The Doctrine of Laches precludes Plaintiff from asking this Court for relief based on post hoc challenges to the Secretary of State’s voter registration list maintenance program and to the Settlement Agreement, which were in place well before the November 2020 general election. The National Voter Registration Act provides that States shall complete their programs to remove ineligible voters from the official lists “not later than 90 days prior to the date of a primary or general election for Federal office.” 52 U.S.C. § 20507(c)(2)(A). Thus, any objection Plaintiff maintained against the State’s list maintenance program for the November 3 election could have been raised well before the general election, and in any event by August 5. Similarly, the Settlement Agreement was entered into six months before election day, yet Plaintiff did not seek to intervene or challenge the Settlement Agreement until November 30, 2020. See Wood v. Raffensperger, No. 1:20-CV-04651-SDG, 2020 WL 6817513, at *7 (N.D. Ga. Nov. 20, 2020) (rejecting virtually identical post-election challenge to Settlement Agreement as barred by laches). As a result, the Plaintiff’s Complaint is dismissed against State Defendants and Intervenor-Defendants on this ground as well.
Third, as an individual voter, Plaintiff lacks standing to raise generalized grievances against election officials’ conduct. Wood v. Raffensperger, No. 20-14418, 2020 WL 7094866, at *4 (11th Cir. Dec. 5, 2020) (Pryor, J.). Plaintiff is not a “Candidate” for the election he seeks to contest in this action and thus has no standing to bring this action. As a result, the Complaint is dismissed against Defendants and Intervenor-Defendants on this ground as well.
Fourth, even if the Court were to examine the merits of this action, Plaintiff fails to state a claim upon which relief can be granted.
Plaintiff seeks to challenge the election of presidential electors, who are the candidates selected by voters under state law. See O.C.G.A. § 21-2-10 (“At the November election to be
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