Page:Wood v. Raffensperger (20-14418) (2020) Decision.pdf/14

 agrees that he is affected by Georgia’s alleged violations of the law in the same way as every other Georgia voter. “This injury is precisely the kind of undifferentiated, generalized grievance that the Supreme Court has warned must not be countenanced.” Dillard, 495 F.3d at 1335 (internal quotation marks omitted).

''Roe v. Alabama ex rel. Evans'', 43 F.3d 574, also does not support Wood’s argument for standing. In Roe, we ruled that the post-election inclusion of previously excluded absentee ballots would violate the substantive-due-process rights of Alabama voters and two political candidates. Id. at 579–81. But no party raised and we did not address standing in Roe, so that precedent provides no basis for Wood to establish standing. Cf. Lewis v. Casey, 518 U.S. 343, 352 n.2 (1996) (noting that in cases where “standing was neither challenged nor discussed… the existence of unaddressed jurisdictional defects has no precedential effect”). And Wood’s purported injury is far more general than the voters’ injury in Roe. The voters in Roe bore individual burdens—to obtain notarization or witness signatures if they wanted to vote absentee—that state courts post-election retroactively permitted other voters to ignore. Roe, 43 F.3d at 580–81. In contrast, Georgia applied uniform rules, established before the election, to all voters, who could choose between voting in person or by absentee ballot, and Wood asserts that the