Wood v. Raffensperger, No. 1:20-cv-04651-SDG (N.D. Ga.), aff’d 11th Cir. – Standing and Laches; Affirmed as Moot Post-Certification (GA)

A lawsuit challenging absentee ballot signature verification procedures and seeking to prohibit certification was dismissed by the District Court for lack of standing and laches, then affirmed by the Eleventh Circuit on the additional ground that the case had become moot once results were certified. The plaintiffs alleged that Georgia’s failure to enforce signature-verification requirements diluted lawful votes, a classic vote-dilution theory recognized under Equal Protection doctrine. The Eleventh Circuit’s mootness ruling created the logical endpoint of a pre/post-certification catch-22: challenges filed before certification were premature; once certified, they were moot. Judge Steven Grimberg denied a motion for preliminary injunction to enjoin Georgia’s certification without conducting a full evidentiary hearing or permitting expert cross-examination, despite extensive documentary and statistical evidence submitted by plaintiffs. The Eleventh Circuit affirmed on procedural grounds; certiorari was denied by the Supreme Court. No court in this chain ruled on the factual merits of the underlying claims.