§ 1.4.2 Requisites of Plaintiff. The plaintiff must have an interest in the subject matter to obtain injunctive relief. Sears, Roebuck & Co. v. L-M Manufacturing Co., 256 F.2d 517 (3d Cir. 1958) . For example, the holder of an equitable title will have sufficient interest to prevent an injury to the land, First Baptist Church v. Branham, 90 Cal. 22, 27 P. 60 (1891) , as will the trustee of an express trust, Kellogg v. King, 114 Cal. 378, 46 P. 166 (1896) , the owner of real property although his tenant is in possession, Schneider v. Brown, 85 Cal. 205, 24 P. 715 (1890), and a tenant for years, Heilbron v. Fowler Switch Canal Co., 75 Cal. 426, 17 P. 535 (1888) . The owner of property in a subdivision has standing to seek injunctive relief enforcing deed restrictions. Horton v. Mitchell, 200 Ariz. 523, 526, 29 P.3d 870, 873 (Ct. App. 2001) . A public agency will have standing to enforce regulation statutes; for example, the attorney general has standing as the legal advisor to the state to enjoin a person practicing medicine without a license, State ex rel. La Prade v. Smith, 43 Ariz. 131, 29 P.2d 718 , modified, 43 Ariz. 343, 31 P.2d 102 (1934) , and abate nuisances per se, State ex rel. Sullivan v. Phoenix Savings Bank & Trust Co., 68 Ariz. 42, 198 P.2d 1018 (1948) . “An organization has ‘direct standing to sue [when] it show[s] a drain on its resources from both the diversion of its resources and frustration of its mission.” Valle Del Sol, Inc. v. Whiting, 732 F.3d 1006, 1017 (9th Cir. 2013) , quoting Fair Housing Council of San Fernando Valley v. Roommate.com, LLC, 656 F.3d 1216, 1219 (9th Cir. 2012) .
A candidate in a primary election has sufficient interest as an elector to restrain the placement of another’s name on the ballot. Hunt v. Superior Court, 64 Ariz. 325, 170 P.2d 293 (1946). A qualified elector has standing to restrain placement of a particular referendum on the ballot. Barth v. White, 40 Ariz. 548, 14 P.2d 743 (1932) .
A subdivision developer has standing to enjoin a nuisance which affects the habitability of residents and also affects the sale of new lots. Spur Industries, Inc. v. Del E. Webb Development Co., 108 Ariz. 178, 494 P.2d 700 (1972) . Where a statute, however, limits the right to sue for injunction to private parties, associations of these persons are of questionable standing. Sacramento Newspaper Guild v. Sacramento County Board of Supervisors, 263 Cal. App. 2d 41, 69 Cal. Rptr. 480 (Ct. App. 1968) .
Public nuisances...
