Department of Homeland Security v. League of Women Voters · ¶9

To start, we consider the likelihood that this Court would reverse. At least one of plaintiffs’ members (J. Doe 4) is registered to vote in a State (Louisiana) that used the modified SAVE program. She has demonstrated that SSA records do not accurately reflect that she is now a naturalized citizen. Supplemental Decl. of J. Doe in No. 25–cv–3501 (D DC), ECF Doc. 16–3, ¶¶2, 14. Had the modified SAVE program not been set aside, she likely would have been required to provide additional proof of citizenship. Such a “need to take . . . affirmative steps to avoid risk of harm . . . constitutes a cognizable injury” supporting standing. Meese v. Keene, 481 U. S. 465, 475 (1987).

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