its members you know myers about their workers well being and negotiate road isn't it just purely secular nation that there may be a vote which alters the the makeup of the puerto rico general assembly in such a way that we elect someone to maybe past to satisfy the bankruptcy court about how to reorganize it's the citizens of the city would be able to bring the exact challenge you're bringing here on the claim that the in your argument seems to be that the ordinary mechanisms of puerto rico government and politics can't operate because it's being done in the shadow of an actor that they can vote for yes acting to satisfy the board over which they have no power yes that's a triple you have to admit that's typical of that the same as in a municipal bankruptcy where the city over which the residents do have control takes action to satisfy the bankruptcy court which the residents don't have control so your theory would seem to suggest that even in that situation there'd be a voting rights challenge that seems surprising to me you know you are i believe that my of the puerto rico legislature's laws your theory must be that they don't really have power because they feel that they need to act to satisfy the requirements of  then wouldn't your legislature have had the option of instead of passing the laws like they did and vance in exactly the same challenge that your dancing here in having police are declared unconstitutional are if you're right that produces unconstitutional couldn't the legislature have brought forward that claim by refusing to deal with the board wanted to do yes i believe so so so i think what we have here is the people you now that we look at this law we think it's good for puerto rico and so they didn't change one is an injury traceable to impairment of the contract but then i think you're saying there's a separate injury that arises from the infringement of what you contend is a voting right yes correct and so and that exists baker there was an unequal treatment these of the the voting population some voters were being advantages in california relative to other things yes i know that that's true here so how how do you  because he said the illusion of the power of the vote loosened relative to what it's a delusion relative to what everybody had before and now everybody has less that's true of every preemption there is that the and you state your name for the record yes there are six yes please the court my name is mark harris i represent the financial oversight of management board on behalf of myself and also on behalf of the commonwealth of puerto rico and are you ready to proceed yes runner thank you very much the appellant's here are bringing in a very broad attack on the entire legal framework governing the relationship between the united states and puerto rico primarily they are attacking from isa claiming that it violates the whole array of their constitutional rights even more broadly they want a declaration that the united states is operating in their words in a legal colonial regime the problem is that a s don't have article three standing to bring these claims because they haven't shown as they are not able to show any concrete particularize injury caused by for me so or caused by this call a regime as just barren noted they have two different theories as to how they think they can show standing but neither one of them works the st one is that they're claiming that their injury in fact comes from the impairment of their collective bargaining agreements which was the result of four laws that the commonwealth passed to deal with puerto rico's fiscal and economic crisis those laws are the subject of the next appeal as runners know the trouble is that injury is not connected to permits it's not buy the relief that they seek here and it's not caused by from either secondly and separately they seem to be arguing that there is some kind of a voting rights or political or social injury which was also caused by the pass and the creation of the board but this is not a typical voting rights injury it doesn't work the same as the cases that they are citing baker versus carr and this court's decision involving the electoral college  any event even if the court were to rule that there was article three standing there please feel as a matter of law let me turn to the st issue which is the claim of standing from injury to the question bart agreement standing because there won't be rigorous ability here and just thompson you know you basically articulated this point even if for me some are found unconstitutional or really anything that the appellants are requesting here it wouldn't change before laws it would not restore the power to block and repeal we don't know your honor at this point whether or not the board was do that we also don't know whether or not the commonwealth would want to do that it's always just just to be just on redress ability and i take the point but i just want to understand what we're saying because it may have an effect on other oversight boards in many many contexts when the locality gets this bill trouble if it has the power to block repeal then wouldn't the redress be to remove that law and then puerto rico would be free to choose to do what it wanted but right now they were not free to choose what it wants so the impairment can be attributed to a condition where because i'm choosing and the relief would simply be to give that choice back to it your honor there may be a different situation if puerto rico itself were praying this case but the path to bring this case they have to claim right now that legislators inclined to do that in effect is not in their complaint that would be out the block it would be much more likely that the law would not be in place i don't believe they have any factual allegations about this at all your honor and in fact the the  that law was passed before that was permitted on that sort of a thank you and before there was an oversight board and in fact all of these laws are very closely related there's no indication there that that you know the reasons that they legislature  me and there's no doubt that the island is in a serious really catastrophic by natural crisis and the legislature took it upon itself to determined to get its own house in order that's really what happened here chronologically the city's functions invested in the appointed oversight board is that not subject to any kind of constitutional challenge and the grounds i don't think so your honor i think you state is the problem very well  this is really not a typical voting rights challenge they're not complaining that they didn't have the power to vote they're also not complaining in the way of voting that lucian argument normally works which is that there are votes don't have the efficacy that they normally would have because they're not able to elect their candidate of choice this selection would proceed any election concerning puerto rican officials would proceed exactly the way it always does the vote any particular voter or the union members they have the right to cast their vote the same way they have the same likelihood of electing the they can if they want to elect the only difference is that their religion that the board she's mean that the officials that they elect that governmental body doesn't have the same power to have these as the federal government or the oversight board but that really strikes me as a classic example of a non concrete non particularized injury that's what lucan called case that will be before this court relatively soon concerning relationship who has the power to reject recommendations or things like that i don't i don't just ridiculous case where they have a standing but it's certainly if they feel that the law is unconstitutional as applied to them they have powers to challenge that but individual citizens do not unless they can they can show that it's affecting a direct in particular injury on them so the case is really not like lyman versus baker which was this court case involving the electoral college and the i think massachusetts system about winner takes all voting for the college in that case the voters were complaining  that the winner takes all system within their ethical ethical see if their votes to choose the directors that's not what's happening here they have the same power they always had to elect the officials that they vote for as i said the real complaint is about between puerto rico and the united states but without any concrete stake like that it's just an abstract dispute is not one that they have standing over i was not planning given my limited time to address the i'm sorry church he appears to be frozen we're going to try and if you can hang on one minute  judge we're going to try and get him right back in now  with respect to the injury to the collective bargaining rights and the allegation they've been diminished i would reiterate his arguments and say they apply to united states just even more so to the extent that the traceability problem here is that they lost and acted by the commonwealth legislature would not necessarily be repealed and then there's to go to the next level and to say that it's traceable not on the relief they ask for is to declare a promise awful and the way this case has shaped up that would be a basically a kansas saying it's the e p a or immigration customs enforcement or some other federal agency did something awful then the statute creating that agency should be declared unlawful and that's just not correct under under the law and the same applies on their redress ability their adjustability  articulated and injury and trauma and i'm not asking that or i'm asking in so far as that's the claim is in the united states the proper party to sue but that claim even and the united might win because there's no standing to bring it i think that may be right if the injury is a result of the existence purely of the existence of the statute but again i about right and that kind of broad political participation in a case they cite are not relevant and the and the salient point in this case is that the alleged injury the alleged lack of voting rights comes directly from the constitution itself as this court has held several times the restriction on who can vote for members of congress is a function of the constitution itself only residents of of course this this court lacks the power to direct that or to direct the admission of puerto rico as a state which would perhaps also redress that injury but it's also outside this court's authority to grant so the district court was correct in in dismissing this case for lack of standing as a nontraditional case or controversy again i don't want to belabor the point mr harris has made so if the court has no further questions we'll s