Segovia v. U.S.

Plaintiffs-former Illinois residents now living in U.S. territories of Puerto Rico, Guam and Virgin Islands lacked standing to make equal protection challenge to Uniformed and Overseas Citizens Absentee Voting Act that required States to allow U.S. citizens living outside United States to vote in federal elections, where: (1) said Act defined “United States” to include instant territories; (2) Act's definition of "United States" precluded plaintiffs from voting in federal election in Illinois because, for purposes of said Act, they still resided within United States; and (3) instant Act, which did not preclude Illinois from providing ballots to plaintiffs, was not responsible for plaintiffs not receiving federal ballot. Moreover, while Illinois’ overseas-voting law similarly precludes plaintiffs from obtaining federal elections ballot, because Illinois law also includes instant territories in definition of “United States,” said law need only satisfy rational basis test for doing so in instant equal protection challenge, even though plaintiffs would have received federal ballot under Illinois law had they lived in other territories, since plaintiffs have no special right to vote in federal elections simply because they used to live in Illinois. Also, different treatment that Illinois gives to residents of various territories was rational at time Illinois law was enacted in 1979, since territories excluded from definition of “United States” at that time were more similar to foreign countries as opposed to incorporated territories where plaintiffs now reside.