The following excerpt is from Civil Rights Educ. & Enforcement Ctr. v. Hospitality Props. Trust, No. 16-16269 (9th Cir. 2017):
Where, as here, a party seeks injunctive relief, "past exposure to illegal conduct does not in itself show a present case or controversy." City of Los Angeles v. Lyons, 461 U.S. 95, 102 (1983) (alteration omitted). Instead, the plaintiff must allege "continuing, present adverse effects" stemming from the defendant's actions. Id.
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