killed Betty Ann seemingly leads to the inevitable conclusion that the Estate cannot show any risk of future harm. Yet application of the Lyons standard to this case is unsettling, because it allows the most egregious cases of institutional disability discrimination in violation of the ADA to continue unabated. Nonetheless, because the Supreme Court spoke broadly about the standing requirements for plaintiffs seeking injunctions, logically speaking, those requirements apply to injunctions sought for violations of the ADA. Indeed, every court to have considered the standing requirements under Title III of the ADA has held that in order for a private litigant to prove standing, she must show a risk of future harm. E.g., Jairath v. Dyer, 154 F.3d 1280, 1283 n. 8 (11th Cir.1998) (<HOLDING>); Plumley v. Landmark Chevrolet, Inc., 122 F.3d
holding that plaintiff had no standing because he had no intention of seeking further medical advice or treatment from defendant holding that plaintiff had no claim under fmla because she had suffered no diminution in income and incurred no costs as a result of alleged violation holding that appellants had no standing to challenge search of car because they had no ownership or possessory rights of any kind in the car holding that a plaintiff had no injury in fact and consequently no standing when it had no enforceable contract right against the defendant holding that the inmate had no cognizable due process claim because he had no liberty interest in being free from disciplinary segregation