Newdow does not recite any concrete and particularized injury as a result of the allegedly unconstitutional recitation of a prayer at President Bush's inauguration.  While it is apparent that Newdow was offended by the prayer, this falls far short of an actual concrete injury sufficient to confer standing.
Moreover, a party seeking injunctive relief must show that he "'has sustained or is immediately in danger of sustaining some direct injury,' as the result of the challenged conduct and the injury or threat of injury must be both " real and immediate," not "conjectural" or "hypothetical.'" City of Los Angeles v. Lyons, 461 U.S. 95, 102 (1983)(citations omitted)(holding that citizen lacked standing to obtain an injunction against the police prohibiting use of strangleholds as it is "untenable" to assert that plaintiff and everyone else who might be stopped for a traffic violation would be subjected to a stranglehold).  The court also noted that "five months have passed since [the date police used a stranglehold on plaintiff] and the filing of the complaint, yet there was no allegation of further unfortunate encounters between Lyons and the police." Lyons, id., at 108.
This circuit has consistently required one seeking injunctive relief to meet these requirements.  Eggar v. City of Livingston, 40 F.3d 312, 316 (9th Cir. 1994)(rejecting plaintiff's argument that the history of constitutional violations made the possibility of future violations sufficiently certain); Nelsen v. Kings County, 895 F.2d 1248, 1252 (9th Cir. 1990) (rejecting standing where threat of future harm was based on "an extended chain of highly speculative contingencies...") ///
7