The following excerpt is from Jackson v. Napolitano, Case No.: 19cv1427-LAB (AHG) (S.D. Cal. 2020):
A plaintiff seeking to establish standing for injunctive or declaratory relief must demonstrate such an invasion of a legally protected interest along with a "sufficient likelihood that he will again be wronged in a similar way." City of Los Angeles v. Lyons, 461 U.S. 95, 111 (1983). This is because "'past exposure to illegal conduct does not in itself show a present case or controversy regarding injunctive relief . . . if unaccompanied by any continuing, present adverse effects." Id. at 95-96, 102 (quoting O'Shea v. Littleton, 414 U.S. 488, 495-96 (1974)).
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