“None of the three lower courts dismissed Voeltz v. Obama on grounds of standing.”
I think the opinion of Judge Lewis was based on both standing and the NBC issue. As the case was filed after the Presidential Primary but before the DNC Convention, Judge Lewis said that at that time Obama was not the parties nominee and so Voeltz didn’t have the standing of a Florida voter.
As I read Judge Lewis’ Order for Dismissal, the grounds were: (1) Failure To State A Claim Upon Which Relief Can Be Granted; (2) a court cannot issue a Writ of Mandamus against itself and (3) Judge Lewis disagreed with Plaintiff Voeltz’ assertion that two U.S. citizen parents are required in order to be considered to a natural born citizen.
Judge Lewis did mention standing briefly but only as a hypothetical should the plaintiff file a declaratory judgement claim.
http://www.scribd.com/doc/99025994/FL-2012-06-29-Voeltz-v-Obama-order-dismissing-amended-complaint