Connecticut Parents Union v. Russell-Tucker, No. 20-1998 (2d Cir. 2021)
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An organization that is not directly regulated or affected by a challenged law or regulation cannot establish injury-in-fact for purposes of organizational standing absent a showing that it suffered an involuntary and material burden on its established core activities.
The Second Circuit affirmed the district court's dismissal of CTPU's complaint alleging that Connecticut's standards regarding the racial composition of its interdistrict magnet schools violate the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution. The court concluded that the district court properly dismissed the complaint based on lack of Article III standing. In this case, because CTPU is an organization that is not directly regulated or affected by the challenged standards and because CTPU has failed to show that it suffered an involuntary, material burden on its core activities, the court concluded that CTPU has not established an injury-in-fact for purposes of demonstrating organizational standing.
The court issued a subsequent related opinion or order on August 18, 2021.
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