Case summary: Texas state LULAC versus Elphont

Texas state LULAC and Voto Latino challenged Texas' revised requirements for voter residency. The dispute arose when the Texas legislature passed SB 1111, which included a provision requiring individuals with registration forms that didn't correspond to a physical address to provide documentation of a residential address in Texas. The district court upheld the law but struck down the PO box provision. LULAC and Voto Latino appealed to the Fifth Circuit and argued for organizational standing, claiming that the law diverted resources and chilled speech. The court disagreed and found that the plaintiffs failed to establish a direct link between the diversion of resources specifically to SB 1111 and the chilling of speech. As a result, they were denied standing.