Reaffirmation of Article III Standing Requirements: Generalized Grievances Insufficient

Introduction

This commentary examines the Third Circuit’s per curiam decision in Mary Basile Logan v. Merrick Garland, No. 24-3265 (3d Cir. Mar. 21, 2025). The appellant, Mary Basile Logan, proceeding pro se, filed a sprawling 900-page amended complaint against a vast roster of federal and state officials and entities. She alleged violations of federal criminal statutes, the Take Care Clause (Art. II, § 3), and the Treason Clause (Art. III, § 3) arising from events such as the COVID-19 pandemic, the 9/11 attacks, and “foreign influence” in U.S. politics. Among other remedies, she sought billions of dollars in damages and sweeping changes to the electoral system. The District Court dismissed her suit for lack of Article III standing, and the Third Circuit summarily affirmed. This decision underscores the bedrock principle that “generalized grievances” against government policy do not confer federal jurisdiction.

Summary of the Judgment

The Third Circuit granted appellees’ motion for summary affirmance, holding that Logan failed to establish a concrete, particularized injury required for Article III standing. Applying longstanding Supreme Court precedents, the court concluded that Logan’s allegations—though voluminous—were generalized political grievances, not individualized injuries. The appeal raised no substantial question, and the District Court’s dismissal with prejudice was affirmed.

Analysis

Precedents Cited

Susan B. Anthony List v. Driehaus, 573 U.S. 149 (2014): Defined injury-in-fact as “concrete and particularized” and not merely “conjectural or hypothetical.”
Valley Forge Christian Coll. v. Americans United for Separation of Church & State, Inc., 454 U.S. 464 (1982): Held that a “generalized interest of all citizens” in proper government is insufficient to invoke federal jurisdiction.
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992): Placed the burden on the plaintiff to prove standing elements, especially injury in fact.
Freedom From Religion Found. Inc. v. New Kensington Arnold Sch. Dist., 832 F.3d 469 (3d Cir. 2016): Emphasized the need to separate those with a true stake from those bringing abstract grievances.
Arizona Christian Sch. Tuition Org. v. Winn, 563 U.S. 125 (2011): Confirmed that disagreement with state law or policy alone does not create standing.

Legal Reasoning

The court’s reasoning proceeded in three stages:

Burdens of Proof: Under Lujan, Logan bore the burden to allege specific facts establishing standing.
Injury-in-Fact Requirement: The court reaffirmed that Article III demands a “concrete and particularized” injury. Mere dissatisfaction with general governmental conduct is insufficient.
Generalized Grievances Doctrine: Drawing on Valley Forge and Winn, the court held that Logan’s claims amounted to “generalized grievances” shared by the electorate at large, rather than individualized harm.

Having found no “specific and concrete injury” to Logan, the Third Circuit determined that the District Court correctly dismissed all claims for lack of jurisdiction. Logan’s numerous requests—$8 billion in damages, changes to ballot eligibility, a one-day hand-counted voting system—did not remedy her failure to show personal harm.

Impact

This decision has several important consequences:

It reaffirms the barriers against using federal courts as venues for sweeping political or historical grievances.
It reminds pro se litigants that voluminous filings and dramatic allegations cannot substitute for the Article III requirement of a personal, concrete injury.
It aids lower courts in swiftly disposing of cases that attempt to invoke the judiciary for general policy complaints rather than genuine disputes between parties.

Complex Concepts Simplified

Article III Standing: The constitutional requirement that a plaintiff must have a personal stake in the outcome. It has three elements:

Injury-in-Fact: A real, personal harm that is actual or imminent.
Causation: A direct link between the defendant’s conduct and the plaintiff’s injury.
Redressability: A likelihood that a favorable court decision will remedy the injury.

Generalized Grievance: A complaint shared in common by all or a large group of citizens, without a tailor-made harm to the individual bringing suit. Courts routinely dismiss such claims for lack of standing.

Conclusion

The Third Circuit’s decision in Logan v. Garland serves as a clear reminder that the federal judicial power is confined to “cases” or “controversies” in which plaintiffs suffer specific, concrete injuries. By summarily affirming the dismissal, the court underscored that voluminous allegations of governmental wrongdoing—no matter how dramatic—cannot overcome the constitutional threshold for standing. This reaffirmation protects the judiciary from being drawn into generalized political disputes and preserves the separation of powers by keeping policy debates in the legislative and executive branches.