in october 2011, the liberty legal foundation filed suit in arizona, seeking to enjoin the democratic national committee from certifying obama as its nominee for the 2012 u.s. presidential election on the ground that he did not have two citizen parents and thus, it contended, was not a natural-born citizen. the foundation's complaint cited the u.s. supreme court's 1875 decision in "minor v. happersett" as supporting its claim that natural-born citizens were defined by the supreme court as "all children born in a country of parents who were its citizens". this lawsuit was dismissed july 11, 2012, for "lack of jurisdiction." a defense motion for sanctions against plaintiff's attorney, irion, was denied.