obstacle preventing the third party from protecting his own interests.  Jd. at 115-116.
Since Singleton the federal courts have been consistent in applying this requirement. See United States v. Triplet!, 494 U.S. 715 (1990)(attorney had standing to challenge the fee-limiting statute on behalf of potential clients who would be prevented from enjoying their due-process right to obtain legal representation); Voight v. Savell, 70 F.3d 1552 (9th Cir. 1995)(state court clerk with hiring authority lacked standing to assert the rights of non-resident job applicants); Hong Kong Supermarket v. Kizer, 830 F.2d 1078 (9th Cir. 1987) (supermarket vendor who sought to enjoin entire  "WIC"5 program lacked standing to assert the rights of program recipients who benefitted from many aspects of the program).
In the instant case, Newdow cannot meet even one of the three elements necessary for third-party standing.  First, he has no apparent relationship with any of the millions of theistic non-Christians in this country and has not alleged the existence of some relationship such that their interests are "inextricably bound" with his.
Second, Newdow is the least effective advocate imaginable for theistic non-Christians as his interests are diametrically opposed to theirs.  As his Complaint makes clear, he denies the existence of God.  Complaint, If 30.  The remedies he seeks (a
5  Under the "Women, Infants, and Children" ("WIC") program at-risk children and pregnant, postpartum, and breastfeeding women receive coupons redeemable at supermarkets for various food products including milk, eggs, and cheese.  Hong Kong, 830 F.2d at 1079.
15