prayer” from schools and other public places as a violation of her religious freedom. The district court dismissed the case and the appeals court has now upheld that dismissal.
Doretta Holyfield-Vega appeals pro se the dismissal with prejudice of her complaint for injunctive relief against officials of the United States and the State of Alabama. The district court ruled that Holyfield-Vega lacked standing to sue the officials. We affirm.
The district court correctly concluded that Holyfield-Vega failed to allege that she had suffered an injury in fact. To have standing, a plaintiff must establish that she has incurred an injury to a protected interest that is “concrete and particularized.” Holyfield-Vega alleged that “[t]he removal of pray[er]” from “school and other areas” by federal and state officials violated her right to the free exercise of religion under the First Amendment, but Holyfield-Vega failed to describe how she had been injured by the officials’ conduct. Holyfield-Vega argued that she was entitled to proceed “[a]s a concern[ed] United States Citizen,” but a plaintiff “does not state an Article III case or controversy”“claiming only harm to [her] and every citizen’s interest in proper application of the Constitution . . . and seeking relief that no more directly and tangibly benefits [her] than it does the public at large.” The district court correctly dismissed Holyfield-Vega’s complaint for lack of subject matter jurisdiction.
Right result, wrong reasoning. This is the same problem I always have with the court’s standing doctrine. Hell yes “every citizen’s interest in proper application of the Constitution” should be enough to grant standing. There are too many areas of the law, especially in Establishment Clause jurisprudence, where this entirely artificial doctrine has made the constitution virtually unenforceable because no one has standing to challenge it. The court should have granted standing and granted summary judgment to the defendants.
But here’s a bit of irony: One of the named defendants in the case was Judge Roy Moore of the Alabama Supreme Court.