In Taylor v. City of Flagstaff, (D AZ, Oct. 9, 2019), an Arizona federal district court held that a citizen of Flagstaff, Arizona lacked standing to challenge the constitutionality of the city’s annual Grand Menorah Lighting at City Hall. The court said in part:
Although Plaintiff is a resident of Flagstaff…, Plaintiff did not allege that he has had direct contact with the Grand Menorah Lighting at City Hall, or any other religious ceremony purportedly held in City Hall. According to the Complaint, Plaintiff’s contact with the Grand Menorah Lighting at City Hall has, at most, been via newspaper articles reporting the “Flagstaff Hanukkah tradition.”…. While Plaintiff alleges that he has been “quite concerned” and “very disturbed” by the Grand Menorah Lighting at City Hall, … —without more, the injury asserted by Plaintiff is too generalized and remote to confer standing….
The court concluded that the same test for standing applies to both plaintiff’s Establishment Clause claim and his claim under the no-aid provision of the state constitution.