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Lujan v. Defenders of Wildlife

504 U.S. 555 (1992)

tl;dr: Plaintiffs here may not bring suit because they do not have standing, due to lack of injury in fact and redressability of th

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Lujan v. Defenders of Wildlife is a Supreme Court case that deals with a challenge to a rule interpreting the Endangered Species Act. The main issue is whether the plaintiffs have standing to seek judicial review of the rule. To establish standing, a plaintiff must show three elements: (1) an "injury in fact," (2) a causal connection between the injury and the conduct complained of, and (3) it must be likely that the injury will be redressed by a favorable decision. The Court of Appeals erred in denying the Secretary's motion for summary judgment because the plaintiffs did not provide evidence of injury and redressability. The proposed "ecosystem nexus" standing theory, "animal nexus" and "vocational nexus" approaches require a factual showing of perceptible harm at the summary judgment stage. The respondents failed to demonstrate redressability because they challenged a generalized level of government action instead of attacking the separate decisions to fund particular projects allegedly causing them harm. The legal uncertainty regarding the Secretary's authority affects redressability, and any relief the District Court could have provided against the Secretary was unlikely to produce action from the funding agencies.

The court ruled that the respondents lacked standing to bring their case because they did not show a direct injury resulting from the statute's enforcement. Administrative agencies' power is limited by granted authority, and courts can only intervene to protect individual rights beyond that authority. Plaintiffs must show a personal stake in the outcome and a direct injury that is real and immediate. Justice Stevens concurs with the judgment of reversal but disagrees with the Court's conclusion that the respondents lack standing.

The plaintiffs have standing in the case, but the Court rules that the consultation requirement in § 7(a)(2) does not apply to activities in foreign countries. Justice Blackmun dissents from the Court's decision, believing that the plaintiffs have raised genuine issues of fact regarding injury and redressability. The Court's rejection of the claim of vocational or professional injury by the respondents is unreasonable. The author disagrees with the Court's rejection of "procedural injuries" as sufficient for standing. The dissent disagrees with the Court's approach to environmental standing and believes that civil liberty includes the right to claim protection under the law for any injury.

IRACIssue, Rule, Analysis, Conclusion

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Facts & Holding

Facts:Endangered Species Act instructs Secretary of Interior to promulgate by...

Holding:Irreducible minimum of standing contains 3 elements:Plaintiff must have suffered...

Lujan v. Defenders of Wildlife

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