Lujan v. Defenders of Wildlife (1992)
Facts: The respondent, Defenders of Wildlife, is an organization dedicated to wildlife conservation that filed a petition against the Secretary of Interior, Manuel Lujan, seeking a declaratory judgment stating that his interpretation of a new regulation within the Endangered Species Act of 1973 was in error. The alleged misinterpretation, the Defenders argued, neglected to acknowledge the affects of United States' activities in foreign countries regarding the endangered species there within. Lujan asks if the Defenders of Wildlife have standing; has this group experienced an injury-in-fact caused by the regulation and if so is there an appropriate course of redress following. Defenders responded by indicating their standing laid within the individual members of their organizations who had visited the foreign countries in controversy.
Holding: The Defenders of Wildlife held no standing in the controversy.
Reason: The three-part standing requirement of Article III states that there are three constitutional standing requirement: Injury, Causation, and Redressability.
If any of the three requirements are jeopardized then the current controversy has no standing. The injury requirement states that the respondent must have suffered, or will suffer in the future, an incursion of a legally protected interest.
Significance: The three-part standing requirement as it is interpreted in Lujan disallows organizations to represent an injured party who is a member of that organization. Instead, the injured party must be the plaintiff of the controversy. This interpretation severely limits the role environmental organizations may have in bringing environmental cases to court. Subsequently, this case has set the precedent for citizen suits alleging procedural injuries. Furthermore, the party filing suit must be the party that was directly injured, and cannot be an organization representing that party. Significant to this case as well was the redressability requirement which states that it must be likely,