Case Explained: 26a0231p.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-08-14 The sixth-circuit affirmed the district court’s grant of summary judgment to defendants, holding that the American Freedom Law Center lacked Article III standing to pursue its First Amendment and Fourteenth Amendment claims. The court applied the three-element test for standing established in *Lujan v. Defenders of Wildlife* and *FDA v. Alliance for Hippocratic Medicine*: injury in fact, causation, and redressability. The court concluded that American Freedom failed to demonstrate a cognizable injury in fact traceable to the defendants’ actions. Regarding reputational harm, the court found no evidence that the defendants’ 2019 press release caused incremental harm beyond the existing Southern Poverty Law Center (SPLC) designation, as the release did not name the law firm and merely cited the SPLC’s report as a source for a general trend. Furthermore, the court noted that the state removed the press release from its website and disavowed any intent to collaborate with the SPLC or use its list for investigations, rendering any past reputational harm non-imminent and speculative for future relief. Regarding economic injury, the court found no evidence that donor contributions decreased specifically due to the defendants’ actions; alleged losses were either caused by the SPLC’s prior designations (such as the AmazonSmile denial) or lacked a causal link to the press release. Finally, the court rejected the diversion-of-resources theory, ruling it was forfeited on appeal and substantively insufficient because it relied on conclusory allegations of future expenditures without concrete details linking those costs to a specific, imminent injury caused by the defendants. As a practical consequence, the judgment in favor of the Michigan Attorney General and the Director of the Department of Civil Rights is upheld, and the law firm’s lawsuit seeking declaratory and injunctive relief is dismissed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.