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Second, P.3d 311 (2003), the court determined that the plaintiff legislators lacked standing because they did not suffer an “injury” when the majority of the legislature found the supermajority requirement 1 Article 9, Section 22(C)(2) excepts from the supermajority requirement “[f]ees and assessments that are a

In Arizona, standing is “not jurisdictional, but instead is a prudential doctrine requiring ‘a litigant seeking relief in the Arizona courts [to] first establish standing to sue.’” Dobson, 233 Ariz. at 122, ¶ 9, 309 P.3d at 1292 ( ¶ 19, ).

Under Arizona’s Constitution, standing is not jurisdictional, but instead is a prudential doctrine requiring “a litigant seeking relief in the Arizona courts [to] first establish standing to sue.” ¶ 19

525 ¶ 20, (“Without the standing requirement, the judicial branch would be too easily coerced into resolving political disputes between the executive and legislative branches, an arena in which courts are naturally reluctant to intrude.”).

"Because the Arizona Constitution does not contain a provision analogous to the case or controversy requirement of the U.S. Constitution, `we are not constitutionally constrained to decline jurisdiction based on lack of standing.'" ¶ 31 , ( , ).

Although “we are not constitutionally constrained to decline jurisdiction based on lack of standing,” ¶ 24, “[c]oncern over standing is particularly acute” when “legislators challenge actions undertaken by the executive branch,” ¶ 20

establish standing, especially in actions in which constitutional relief is sought against the government,” ¶ 16

E.g., Fernandez v. Takata Seat Belts, Inc., ___ Ariz. ___, ___, ¶ 6, Bennett v. Napolitano (“Napolitano”), ¶ 19

¶ 18, (“To establish federal standing, a party invoking the court's jurisdiction ‘must allege personal injury fairly traceable to the defendant's allegedly unlawful conduct and likely to be redressed by the requested relief.’”) (citing Allen v. Wright, 468 U.S. 737, 751 (1984)); see

“To ensure separation of the powers of government under the U.S. Constitution, federal courts have consistently established doctrines ‘founded in concern about the proper — and properly limited — role of the courts in a democratic society.’” -25, ¶ 17 , -16 (2003) (quoting Allen v. Wright, 468 U.S. 737, 750 , 104 S.Ct.