IRLI, on behalf of its client the Federation for American Immigration Reform, intervened as a defendant in a federal lawsuit brought by the Mexican American Legal Defense and Educational Fund (MALDEF) against the Arizona governor, attorney general, and secretary of state challenging as unconstitutional Proposition 200, the “Arizona Taxpayer and Citizen Protection Act,” a ballot initiative passed by Arizona citizens to protect the state from voter fraud by requiring proof of citizenship to vote as well as requiring identification for the receipt of non-federal public benefits. The district court denied a preliminary injunction, which was appealed to the U.S. Court of Appeals for the Ninth Circuit. The Ninth Circuit dismissed the lawsuit for lack of standing because the plaintiffs failed to meet their burden of demonstrating an injury-in-fact. Friendly House v. Napolitano, 419 F.3d 930 (9th Cir. 2005).