California — Meland v. Padilla, No. 2:19-cv-02288, decided April 20, 2020. The U.S. District Court, Eastern District of California dismissed a complaint filed by a shareholder of a publicly traded corporation subject to Senate Bill 826, the California bill requiring publicly held corporations headquartered in California to have at least one woman on their board of directors, claiming that S.B. 826 impaired his right to vote for directors in violation of his equal protection rights. The court held that the plaintiff lacked standing, noting that both the requirement to have a woman on the board of directors and the penalty for lack of compliance are imposed on the corporation and not the shareholders. In addition, his right to vote was not legitimately impaired. He could still vote for any director he wanted, including a male nominee. Thus, the plaintiff had not suffered an injury in fact, as required to have to standing. For more information about S.B. 826 see our article.