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Husband argues that Wife did not prove she was liable on an obligation attached to the Property such that his failure to refinance (and thereby satisfy the Deed of Trust) caused her “a distinct and palpable injury.” ¶ 16 (1998); Ariz. Ass’n ¶ 17 (App. 2009).

¶15 Arizona courts “are not constitutionally constrained to decline jurisdiction based on lack of standing.” ¶ 24

To have standing, “a plaintiff must allege a distinct and palpable injury.” , 69 ¶ 16

COOPER ET AL. Opinion of the Court 65, 69 ¶ 16

¶ 16, (“To gain standing to bring an action, a plaintiff must allege a distinct and palpable injury.

Id.; ¶ 11, (“Mandamus ‘does not lie if the public officer is not specifically required by law to perform the act.’” (citation omitted)).

In order to have standing, a plaintiff must have suffered “a distinct and palpable injury.” ¶ 16 , (citing Warth v. Seldin, 422 U.S. 490, 501 , 95 S.Ct.

¶ 11, see also Marbury v. Madison, 5 U.S. 137, 169 (1803) (discussing nature of mandamus); A.R.S.

-72, ¶ 25 , -20 (1998); , (waiving standing requirement because suit by senate president against governor involved "dispute at the highest levels of state government” and substantial issues of first impression); Goodyear Farms v. C

Consequently, standing to bring an action requires the plaintiff to “allege a distinct and palpable injury.” ¶ 16

We "consistently” have required standing because it "sharpens the legal issues presented by ensuring that true adversaries are before the court and thereby assures that our courts do not issue mere advisory opinions.” ¶ 24

“Mandamus does not lie if the public officer is not specifically required by law to perform the act.” ¶ 11 , (internal quotation omitted).

¶ 11 Athough “we are not constitutionally constrained to decline jurisdiction based on lack of standing,” , 71 ¶ 24, “[cjoneern over standing is particularly acute”,when this Court is asked, in effect, to referee disputes between the political branches.

“To gain standing to bring an action, a plaintiff must allege a distinct and palpable injury.” ¶ 16

("To establish standing, we require that petitioners show a particularized injury to themselves.").

"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 , ( , ).

Id.; ¶ 16 , (holding that standing to bring an action requires plaintiff to “allege a distinct and palpable injury”).

We have described mandamus as available only “to require public officers to perform their official duties when they refuse to act.” , 68 ¶ 11, ( , ).

The paucity of eases in which [courts] have waived the standing requirement demonstrates both [the courts’] reluctance to do so and the narrowness of this exception.” ¶ 25