Bowyer v. Ducey, No. 2:20-cv-02321-DJH (D. Ariz.) – Dismissed for Standing; Claims Mischaracterized as Evidence Failure (AZ)

[Reasonable Inference – Characterization as evidence dismissal is misleading] A federal lawsuit alleging large-scale election fraud and seeking to decertify Arizona’s election results was dismissed for lack of legal standing. The presiding judge described the claims as “sorely wanting of relevant or reliable evidence” and noted entertaining the suit “would cause extreme and unprecedented harm” at that late date. Critically, the “lack of evidence” characterization was made in the context of a standing dismissal – prior to discovery – meaning the court assessed the sufficiency of pleadings without permitting development of the evidentiary record that plaintiffs sought. The Bost v. Illinois ruling, discussed infra, subsequently removed the principal standing barrier that barred plaintiffs in this class of cases.