The following excerpt is from Sowell v. Tinley Renehan & Dost, LLP, 19-2809-cv (2nd Cir. 2020):
rather, the "threatened injury must be certainly impending." Whitmore v. Arkansas, 495 U.S. 149, 158 (1990) (internal quotation marks omitted). A lawyer-plaintiff's conclusory assertion that a court rule or doctrine of interpretation has a chilling effect on her First Amendment rights is not sufficient to establish injury in fact. See Conn. Bar Ass'n v. United States, 620 F.3d 81, 90 n.12 (2d Cir. 2010) ("Allegations of a 'subjective chill' are generally 'not an adequate substitute for a claim of specific present objective harm or a threat of specific future harm.'" (quoting Laird v. Tatum, 408 U.S. 1, 13-14 (1972))).
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